Privacy Policy

Ararat International School is committed to protecting your privacy: it is the foundation of a safe and trustworthy educational community. This Privacy Policy describes how we collect, use and protect your data when you use the services of Ararat International School or visit our public website.

Ararat International School provides its services not only to individual users, but also to organizations such as schools and educational institutions. If access to our services is provided to you through your organization, or you use an account associated with your organization and we act solely on its behalf, this Privacy Policy does not apply. In such cases, the terms of use are governed by the privacy policies of your organization.

Because Ararat International School is an educational platform intended, among others, for children, we take additional measures to protect their privacy, including that of users under 13 years of age.

Our Privacy Policy

Ararat International School is an online educational platform that allows registered parents or guardians (“Parents”) to enroll students (“Students”) in online courses and classes, and registered teachers (“Coaches”) to create, deliver and promote these classes (the “Services”).

This Privacy Policy describes what personal data Ararat International School collects from registered parents, coaches and students, as well as how we collect and use the personal data of visitors to our public website (collectively, the “Site”).

Students using the services of Ararat International School work in a special mode called Learning Space, which provides additional protective measures, including protection for children under 13 years of age, as set out in our Children’s Privacy Policy.

Information We Collect

When you visit our Site, we may collect information about you which, alone or in combination, may be used to identify you, your device or your household (“Personal Data”), as described below:

Personal Data you provide through the Site:

We collect Personal Data that you provide to us directly, for example when you register an account with Ararat International School in order to use the services. For example, we may collect the following information:

📌 Contact information:

• Name or public name
• Email address
• Telephone number

📌 Demographic data:

We may collect age, month and year of birth, gender, preferred pronouns and similar data if they are voluntarily provided in the profile.

📌 Sensitive data:

• Parents may provide information relating to the learning needs of their child (for example, a health condition or the need for special arrangements).
• Teachers and students must not discuss or share sensitive data with each other.
• If we suspect that a student is over 18 years of age, we may ask the parent to provide a supporting document (for example, a birth certificate). We do not record such data, apart from the month and year of birth.

📌 Content and files:

• The classes you are enrolled in
• Video and audio recordings of classes, which are recorded automatically
• Content you upload (profile photo, messages in the classroom)
• A profile photograph uploaded by you or linked to Facebook
• Data provided in the “About me” section
• Information provided in reviews
• Teacher data required for background checks

📌 Passively collected data:

When you use our Site, we and our third-party partners may automatically collect and store certain data, for example:

🔹 Usage data – login times, search queries, pages viewed.

🔹 Identifiers and device information – IP address, device

identifiers (for example, cookies), operating system and browser type. This data may be used to analyze site traffic.

Cookies

On our Site, we and third-party services that provide additional functionality may use cookies technology. Cookies help improve the functionality of the site, analyze its use and provide a personalized user experience.

Most web browsers have a “Help” section where you can find information on how to be notified when new cookies are received and how to disable them. We recommend leaving cookies enabled, as they allow you to take advantage of all the features of the site. You can read more about cookies in the section

“Cookie Policy”.

Inferred (interpreted) data

We may analyze the data collected and automatically generate information about your likely interests. For example, we may determine which chess courses may be of interest to you based on your search queries. We may also determine your approximate location (city, country) from your IP address.

Aggregated personal data

We may aggregate user data (including personal data) and use it in aggregated form to analyze and improve the platform. Such data does not make it possible to identify a specific user.

Data processing

We process your personal data on lawful grounds, including:

• Performance of a contract – in order to provide our services.
• Legitimate interests – in order to improve the service, ensure security and protect our users.
• Consent – where this is required by the law of your country.
• Compliance with legal obligations – in cases where this is required by law.

Mandatory personal data

Certain personal data is required in order to make full use of the platform:

• For teachers – teachers are required to provide information for background checks and to turn on their camera during online lessons.
• For students – students, except in certain cases, are required to turn on video at least at the beginning of a class in order to confirm their identity and ensure the safety of the participants.

You may decline to provide some of this data, but this may limit your access to the functionality of the platform.

Sources of personal data

The main source of personal data about you is you yourself. However, we may also obtain information from the following sources:

• Integrated services and partners. Third-party services and platforms, including social networks and payment systems, with which you interact through the Ararat platform.
• Partners in joint projects. Organizations with which we cooperate in the field of online education, as well as schools and educational institutions that use our platform.
• Service providers. Companies that help us provide our services (for example, analytics systems, payment solution providers, teacher verification systems).
• Public sources. Government registers, academic databases and services for verifying the qualifications of teachers.

