1. GENERAL PROVISIONS

1.1 This policy of personal data processing (hereinafter referred to as the "Policy") regulates the rules of personal data processing of users (hereinafter referred to as the "User") who use the "Spanish with Vicky" application (hereinafter referred to as the "Application").

1.2 The Policy defines the rules, purposes and conditions of personal data processing by the private limited liability company GRLS Digital S.L. CIF B069404560 (hereinafter referred to as "Operator"), establishes the procedures for the collection, storage, transfer and protection of personal data.

1.3 If the User does not agree with the terms of the Policy, he/she must immediately stop using the Application. By using the Application, the User accepts the Policy in full.

1.4 The Policy is drawn up in accordance with Article 18.1, paragraph 2 of the Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, Regulation of the European Parliament and of the Council of the European Union 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free circulation of such data, as well as on the repeal of Directive 95/46/EC (General Data Protection Regulation / GDPR), as well as other legal acts of the European Union in the field of protection and processing of personal data. The Policy applies to all personal data that the Operator may receive from the User.

1.5 The Operator processes data on the basis of the principles of:

• legality of the purposes and methods of personal data processing, integrity and fairness in the Operator's activities;
• reliability of personal data, their sufficiency for the purposes of processing, inadmissibility of processing of personal data that are redundant in relation to the purposes stated in the collection of personal data;
• processing only personal data that meet the purposes of their processing;
• compliance of the content and scope of processed personal data with the stated processing purposes. Personal data must not be redundant in relation to the stated purposes of their processing;
• inadmissibility of combining databases containing personal data processed for incompatible purposes;
• ensuring accuracy of personal data, their sufficiency and, where necessary, relevance in relation to the purposes of personal data processing.The Operator shall take the necessary measures to delete or clarify incomplete or inaccurate data;
• storing personal data in a form that allows to identify the subject of personal data for no longer than required by the purposes of personal data processing.

1. BASIC TERMS.

2.1 In this Policy, terms are used in the following meanings:

Personal Data - any information that directly or indirectly relates to a certain or definable natural person (subject of personal data).

Application - "Spanish with Vicky" software that runs on smartphones, tablets and other mobile devices and is designed for learning Spanish.

Processing of personal data - any action or set of actions with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

Dissemination of personal data - actions aimed at disclosure of personal data to an indefinite number of persons.