This is a translation provided for convenience. In case of any discrepancy, the Russian version prevails.
Personal Data Processing Policy
This Policy has been developed in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law”) and sets out the procedure for processing, and the measures for ensuring the security of, the personal data of users of the Neolex website (the “Website”). The Policy is published in open access (Part 2 of Article 18.1 of the Law).
1. Operator
Personal data operator: Polina Mikhailovna Ermolina, applying the special tax regime “Professional Income Tax” (self-employed, Federal Law No. 422-FZ of 27 November 2018), INN 500319287601, e-mail: ermolinapolina358@gmail.com. For any questions about personal data processing, write to ermolinapolina358@gmail.com or use the feedback form.
2. Key terms
The terms “personal data”, “processing”, “dissemination”, “cross-border transfer” and others are used in the meaning set out in Article 3 of the Law.
3. Data subjects and categories of data
- Website users: name, nickname, profile photo, country and city of residence, information about countries visited and experience of staying in them, role (applicant, student, mentor, etc.), study goals, information about education, language proficiency and exam results, study budget.
- Mentors, tutors and university representatives, additionally: phone number, links to Telegram, WhatsApp, Instagram, YouTube and website, description of services and prices.
- User content: posts, comments, reviews, questions and answers, “likes”, subscriptions to other users.
- Enquiries: name, e-mail, text of the enquiry. Newsletter subscribers: e-mail.
- Subscription purchasers: e-mail for sending the receipt; bank card details are not transferred to and are not processed by the Operator.
- Technical data: browser local storage data and cookies, the account identifier of the platform on which the Website is hosted.
The Operator does not process special categories of personal data (Article 10 of the Law) or biometric data (Article 11 of the Law). Please do not post such information in your posts.
4. Purposes of processing
- registration and maintenance of the user profile, enabling sign-in to the Website;
- matching of study programmes, scholarships and internships, the “My Options” section;
- operation of social features: feed, subscriptions, “likes”, comments, reviews, map of visited countries;
- connecting users with mentors, tutors and universities;
- performance of the public offer agreement when a paid subscription is purchased, sending of cash receipts;
- responding to enquiries, handling complaints and content moderation;
- sending the newsletter (only with separate consent);
- ensuring the operability and security of the Website.
5. Legal grounds
The data subject’s consent to the processing of personal data (clause 1 of Part 1 of Article 6 of the Law), separate consent to the processing of personal data authorised by the data subject for dissemination (Article 10.1 of the Law), performance of a contract to which the data subject is a party (clause 5 of Part 1 of Article 6 of the Law), Federal Law No. 422-FZ “On Conducting an Experiment to Establish the Special Tax Regime ‘Professional Income Tax’” and the Law of the Russian Federation “On Consumer Rights Protection”.
6. Operations with data
Collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), dissemination (in respect of data authorised by the user for dissemination), depersonalisation, blocking, deletion, destruction. Processing is carried out using automated means. No decisions producing legal consequences are made on the basis of solely automated processing; the automatic profanity filter only prevents a text from being published until it is corrected.
7. Publicly available data
Name, nickname, photo, role, country and city of residence, map of visited countries and experience, the “Highlights” section, posts, comments, reviews, number of followers and the contacts that the user has personally posted in the profile are visible to other users. They are processed on the basis of a separate consent to dissemination. The user may at any time delete this information from the profile or withdraw the consent.
Private messages. Messages between users are stored on the Operator’s server and are accessible only to the sender and the recipient. The Operator does not read messages, except when reviewing a complaint about a breach of the Community Rules submitted by a participant of the conversation. Messages are deleted together with the account. A user may block another user; the list of blocked users is visible only to its owner.
Stories. Stories are public posts by users with a paid subscription; they are deleted automatically after 24 hours.
8. Storage, localisation and cross-border transfer
Personal data are stored no longer than required by the purposes of processing and are destroyed within 30 days after the purposes are achieved or consent is withdrawn, unless otherwise provided by law. Payment information is stored for the periods established by tax legislation.
When collecting personal data of citizens of the Russian Federation, the Operator ensures the recording, systematisation, accumulation, storage, clarification and retrieval of such data using databases located in the territory of the Russian Federation (Part 5 of Article 18 of the Law). The current version of the Website is a prototype hosted by a foreign platform provider; before starting to collect data of Russian citizens in production mode, the Operator will move the databases to the territory of the Russian Federation, and any cross-border transfer is carried out only after notifying Roskomnadzor in accordance with Article 12 of the Law.
9. Transfer to third parties
Data may be transferred without consent only in cases expressly provided for by law. With the user’s consent and to the extent necessary to provide the services, data are transferred to: the hosting provider, the payment operator (to accept payments), and the Federal Tax Service of Russia via the “My Tax” (Moi Nalog) app (information for generating the receipt). The Operator does not sell personal data and does not transfer them for advertising purposes.
10. User rights
The user has the right to: obtain information about the processing of their data (Article 14 of the Law); demand that the data be clarified, blocked or destroyed if they are incomplete, outdated, inaccurate or processed unlawfully; withdraw consent; appeal against the Operator’s actions to Roskomnadzor or in court. Requests are sent to ermolinapolina358@gmail.com. The Operator responds within 10 business days of receipt of the request; this period may be extended by no more than 5 business days with notice of the reasons.
11. Protection measures
The Operator applies legal, organisational and technical measures (Articles 18.1 and 19 of the Law): appointment of a person responsible for processing (the Operator itself), differentiation of access rights to data, secure connection (HTTPS), prohibition of displaying hidden sections of the database to unauthorised persons, backup, and monitoring of compliance with the Policy. If a data leak is detected, the Operator notifies Roskomnadzor within the time limits established by Part 3.1 of Article 21 of the Law.
12. Cookies and local storage
The procedure for their use is described in the Cookie Policy. The Website does not use third-party analytics or advertising systems; fonts are loaded from the same server as the Website.
13. Changes to the Policy
The Operator may amend the Policy. A new version takes effect from the moment it is published on this page.
Version of 13 October 2026.