How we use your personal data and other information

We may use any category of your personal data for the following purposes:

• Operating and improving the Ararat platform, including fixing errors, supporting users, personalization and improving the quality of the service.
• Sending notifications and marketing messages, including recommendations for new courses, special offers and news for parents and teachers (with the option to unsubscribe from promotional mailings).
• Communicating with users, including confirming registration, sending updates, customer support and administrative notifications.
• Developing new features and analyzing data, including studying user behavior on the platform in order to improve the learning process.
• Verifying teacher data, including background information, in order to ensure the safety of students.

We may combine data from various sources in order to provide you with a more convenient, personalized experience.

Ararat teachers may review recordings of their own classes, use them to analyze the effectiveness of lessons and make them available to parents and students for repeat viewing. We may also use recordings to improve teaching quality, provide customer support and comply with regulatory requirements.

If you are a parent or a teacher, Ararat may use your contact details for marketing purposes, including informing you about new courses, events and features of the platform. Every promotional email contains instructions on how to opt out of such notifications. If you wish to stop receiving marketing emails altogether, please contact us. However, even in that case we will continue to send you important notifications relating to the use of the platform.

Storage and transfer of personal data

Your data, including personal data, may be transferred to and stored on servers outside your country, where data protection laws may differ from those in force in your region.

Disclosure of your personal data and other information

We may share your personal data with third parties with your consent or when you interact with them explicitly. For example, we use third-party services to process payments.

We may also share data in the following cases:

1⃣ Teachers and partner schools. When registering, parents agree that teachers may have access to information about students, their progress and the lessons they have attended. In some cases, teaching may be provided not by a single teacher but by an educational organization, and in such cases the entire teaching team may have access to the materials.

2⃣ Business transfers. In the event of a reorganization, investment or transfer of the management of the platform to a third party, user data may be transferred to the new owners.

3⃣ Third-party services. We use the services of third-party companies (for example, payment processing, analytics and advertising). These companies may have access to your data in order to keep the platform running and to personalize the user experience.

4⃣ Legal requirements. We may disclose personal data if this is required by law or in order to:

• protect the rights of users and of the platform,
• ensure the security of the service,
• comply with legal obligations.

5⃣ Third-party analytics services. We use analytics tools, for example Google Analytics, in order to understand how users interact with the platform. More information: www.google.com/policies/privacy/partners.

6⃣ Links to third-party resources. Teachers may recommend third-party learning resources to students. If you decide to use them, the processing of data will be governed by their privacy policies.

Your personal data may be transferred to third parties only in the following cases:

• Partners in the EU – data is transferred in accordance with the GDPR.
• Partners in the Russian Federation – data is processed in accordance with Federal Law No. 152-FZ “On Personal Data”.
• International transfers – where data is transferred outside your country, we ensure an appropriate level of data protection, for example by using the EU Standard Contractual Clauses (SCCs) or other mechanisms.

Publicly posted information

You can share data and messages with other users through our platform. We strongly recommend that you do not publish personal or confidential data.

We expect users to observe community standards, respect the privacy of others and not to distribute the personal information of third parties.

User profile:

Your public profile will be visible to other users of the platform. You can add such details as first name, last name, photograph, short description.

We do not control the further use of information published in a profile, so please think carefully about the data you wish to make available.

Online classes:

If you take part in online classes, other users may see your video, your name and the materials you upload.

Public discussions:

You can take part in public discussions on the platform. All information published there becomes available to all users.

Messages:

Students can send messages to teachers, and parents can communicate with each other and with teachers. Parents have access to the messages of their children.

Once a message has been published or sent, we no longer control its further distribution.

Data security

We take all possible measures to protect the personal data of users. However, the internet is not a completely secure environment, and we cannot guarantee absolute protection of data.

You are responsible for the security of your account credentials. Do not share your password with third parties and do not use the same passwords for our platform and for other services.

Do Not Track (DNT)

The Do Not Track (DNT) feature allows you to prevent websites from tracking your activity. You can enable or disable DNT in your browser settings.

At present our platform does not support DNT, but we process the data of all users in accordance with our privacy policy.

Access to data and keeping it up to date

We guarantee that users can change, delete or restrict the use of their personal data. Up-to-date data helps us provide a better service.

Additional notice for California residents This section applies only to users from California. Data collected over the last 12 months

We collect and store data in accordance with California Civil Code § 1798.140(o). Use of data

We use all categories of personal data in accordance with our policy.

Disclosure of data

We do not share personal data with third parties, except in the cases set out in our privacy policy.

Rights of users from California

If you are a California resident, you have certain rights in respect of your personal data under the law of that state.

