Privacy Policy and Personal Data Processing

Last updated: 25.09.2026

Version: 1.2

This Privacy Policy and Personal Data Processing Policy (“Policy”) sets out how we collect, use, store, share, and protect personal data of users of the website https://commexcell.ru, as well as individuals who purchase products or services, access training, submit consultation requests, contact us, or otherwise interact with the Operator.

By using the Website, completing forms, creating an account, placing an order, paying for services, or otherwise providing personal data, the User confirms that they have read this Policy. If the User does not agree with its terms, they must discontinue use of the Website and refrain from providing personal data.

1. Operator and Scope
Personal Data Operator:
Andrey Kryukov
INN 616511140932
Email: ce@andreykryukov.com
Website: https://commexcell.ru

Hereinafter referred to as the “Operator,” “we,” “us,” or “our.”

This Policy applies to all information that the Operator obtains about users of the website https://commexcell.ru (“Website”), services, educational programs, consultations, digital products, feedback forms, and other channels of interaction.
This Policy does not govern the processing of data on third-party websites or services to which links may be placed on the Website. The User should review the privacy rules of such third parties independently.

2. Principles of Data Processing
We process personal data on a lawful and fair basis, in the amount necessary for specific and predetermined purposes.
We adhere to the following principles:

• We process data only when there is a lawful basis
• We collect only the data that are necessary for the stated purposes
• We do not use data in ways incompatible with the original purposes of processing without an appropriate legal basis
• We take reasonable organizational and technical measures to protect data
• We limit access to data to employees and contractors who need it to perform their tasks
• We retain data no longer than required by the purposes of processing, a contract, or applicable law
• We enable users to exercise their rights within the scope permitted by applicable law

3. What Data We Process
Depending on how you interact with us, we may process the following categories of data.
3.1. Data Provided by the User

• Surname, first name, and patronymic, if provided
• Name or pseudonym used in the personal account
• Email address
• Phone number
• City, country, and other information voluntarily provided
• Data required for invoicing, documentation, and performance of contracts
• Information contained in requests, applications, reviews, messages, and other correspondence
• Account data, including user identifiers, order history, purchased courses and modules, access statuses, learning progress, and issued certificates
• Results of tests, assignments, and other learning activities, where applicable
• Identity-document details only where necessary for a specific lawful purpose, required by law, certification conditions, or otherwise lawfully requested

3.2. Order and Payment Data
We may process information about orders, amounts, currency, payment status and method, and data necessary for accounting, tax, and contractual records.
We do not receive or store full bank card details if payment processing is performed by an external payment provider. Card and banking details are processed by such providers in accordance with their own rules and legal requirements.

3.3. Technical and Analytics Data
When you visit the Website, the following may be automatically collected:

• IP address
• Browser type and version
• Device type and operating system
• Date, time, and duration of visit
• Pages viewed, referral source, and actions on the Website
• Technical identifiers and event logs
• Cookies and similar technologies
• Aggregated usage statistics

To analyze Website performance, we may use Yandex Metrica, Google Analytics, and other web analytics services — only if they are actually used. Such services may use cookies and receive de-identified or pseudonymized technical data in accordance with their own policies.

4. Purposes of Processing
We process personal data for the following purposes:

• Handling requests, enquiries, and consultation applications
• Registering and administering user accounts
• Concluding, performing, amending, and terminating contracts
• Processing orders, payments, refunds, and other transactions
• Providing access to educational programs, digital materials, courses, modules, consultations, and other products or services
• Identifying Users and ensuring secure access to the personal account
• Supporting users and resolving disputes
• Confirming completion of training, recording educational results, and issuing certificates, where applicable
• Complying with legal requirements, including tax, accounting, and other mandatory records
• Ensuring Website security, preventing fraud, unauthorized access, and abuse
• Analyzing and improving the Website, products, learning materials, services, and user experience
• Sending service, organizational, and legally significant notifications
• Sending news, offers, invitations, and information about products and services, where there is a proper legal basis and an option to opt out
• Protecting the rights, legitimate interests, and property of the Operator, users, and third parties within the scope of applicable law

5. Legal Bases for Processing
We process personal data on one or more of the following legal bases:

• The User’s consent to the processing of personal data
• Necessity to conclude or perform a contract with the User
• Necessity to comply with legal obligations
• Our legitimate interests, including ensuring Website operation and security, preventing fraud, improving service quality, conducting business communications, and defending our rights in potential disputes, provided that such interests do not override the User’s rights and freedoms
• Other grounds provided by applicable law

User consent may be given by completing forms on the Website, ticking a relevant checkbox, clicking a submit button where explicitly indicated, signing a document, or otherwise indicating a clear affirmative action.
Where separate consent is required, we request it in the relevant form. The User may withdraw consent as described in Section 11 of this Policy.

6. Cookies and Similar Technologies
The Website may use cookies and similar technologies to:

• Ensure the Website and its core functions operate properly
• Remember User settings and preferences
• Maintain security and prevent abuse
• Analyze traffic and usage patterns
• Improve content, interface, and service quality
• Evaluate the effectiveness of advertising and information campaigns, where applicable

Users may restrict or disable cookies in their browser settings. This may affect the proper functioning of certain Website features.
Where required by applicable law, we request consent for non-essential cookies through a cookie banner or preference management mechanism.

