COOKIE AND METRICS DATA COLLECTION AND PROCESSING POLICY
Moscow
31 March 2026
This policy, in accordance with Part 2 of Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data," defines the policy of MARINE COURSE Limited Liability Company (hereinafter referred to as the Operator) regarding the processing of cookies and metrics data that it may receive from the User of the Site https://morkurs.ru/ during its use. This policy is an integral part of the Operator's internal document which defines the Operator's general policy regarding the personal data processing and discloses general information about the Operator's personal data protection requirements.
1. Terms and definitions
1.1. The following terms and definitions for the purposes of this policy have the following meaning:
"Operator" - MARINE COURSE Limited Liability Company, TIN [Taxpayer Identification Number] 9707039746, PSRN [Primary State Registration Number] 1247700740418, address: 127006, Moscow, 34 Dolgorukovskaya St., bldg. 2, which is the owner and operator of the Site.
"User" is any individual (subject of personal data), including acting on behalf of and in the interests of an individual or legal entity represented by him, who may, in the process of using the Site, provide the Operator with his personal data, independently or through an individual or legal entity represented by him/her that has expressed consent to the terms and conditions set forth in the Agreement, either by signing it, or by performing the implicit actions specified therein aimed at using the Site. In the context of this policy, the User also means persons whose personal data are processed by the Operator on the Site user's instructions contained in the Agreement.
"Site", "Personal data information system," "Information system" mean the website available on the Internet at https://morkurs.ru/, as well as the software modules, widgets, and feedback forms integrated therein (including those provided by third parties) used to interact with the User. The Site comprises a collection of information, text, graphic elements, designs, images, photos, videos, and other intellectual property.
"Agreement" is a user or other agreement between the User and the Operator, regulating the procedure for using the Site.
Cookies are small pieces of data sent by a web server and stored on the User's device. Cookies contain small pieces of text and are used to store information about browser activity. They allow to store and retrieve identification information and other information on computers, smartphones, telephones, and other devices. Cookie specifications are described in RFC 2109 and RFC 2965. Other technologies are used for the same purposes, including data stored by browsers or devices, device-related identifiers, and other software. In this policy, all of these technologies are referred to as cookies.
"Web beacons", "pixels" are electronic images (single-pixel (1x1) or clear GIF images). Web beacons can help the Operator recognize certain types of information on the User's device, such as cookies, the time and date of a page view, and a description of the page where the web beacon is located.
"Counter" is a computer program that uses a piece of code installed on a website to analyze cookies and collect statistical and personal data about that website. Personal data is collected in an anonymized form.
"IP address" is a number from the numbering resource of a data transmission network built on the basis of the IP protocol (RFC 791), which uniquely identifies, when providing telematic communication services, including access to the Internet, a subscriber terminal (computer, smartphone, tablet, other device) or communication equipment included in the information system and belonging to the User.
1.2. All other terms and definitions contained in the text of this policy shall be interpreted by the Parties in accordance with the legislation of the Russian Federation, current recommendations (RFC) of international Internet standardization authorities, and the usual rules for interpreting relevant terms that have developed on the Internet.
1.3. The terms and definitions used in this policy may be used in both singular and plural forms depending on the context, and the spelling of terms may be either capitalized or lowercase.
2. GENERAL PROVISIONS
2.1. This policy defines the procedure and conditions for the Operator's use of cookies and metrics data collection technologies, including the transfer of received data to third parties, the specifics of automated information processing, the procedure for accessing collected data, the system for protecting such data, the organization of internal control and liability for violations of the procedure for their processing, as well as other issues related to the handling of cookies and metrics.
2.2. This policy applies to all processes involving the use of cookies and the collection of metrics data, whether automated or not, on the Site. The Operator does not control and is not responsible for third-party websites that the User may access via links posted on the Site.
2.3. This policy applies in conjunction with the Privacy Policy posted on the Site at: https://morkurs.ru/ documents/35/. The provisions of the Privacy Policy shall apply to any matters not regulated by this document.
3. PROCESSED DATA COMPOSITION
3.1. Personal data processed in accordance with this policy and automatically transferred to the Operator during the use of the Site using software installed on the User's device may include the following information:
3.1.1. IP address of the User's device;
3.1.2. cookies data;
3.1.3. data collected by counters;
3.1.4. data obtained using web beacons;
3.1.5. information about the User's browser;
3.1.6. technical characteristics of the device and software;
3.1.7. date and time of access to the Site;
3.1.8. addresses of the requested pages of the Site;
3.1.9. geographic coordinates of the User's location.
4. TYPES OF COOKIES
4.1. The Operator uses various types of cookies on the Site, which serve different purposes and, depending on them, can be classified into one of the following categories:
4.1.1. "Essential" cookies are those that are strictly necessary for the functioning of critical components of the Site.