• Access to data and portability

You can ask us which personal data we have collected over the last 12 months.

Once the request has been verified, we will provide:

• The categories of data collected;
• The sources from which they were obtained;
• The purposes of processing;
• The categories of third parties with whom we share data;
• The specific data we hold about you.
• Right to opt out of the sharing of data (Opt-Out)

You have the right to opt out of the sharing of data with third parties.

If you do not want your data to be used for advertising or analytics purposes, send a request to info@araratchess.ru with the subject line “Do Not Sell My Personal Information”.

We do not share the personal data of persons under 18 years of age, unless we obtain

explicit consent (opt-in).

• Deletion of data

You can request the deletion of all your personal data, if their retention

is not required by law.

Once the request has been verified, we will delete your data and inform our partners accordingly.

• Non-discrimination

We do not restrict access to our platform and do not charge higher prices to users who have exercised their rights.

How do I submit a request?

You can send a request to info@araratchess.ru, stating:

1. Full name (as in your account);
2. The email address associated with the account;
3. Telephone number (for verification);
4. Type of request (access, deletion, etc.).

How a request is processed

• Acknowledgement of receipt of the request — within 10 days.
• Processing of the request — up to 45 days (may be extended to 90 days).

Additional rights of users from California

California residents under 18 years of age who are registered users of online services have the right to have removed the content they have published, in accordance with Section 22581 of the California Business and Professions Code.

To remove content you have published, send a detailed description

of the material to be removed to info@araratchess.ru.

⚠ Important: Your request does not guarantee the complete removal of the content, since the law may not require or may not permit removal in certain cases.

Rights of users from Europe (GDPR)

If the processing of your personal data is governed by the law of

the European Union (GDPR), you have the following rights:

✅ 1. Access, correction and deletion

You can request access to, correct or delete your personal data.

✅ 2. Data portability

If data is processed automatically on the basis of a contract or of your consent, you can obtain a copy of it in a convenient format.

✅ 3. Withdrawal of consent

If the processing of data is based on your consent, you can withdraw it at any time.

✅ 4. Restriction of processing and objection

You can restrict the processing of data or object to processing in certain cases.

✅ 5. Instructions regarding data after death (France)

Residents of France may leave specific instructions regarding the use of their data after their death.

To exercise these rights or to contact our data protection officer, please write to us at info@araratchess.ru.

If we process data on behalf of another organization (for example, a school), you should contact that organization directly.

📌 You also have the right to lodge a complaint with the data protection authority in your country, but we recommend that you contact us first, so that we can resolve your issue directly.

Rights of users from Russia (Federal Law No. 152-FZ)

If the processing of your personal data is governed by the law of the Russian Federation (Federal Law No. 152-FZ “On Personal Data”), you have the following rights:

✅ 1. Access, correction and deletion

You can request information about your personal data and require it to be corrected or deleted if it is inaccurate or no longer up to date.

✅ 2. Restriction of processing and withdrawal of consent

You can restrict the processing of your data or withdraw your consent to its processing, if the data is processed on the basis of your consent.

✅ 3. Prohibition on the dissemination of personal data

You can require the dissemination of your personal data to be restricted if you do not want it to be shared with third parties.

✅ 4. Information about the transfer of data

You have the right to know to whom and for what purposes your personal data is transferred.

✅ 5. Applying to Roskomnadzor

If you believe that your rights have been infringed, you can lodge a complaint with

Roskomnadzor, the authority that regulates the processing of personal data in Russia.

To exercise these rights, please write to us at info@araratchess.ru. If we process your data on behalf of another organization (for example, a school), you should contact that organization directly.

📌 We strive for transparency in the processing of personal data and are ready to resolve your issue promptly.

Grounds for processing personal data

We process personal data on the basis of:

🔹 Your consent;

🔹 The need to provide services and to perform contracts;

🔹 Legal and statutory requirements;

🔹 Legitimate interests (for example, ensuring security and protecting data).

Retention period for personal data

We retain personal data for as long as is necessary to provide our services, to carry out the transactions you request, to comply with legal obligations, to resolve disputes, to enforce our agreements and for other legitimate business purposes.

📌 Your personal data may be stored and processed on servers in various countries, including the USA, Europe and Russia. We comply with the requirements of the GDPR, COPPA, and also with Russian law in order to protect your data.

Retention periods may vary considerably depending on the type of data, the context of its processing and factors such as:

• The expectations of users and their consent,
• The sensitivity of the data,
• The availability of tools that allow users to delete data,
• Legal and contractual obligations.

📌 Example: We keep lesson recordings for 90 days from the date on which they took place.

