Privacy Policy
Draft for review. Based on French and EU law (GDPR), which applies to your business as a French operator regardless of where your clients are based. This is a working template, not legal advice. Please have a qualified lawyer review it before publishing.
Still needed (shown in red below): your website address. Name and contact email are filled in below; let me know if you'd rather use the Gmail address instead of the gmx.fr one for privacy requests.
1. Who We AreThis Privacy Policy explains how Anna Gosteva, trading as Gosti.Russian (“we,” “us,” or “the Operator”), the operator of [website address] (the “Site”), collects, uses, and protects personal data belonging to visitors and students (“you”).
We provide Russian language lessons and exam preparation to clients around the world. As a business established in France, we apply French and EU data protection law (the GDPR) to all personal data we process, and we extend the same rights described in this policy to all visitors, regardless of where they live.
2. What Personal Data We CollectWe collect personal data that you provide directly to us, primarily through the contact and booking form on the Site. This includes:
● Your name
●Your email address
●Your stated learning goal (General Russian, Business Russian, Exam Prep, or Not sure)
●Any message or additional information you choose to include
If you also use analytics tools, live chat, or advertising pixels (for example Google Analytics, Meta Pixel, or similar), add them here along with the data they collect. This draft assumes only the contact form for now.
3. How We Use Your Personal DataWe use the personal data you provide to:
● Respond to your inquiry and discuss your learning goals
● Build and offer you a personalized learning plan
● Schedule and deliver lessons, if you become a student
● Send you information about our courses, if you have asked for it
● Maintain records for our own administrative and accounting purposes
We do not sell your personal data, and we do not use it for purposes unrelated to the ones listed above without asking you first.
4. Legal Basis for ProcessingWe process your personal data based on your consent (given when you submit the contact form), and, once you become a student, on the performance of our contract with you, in line with the General Data Protection Regulation (GDPR). This applies to all clients, wherever they are located.
5. Sharing Your Personal DataWe do not sell or rent your personal data to third parties. We may share personal data with:
● Service providers who help us run the Site or manage communications (for example, email or scheduling tools), under obligations to protect your data
● Authorities, if required by law or to protect our legal rights
List your actual tools here once confirmed, for example your email provider, calendar tool, or website host.
6. International Data TransfersYour personal data is processed by us in France, under French and EU data protection law. If we ever need to transfer personal data outside the European Union, for example to a service provider based elsewhere, we rely on appropriate safeguards permitted under the GDPR, such as adequacy decisions or standard contractual clauses.
7. Data RetentionWe keep your personal data only for as long as necessary to fulfill the purposes described in this policy, for example while we are in contact about lessons, while you remain a student, and for a reasonable period afterward to meet our legal, tax, or accounting obligations. After that, we delete or anonymize your data.
8. Cookies and Similar TechnologiesInclude this section only if the Site uses cookies, analytics, or advertising technology. Many website builders, including Tilda, add basic cookies by default, so please confirm before removing this section.
If the Site uses cookies or similar technologies, we use them to operate the Site properly and, where applicable, to understand how visitors use it. Where required by law, we will ask for your consent before placing non essential cookies, and you can withdraw that consent at any time.
9. Your RightsUnder the GDPR, you have the right to access, correct, delete, or restrict the use of your personal data, to receive a copy of it in a portable format, to object to certain processing, and to withdraw consent at any time. We extend these same rights to all clients, regardless of where you live.
If you are in the European Union, you also have the right to lodge a complaint with your national data protection authority, such as the CNIL in France.
To exercise any of these rights, contact us at gosti.russian@gmx.fr. We will respond within the timeframe required by applicable law.
10. Children's PrivacyThe Site is intended for adults seeking language lessons for themselves or arranging lessons on behalf of others. We do not knowingly collect personal data directly from children without appropriate parental or guardian involvement.
11. Data SecurityWe take reasonable technical and organizational measures to protect your personal data against unauthorized access, loss, or misuse. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
12. Changes to This PolicyWe may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.
13. Contact UsIf you have any questions about this Privacy Policy or how we handle your personal data, please contact us at gosti.russian@gmx.fr.
Notes for implementation
● This is a draft, not a finished legal document. Please have a lawyer familiar with GDPR review it before it goes live.
● Fill in your legal name or business name, website address, and contact email everywhere marked in red.
● Confirm which tools the Site actually uses (analytics, email marketing, scheduling, payment processing) so Sections 5 and 8 can name them specifically rather than staying generic.
● This policy relies on GDPR as the sole legal framework, since your business is established in France. Clients elsewhere are given the same rights as a matter of policy, not because a foreign law requires it. If your business grows to a scale that triggers thresholds under laws like the California CCPA, this should be revisited.
