Personal Data Processing Policy

LLC "Center for International Education" (hereinafter referred to as "Operator," "we")
Website: https://timetoeducation.com/

1. General Provisions and Applicable Law
1.1. This Policy defines the procedure for the processing and protection of personal data of users of the timetoeducation.com website, applicants, and their legal representatives when applying for education in Russian universities, as well as during consultations and subsequent support.
1.2. We act in accordance with the legislation of the Russian Federation, including Federal Law No. 152-FZ "On Personal Data" and other acts (including requirements for the localization of data of Russian citizens), the legislation of the Kyrgyz Republic on personal information/personal data (as amended), and the applicable laws of African countries and the regional African Convention on Cybersecurity and Personal Data Protection (Malabo Convention).
1.3. If the rules of different jurisdictions apply simultaneously, we comply with the stricter requirements, as far as reasonable and technically feasible.

2. Definitions
  • "Personal Data" — any information related to an identified or identifiable individual.
  • "Processing" — any action with personal data (collection, recording, systematization, storage, clarification, use, transfer, anonymization, blocking, deletion, etc.).
  • "Cross-border Transfer" — the transfer of personal data to a foreign country.

3. Data Processed
When filling out the form on the website, we collect:
  • First Name, Last Name;
  • Date of Birth;
  • Phone Number;
  • Email Address;
  • Files: copies of certificates, entrance exams, and other documents required for admission/registration (including translations, notarized copies, if necessary).
  • Technical data may also be automatically processed: cookies, IP address, browser/device data, page visit statistics.
4. Purposes of Processing
  • Admission and consideration of applications for study at Russian universities;
  • Identification and communication with the applicant/legal representative;
  • Preparation and submission of documents to educational institutions/preparatory departments;
  • Consultation on admission, visa, and migration procedures;
  • Fulfillment of contracts, billing, accounting, and tax reporting;
  • Compliance with legal requirements and requests from competent authorities;
  • Support and improvement of the website and service quality (analytics, feedback);
  • Protection of the Operator's and third parties' legal rights and interests when there are legal grounds.


5. Legal Grounds
  • Consent of the data subject (separately for processing, cross-border transfer, receiving newsletters — if applicable);
  • Conclusion and execution of a contract/pre-contractual activities at the initiative of the data subject;
  • Compliance with legal obligations (education, migration, accounting, tax legislation, etc.);
  • Legitimate interests of the Operator (service improvement, fraud prevention) — subject to balancing with the rights of the data subject and, where required, consent.

6. Special Categories and Third-Party Data
We do not request special categories of data (health data, biometrics, etc.), except where directly necessary for admission/residence (e.g., medical certificates for dormitory) and only with separate consent/based on law. When submitting documents of third parties (e.g., parents for consent/guarantee), you confirm that you have obtained their consent, if necessary.


7. Data Sources
Data is provided by the user personally (through the form) or by their legal representative. Additionally, data may be obtained from open sources/universities — strictly for admission purposes and when there is a legal basis.


8. Cross-Border Transfer and Localization
8.1. Processing may involve data transfers between the Russian Federation, Kyrgyz Republic, and African countries (where documents are submitted or communication occurs).
8.2. When transferring data to countries that do not ensure an "adequate" level of protection under Russian/Kyrgyz law or local African law, we:
— Obtain the required consent of the data subject (if necessary);
— Conclude contracts with recipients that include data protection obligations;
— Assess legal risks and apply additional measures (encryption, pseudonymization, etc.).
8.3. For personal data of Russian citizens, we comply with the requirements for primary collection/recording/storage in the Russian Federation (localization) as amended, effective from July 1, 2025.


9. Storage and Retention Periods
  • Application data and the applicant's dossier: for the period of admission and study/support, then for the periods established by accounting legislation/claim periods (usually 3–5 years, unless otherwise required by law).
  • Data for newsletters (if subscribed): until consent is withdrawn.
  • Technical logs: as necessary for security and audit purposes.
  • Data deletion/anonymization occurs after the retention periods or upon the legal request of the data subject (unless there is another obligation to store the data).

10. Data Transfer to Third Parties
We may transfer data to:
  • Universities and preparatory departments (admission committees);
  • Translators/notaries/document evaluators;
  • Visa centers, migration authorities;
  • Payment providers and banks;
  • Hosting providers, email/messenger systems, website analytics services;
  • Consultants and other contractors under a data processing agreement (with DPA/contractual guarantees).
All recipients are obliged to ensure the confidentiality and security of the data.


11. Security
We apply organizational and technical security measures: access restriction by role, encryption during transmission and storage (where applicable), backup, two-factor authentication for administrative access, action logging, regular testing, and staff training. These measures are updated based on risks and applicable legal requirements.


12. Data Subject Rights
Depending on the applicable law, you have the right to:
  • Obtain information about the processing and a copy of your data;
  • Request clarification (updating, correction);
  • Request blocking/deletion if the data is processed unlawfully or the purposes have been achieved;
  • Withdraw consent (does not affect the legality of processing before withdrawal);
  • Restrict processing or object to it — where provided by law;
  • Appeal the Operator’s actions to the competent authority and court.
Implementation of specific rights may differ by jurisdiction (e.g., "portability"), and we will inform you about this when making a request.

13. Minor’s Rights
Our services are aimed at applicants. If you are under 18 years old, processing is allowed with the involvement and/or consent of a parent/legal representative, where required by the law of your country and/or the country of processing.


14. Cookies and Similar Technologies
We use cookies for website functionality, visitor analytics, and service improvement. You can manage cookies through your browser settings. Disabling them may affect the functionality of certain features.


15. International and Local Standards in Africa
We strive to comply with the requirements of local laws of applicants' countries of residence (e.g., South Africa — POPIA; Kenya — Data Protection Act 2019; Nigeria — NDPA 2023/previously NDPR 2019) and the regional Malabo Convention, if applicable to specific processing/transfer.


16. Automated Decisions and Profiling
We do not make decisions that have legal consequences for the data subject (automatic rejection/admission) based on fully automated processing. Candidate evaluation is carried out with the participation of specialists/partners from educational institutions.


17. Contact and Requests
For issues related to personal data and to exercise your rights, you can contact us through the form on the website or the contact details provided on the "Contacts" page of the timetoeducation.com website. When making a request, we may ask you to verify your identity.


18. Policy Changes
We may update this Policy. The current version and effective date will be published on the website. Significant changes (e.g., new processing purposes) will be accompanied by additional notification/obtaining consent, if required by law.


19. Consent
By submitting the form on the website and/or providing documents, you confirm that:
  • You have read this Policy;
  • You consent to the processing and, if necessary, to the cross-border transfer of your data for the purposes specified in Section 4;
  • You have obtained consent from legal representatives/third parties for providing their data if you are submitting them on their behalf.