Cookie Policy

What are Cookies?

Cookies are small text files, which may be placed on your computer or mobile device and make it possible to uniquely identify your browser or device.

Cookies are used together with web-beacons (also known as single-pixel GIF files or transparent GIFs) — these are electronic images contained on a website or in emails that can read the cookies placed on your device.

What are Cookies used for?

Cookies and similar technologies allow a website or service to recognize your device, if it has already visited that site.

🔹 The main functions of cookies:

✅ Analyzing how the site is used,

✅ Providing convenient navigation,

✅ Remembering your settings and preferences,

✅ Improving the user experience.

We, as well as our analytics and advertising partners, use cookies and other identifiers (for example, the IP address) to collect personal data (which pages you visit, which links you follow, etc.).

We may also use cookies for targeted advertising.

Other terms

🔹 Your access to and use of our site are governed by the Terms of Use.

Changes to the Privacy Policy

We may amend this Privacy Policy at any time.

📌 How will you find out about changes?

• We will post a notice of significant changes,
• In the event of material changes we may ask for your consent, if this is required by law.

🗓 The date of the last update is always shown at the top of the document.

Contact us

📩 If you have questions about the Privacy Policy of Ararat International School, you can write to us:

✉ Email: info@araratchess.ru

Children’s Privacy Notice

This section explains how we collect, use and share the information of children under 13 years of age (hereinafter, the “Child” or the “Children”). We comply with the US Children’s Online Privacy Protection Act (COPPA) and apply these measures to the personal data of children within the United States.

📌 More information about COPPA and the protection of children online is available on OnGuard Online.

• Collection of information

Ararat International School collects personal data about children:

📌 Directly from parents – parents register their child, providing the name and age, and also, optionally, information about the form of schooling (for example, home schooling) and comments for the teacher.

📌 After parental consent has been obtained – children can use the platform in a special “student mode” (hereinafter, the Learning Space), where they can mark the classes that interest them (but cannot enroll in them on their own).

📌 During online lessons – children may take part in video calls, during which their voice and image are recorded.

📌 Automatically collected data – IP address, device type, operating system and other technical parameters (which are not shared with third parties for advertising purposes).

❗ We do not collect payment data from children and do not require them to provide more data than is necessary to take part in classes.

• Use and sharing of data

Once verifiable parental consent has been obtained, we may:

✅ Recommend suitable classes based on the interests of the child.

❌ We do not send promotional emails to children.

❌ We do not share their data with analytics services for advertising purposes.

📌 What data is shared with teachers?

• The name, age and time zone of the child,
• Notes from the parents (for example, learning recommendations),
• The video and voice of the child during classes, available to the teacher and to the other members of the group.

⚠ Important: During classes a child may voluntarily share their data with the teacher and classmates (for example, upload photographs or videos). We cannot fully control the behavior of teachers and students, but we do take measures to protect data.

📌 Some teachers may suggest that students use third-party services.

Parents are advised to review the privacy policies of these platforms before using them.

• Recordings of classes

We record lessons, and they are available to:

✅ The teacher,

✅ Parents and children in the group (if there is a need to review the material).

📌 In some cases the role of teacher is performed by entire educational organizations, and recordings may be available to their team.

⚠ It is prohibited to:

❌ Copy and distribute recordings without consent,

❌ Use recordings for advertising purposes without additional consent

from the parents.

• Parental consent

📌 We comply with all regional data protection laws. Depending on the country in which you live:

• In the USA we act in accordance with COPPA (Children’s Online Privacy Protection Act).
• In the European Union the processing of personal data is governed by the General Data Protection Regulation (GDPR).
• In Russia data processing complies with Federal Law No. 152-FZ “On Personal Data”.

We request parental consent before collecting a child’s data and send

a detailed privacy policy notice.

📌 How is consent confirmed?

The parent provides payment details in order to:

1⃣ Confirm their identity,

2⃣ Pay for the subscription and enroll the child in classes.

❗ If a parent does not give consent, the platform does not collect the data of the child, and the child

cannot use the services.

📌 If consent is not given within a certain period, the contact details of the parents are deleted from the system.

• Parental choices and control

✅ You can:

🔹 Review and prohibit the further collection of data,

🔹 Request the deletion of the data of your child.

📌 How do I delete data?

1⃣ Log in to your personal account, change or delete the information, 2⃣ Turn off personalized recommendations,

3⃣ Send a request to technical support at info@araratchess.ru.

❗ Important: Deleting data may lead to the deletion of your account and to the discontinuation of the services.

📌 We do not keep data longer than is necessary, and automatically delete it if it is no longer needed.