Consent to the Processing of the User’s Personal Data

I, the User, freely, of my own will and in my own interest, give my specific, substantive, informed, conscious, and unambiguous consent to Individual Entrepreneur Katerina Valerievna Kamyshova (OGRNIP: 326774600180481, INN: 771594439274, registered address: 127349, Moscow, Leskova St., 9, apt. 148; hereinafter, the “Operator”) to process my personal data when I use the website at https://hanziway.com/ (hereinafter, the “Website”) on the following terms.

This consent is given by selecting a separate checkbox in a Website form and submitting that form.

1. Personal Data

• last name, first name, patronymic, email address, telephone number, date of birth, and gender, where provided by the User;
• login and internal account identifier;
• internal payment-record identifier, information about the selected plan and number of access days, payment type and frequency, amount and currency, payment and subscription statuses and dates, and technical offer, invoice, payment, contract, and subscription identifiers;
• information about the provision and duration of PRO access, automatic renewal, upcoming charges, cancellation of renewal, refunds, chargebacks, or payment disputes;
• information about the accepted versions of the Terms of Use and Privacy Policy and the User’s automatic-renewal choice;
• IP address, technical device, browser and operating-system information, session parameters, and time zone required to operate and protect the Website and process the payment;
• information voluntarily provided by the User to support.

The Operator does not request the full bank-card number, card expiration date, CVV/CVC code, SMS codes, or online-banking credentials. The User enters such information directly on the relevant payment-service page.

2. Purposes of Processing

• registering the User, operating the Personal Account, and providing Website functionality;
• entering into and performing the agreement with the User;
• creating, confirming, and accounting for one-time and recurring payments, providing and extending PRO access, displaying payment history, and managing automatic renewal;
• sending service notifications and handling enquiries, refunds, chargebacks, and payment disputes;
• operating and securing the Website and correcting errors;
• complying with legal requirements and protecting the rights and legitimate interests of the Operator and the User.

3. Processing Methods and Operations

Processing may be performed by automated, non-automated, or mixed means and may include collection, recording, systematisation, accumulation, storage, clarification (updating and modification), retrieval, use, transfer (provision and access), including cross-border transfer, depersonalisation, blocking, deletion, and destruction of personal data.

4. Transfer and Entrusted Processing

To operate the Website, the Operator may entrust personal data processing to the following server-infrastructure providers:

• IOT JSC (121205, Moscow, Skolkovo Innovation Center, Bolshoy Blvd., 42, bldg. 1, fl./prem./ws. 0/138/12);
• Datacenter JSC (2 Nagornoye Highway, Khimki, Moscow Region);
• Ixelerate LLC (33G Altufyevskoe Highway, Moscow).

If the User selects payment in US dollars, the Operator transfers a limited set of data to the Republic of Cyprus to LAVALANE LTD, registration number HE 387079, registered at 3 Kallipoleos Street, Office 102, 1055 Nicosia, Cyprus. The transfer is required to create and manage the payment or subscription, confirm its status, provide PRO access, and cancel future charges.

To create a payment or subscription, the Operator transfers the User’s email address, selected offer identifier, USD currency, payment frequency, payment-page language, and technical return-page URLs. To check the status, the technical identifier of the relevant payment or subscription is transferred. To cancel automatic renewal, the User’s email address and subscription contract identifier are transferred. Data entered on the external payment page is processed in accordance with the recipient’s Privacy Policy.

This consent does not itself activate automatic renewal. Automatic renewal is activated only by the User’s separate express choice during checkout and may be cancelled in the “Payments” section of the Personal Account.

5. Duration and Withdrawal

This consent is valid from the moment it is given until the purposes of processing have been achieved or the consent is withdrawn, unless longer processing is required or permitted by law or by the agreement with the User.

The User may withdraw this consent by sending a request to the Operator’s address stated above or by email to hanziway@yandex.ru. The request must contain information sufficient to identify the applicant and confirm the applicant’s relationship with the Operator. Withdrawal does not affect the lawfulness of processing carried out before the Operator receives the request.

I confirm that I have read Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” and the Privacy Policy published on the Website.