Personal Data Processing Policy
*Courtesy English translation. The Russian text (PRIVACY_POLICY.ru.md, «Политика обработки персональных данных») is the binding version.*
Operator: [not set — Settings → Operator], INN/OGRN [not set — Settings → Operator], address: [not set — Settings → Operator], e-mail: [not set — Settings → Operator], phone: [not set — Settings → Operator] (the "Operator").
Platform: "Iterum School" — https://www.lms.iterum.school (the "Platform").
Person responsible for organising personal-data processing: [not set — Settings → Operator], [not set — Settings → Operator].
Document version: 2026-08-22. Published without restriction under art. 18.1(2) of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data".
1. General
- This Policy sets out how the Operator processes and protects the personal data ("PD") of Platform users: students, their parents (legal representatives), teachers and administrators.
- It is based on the Constitution of the Russian Federation, Federal Laws No. 152-FZ "On Personal Data", No. 149-FZ "On Information", No. 273-FZ "On Education", No. 38-FZ "On Advertising" and other Russian legislation.
- Using the Platform means you agree with this Policy. Consent to PD processing is given as a separate document at first sign-in (152-FZ art. 9). Refusing consent makes it impossible to use the Platform.
2. Data subjects and data collected
| Subject | Personal data |
|---|---|
| All users | full name, e-mail, phone number, role and account status, password (stored only as a bcrypt hash), interface language, photo (avatar, if uploaded), Telegram ID (if provided) |
| Students | date of birth (to decide whether a representative's consent is required); enrolment and course/module/lesson access; progress (lesson completion, quiz results, time spent); homework with attached files, text and voice notes; group and timetable; attendance; parent / legal-representative details (name, phone, e-mail) |
| Parents / legal representatives | relationship; if they have an account — name, e-mail, phone, password; read-only access to their children's data |
| Teachers | assigned courses/modules/groups; grades and feedback given; remuneration records (visible only to administrators with the Finance right) |
| All (communications) | internal chat messages; records of information mailings and their status |
| All (finance) | invoices, amounts, payment status and method, fiscal receipt number. Full card details are never stored on the Platform |
| All (technical) | IP address, browser details, sign-in date and time, session identifier (cookie), consent records (date, time, IP, document version) |
Special categories of PD (health, ethnicity etc.) and biometric data are not processed.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Provision of educational services, organisation of learning, attendance and progress records | paid educational services agreement (152-FZ art. 6(1)(5)); consent of the subject / legal representative |
| Communication with the student and representatives about learning (timetable, assignments) | agreement; consent |
| Invoicing, payment records, accounting | agreement; Federal Law No. 402-FZ "On Accounting"; Tax Code |
| Information and promotional messages | separate consent (38-FZ art. 18, 152-FZ art. 15); may be withdrawn at any time |
| Platform security, protection against unauthorised access | Operator's legitimate interest; 152-FZ art. 19 |
| Compliance with law, responses to authorised bodies | law |
No decisions with legal consequences are taken solely on the basis of automated processing. PD is not used for profiling or third-party advertising and is never sold.
4. How data is processed
- Processing is automated: collection, recording, systematisation, accumulation, storage, updating, extraction, use, transfer (access) within section 4.2, depersonalisation, blocking, deletion, destruction.
- Only the Operator's staff and teachers who need PD for their duties have access, limited by their role in the Platform (permissions matrix). A teacher sees only their own students; a parent only their own children.
- Localisation. Recording, systematisation, accumulation, storage, updating and extraction of Russian citizens' PD is carried out in databases located in the Russian Federation: [not set — Settings → Operator] (152-FZ art. 18(5)). No cross-border transfer takes place.
- PD is not shared with third parties except: the hosting provider (under contract, storage on servers in Russia only); telecom / mailing providers — only with separate marketing consent and only contact data; state bodies on lawful request.
- Lesson videos are hosted on Russian video platforms or the Operator's own servers. No third-party analytics or trackers are embedded.
- Cookies. Only strictly necessary cookies are used: the session ID (
PHPSESSID, deleted when the browser closes) and the sign-in page language (login_lang). No tracking or advertising cookies.
5. Retention and destruction
| Data | Period |
|---|---|
| Account and learning data | period of study + 3 years (or as set in the agreement), then anonymisation |
| Financial documents (invoices, payments) | 5 years (402-FZ art. 29) — kept in anonymised form after the account is anonymised |
| Security log (sign-ins, actions), technical data | 1 year |
| Chat messages | 1 year |
| Consent records | whole processing period + 3 years (proof of consent) |
On withdrawal of consent the Operator stops processing and destroys (anonymises) the PD within 30 days (152-FZ art. 21(5)), except data that must be kept by law. Destruction is automatic (account anonymisation: name, contacts, date of birth, files, messages and learning history are removed) and is logged.
6. Your rights
A data subject (or, for a minor, their legal representative) may (152-FZ art. 14):
- obtain information about the processing and a copy of their data — on the Platform: Settings → My Account → Download my data (instant export), or by request to [not set — Settings → Operator] — answered within 10 business days (152-FZ art. 20);
- demand correction, blocking or destruction of incomplete, outdated, inaccurate or unlawfully obtained PD;
- withdraw consent (Settings → My Account → Withdraw consent, or in writing) — access to the Platform then ends and data is destroyed within 30 days;
- withdraw marketing consent separately without giving up the course;
- complain to Roskomnadzor (https://rkn.gov.ru) or to a court.
7. Minors
Consent for a student under 18 is given by a parent or other legal representative (Civil Code art. 26, 28). If no date of birth is on file the student is treated as a minor. The representative's consent is recorded on the Platform from the parent account or on paper (the administrator then marks it in the system). A parent sees their child's data in the parent portal.
8. Security measures
Legal, organisational and technical measures under 152-FZ art. 18.1 and 19: an appointed responsible person; this Policy and internal regulations; role-based access; bcrypt password hashes; CSRF, SQL-injection and session-fixation protection; sign-in throttling; HTTPS; uploaded files are never executed; a log of actions with PD; regular backups inside Russia.
Incidents. If an unlawful transfer (leak) of PD is detected, the Operator notifies Roskomnadzor within 24 hours, submits the internal investigation results within 72 hours (152-FZ art. 21(3.1)) and informs affected subjects.
9. Operator details
- Roskomnadzor personal-data operator notification: [not set — Settings → Operator].
- Education licence: [not set — Settings → Operator].
- Privacy requests: [not set — Settings → Operator], [not set — Settings → Operator].
10. Changes
The Operator may amend this Policy. The new version is published on this page with its version number; after material changes users re-confirm consent at next sign-in.