7. Sharing Data with Third Parties
We do not sell Users’ personal data.
We may entrust the processing of personal data to, or transfer data to, third parties in the amount necessary to achieve the purposes of processing, including the following categories of recipients:

• Payment services and banks — to process and confirm payments
• Hosting providers, cloud services, IT infrastructure and technical support vendors
• Educational platforms, learning management systems, and digital access services
• CRM systems, email and messaging services, and customer support tools
• Analytics services, subject to legal requirements and applicable consent settings
• Accountants, auditors, lawyers, financial consultants, and other professional advisers bound by confidentiality obligations
• Government authorities, courts, law enforcement agencies, and other persons — in cases and manner prescribed by law
• Parties involved in reorganization, sale of business, investment, or other corporate transactions, subject to confidentiality and legal safeguards

We undertake to select contractors and partners with due care and, where necessary, to enter into agreements providing for confidentiality and data protection measures.

8. International Data Transfers
Certain digital services may involve processing or storage of personal data outside the User’s country of residence.
International transfers of personal data are carried out by the Operator only where there is a lawful basis and with appropriate safeguards as required by applicable law.
With respect to personal data of citizens of the Russian Federation, the Operator complies with applicable legal requirements on localization, international transfers, and other relevant obligations. When collecting personal data of Russian citizens via the internet, basic operations of recording, systematization, accumulation, storage, updating, and retrieval must be carried out using databases located in the Russian Federation, subject to statutory exceptions.

9. Retention and Deletion of Data
We retain personal data only for as long as necessary for the purposes of processing, performance of a contract, protection of legitimate interests, resolution of disputes, or compliance with legal requirements.
Indicative retention criteria:

• Account and learning access data — for the duration of the account and access to the product, and for a reasonable period thereafter
• Order, payment, contract, tax, and accounting records — for periods required by applicable law
• Enquiry and application data — for the period necessary to handle the enquiry and subsequent business communication
• Marketing data — until consent is withdrawn, the User opts out, or the purpose ceases to apply
• Analytics data — within the periods set by the relevant service and the Operator’s settings

When the purposes of processing are achieved, upon withdrawal of consent (if no other legal basis exists), or upon expiry of a mandatory retention period, we delete or de-identify personal data.

10. Data Security Measures
We take necessary and reasonable legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, provision, and other unlawful actions.
Such measures may include:

• Access controls and segregation of duties
• Use of passwords, authentication, and access management
• Application of secure transmission channels where technically feasible
• Limiting access by employees and contractors on a need-to-know basis
• Backup, logging, and monitoring of information systems
• Periodic review of internal processing and security procedures
• Training of persons with access to personal data on confidentiality requirements

Despite the measures taken, no method of transmission over the internet and no storage system can guarantee absolute security. Users are also responsible for keeping their passwords confidential, not sharing access credentials with third parties, and promptly notifying us of any suspected unauthorized access.

11. User Rights
Users have the right, within the scope permitted by applicable law, to:

• Obtain information about the fact, purposes, methods, and legal bases of processing of their personal data
• Request correction, blocking, or deletion of inaccurate, outdated, incomplete, unlawfully obtained, or excessive data
• Withdraw consent to the processing of personal data
• Object to marketing communications
• Lodge a complaint with a competent authority or court
• Exercise other rights provided by applicable law

To exercise these rights, Users may send a request to ce@andreykryukov.com with the subject line “Personal Data.”
The request should contain sufficient information to identify the User and process the request. We may require additional details to verify the identity of the applicant and prevent unauthorized access to data.
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. We may also continue processing data after withdrawal where there are other lawful grounds, including performance of a contract, legal storage obligations, compliance with legal duties, or defense of rights in a dispute.

12. Marketing Communications
We may send Users information about products, services, training, events, and special offers where permitted by applicable law.
Users may opt out of marketing communications at any time by:

• Clicking the “Unsubscribe” link in an email, where available
• Adjusting preferences in the personal account, if such functionality is provided
• Sending an email to ce@andreykryukov.com with the subject line “Opt-out from Marketing Communications”

Opting out of marketing messages does not stop essential service-related communications required to perform a contract or provide services, such as order confirmations, receipts, payment notifications, access information, security notices, and other service updates.

13. Data of Minors
The Website, products, and services are not intended for individuals below the age at which they can independently consent to the processing of personal data under applicable law.
If we become aware that personal data of a minor has been collected without the required consent of a legal guardian, we will take reasonable measures to cease processing and delete such data, unless otherwise required by law.

14. Limitation of Liability
We are not liable for the actions of Users, third parties, or external services that are beyond our reasonable control.
We are not responsible for the content, security, availability, or data processing practices of third-party resources to which Users navigate via links from the Website.
Users are responsible for the accuracy of the data they provide, for compliance with the rights of third parties when transmitting information to us, and for the security of their account credentials.
Nothing in this Policy limits User rights that cannot be restricted under applicable law, nor does it relieve the Operator of obligations expressly imposed by law.

15. Changes to This Policy
We may update this Policy at any time, including in connection with changes in legislation, business processes, technologies used, or the scope of services provided.
A new version of the Policy becomes effective from the date of its posting on the Website, unless another effective date is specified in the revised version. Where material changes are made, we may additionally notify Users by an available method, if required by law or technically feasible.
The current version of the Policy is available at:
https://commexcell.ru/confpol

16. Contact Information
For questions regarding the processing of personal data, exercising rights, withdrawing consent, or submitting complaints, please contact:
Andrey Kryukov
Email: ce@andreykryukov.com

Website: https://commexcell.ru