4.1.2. "Functional" cookies are those that allow the User to interact with the Website's interface and use its features, record information about actions taken on the Site, and customize the Site to the User's needs. Without these cookies, the Website would not be able to provide certain functions, such as remembering the information entered by the User, saving the preferred language, etc.
4.1.3. "Analytical" cookies are analytical/statistical cookies that help improve the performance of the Site and make it more user-friendly. Through analytical cookies, the Operator receives information about the quality and/or effectiveness of the Site and its services, which helps understand how Users use the Site and how they utilize the Operator's services.
5. PROCEDURE FOR COLLECTING PERSONAL DATA USING COOKIES
5.1. Cookies transmitted from the Operator to the User's device and from the User to the Operator may be used by the Operator to achieve the purposes of personal data processing in accordance with the privacy and personal data processing policy.
5.2. The Operator does not explicitly request consent when using essential cookies. If the User does not wish to have his/her personal data collected using essential cookies, he/she can disable their provision to the Operator in the software (browser) on their device. In this case, the User will no longer have access to the Site's functionality associated with essential cookies, which may result in the Site being completely inoperable or not functioning correctly.
5.3. The Operator may use functional and analytical cookies only with the User's consent, which is generally expressed by accepting the Agreement and beginning to use the Site. Otherwise, the User has the right to refuse the use of such cookies by disabling them in the Site or browser settings, without affecting its functionality. The User agrees that their devices and software used to work with the Site, depending on their version and configuration, may or may not have the function of prohibiting operations with cookies for any or specific websites and applications, as well as the function of deleting previously received cookies (for example, private browser mode).
5.4. The Operator has the right to establish a requirement for the User's device to allow the acceptance and receipt of cookies due to security requirements.
5.5. The cookie structure, its content, and technical parameters are determined by the Operator and are subject to change without prior notice to the User. The User has the right to obtain all necessary information about cookies by submitting a request to the Operator in accordance with the procedure established by the privacy and personal data processing policy.
6. PROCEDURE FOR COLLECTING PERSONAL DATA USING WEB BEACONS AND COUNTERS
6.1. Counters placed by the Operator on the Site may be used by the Operator to analyze cookies and collect personal data about the Site usage in order to improve the quality of the Site and its usability. The technical parameters of the counters are determined by the Operator and are subject to change without prior notice to the User.
6.2. The Operator may also use web beacons, either alone or in conjunction with cookies, to collect information about the Site usage. Users have the right to block web beacons when using the Site by disabling image loading in their software (browser) settings.
6.3. Use of third-party web analytics and marketing services:
6.3.1. The Site contains counter codes and web beacons owned by third parties. These services may collect anonymized data about the User's traffic, behavior on the Site, device type, and browser.
6.3.2. The operator has the right to use the following services:
- Yandex.Metrica (YANDEX LLC) is used for statistical tracking of website traffic and session recording.
6.3.3. Data collected by these services (counters, web beacons) may be transmitted to servers operated by the respective companies. Users can block these counters using their browser settings or special extensions (ad blockers), which will not affect their ability to view the Site's content.
7. RECEIVING AND PROCESSING THE USER'S IP ADDRESS
7.1. While using the Site, the Operator automatically receives the IP address of the User's device. The IP address is obtained through:
7.1.1. Loading pages of the Site and interaction with elements of the Site;
7.1.2. Use of cookies, counters, web beacons and other web analytics tools;
7.1.3. In the process of the User sending feedback forms and other requests via the Site.
7.2. The IP address is used by the Operator for the following purposes:
7.2.1. technical support for the Site functioning;
7.2.2. conducting internal audits, analysis and statistics of the Site use;
7.2.3. protection against unauthorized access and illegal actions, detection and prevention of fraud and other abuses;
7.2.4. compliance with the requirements of the legislation of the Russian Federation.
7.3. The IP address is processed automatically in an anonymized form, unless otherwise expressly provided by applicable legal requirements.
7.4. As part of the use of web analytics services specified in paragraph 6.3 of this policy, the IP address may also be transferred to third-party services in an anonymized or shortened (anonymized) form in accordance with the established rules of the services.
7.5. The Operator does not compare the IP address with other personal data of the User, unless otherwise provided by the Agreement or legal requirements.
7.6. The IP address processing period corresponds to the periods established for the storage of cookies and other metrics data. After these periods, the User's data, including the IP address, is subject to deletion or anonymization.
8. FINAL PROVISIONS
8.1. This policy shall enter into force upon its approval by the Operator and shall remain in effect indefinitely until it is replaced by a new version.
8.2. The Operator reserves the right to make changes to this policy without the User's consent. All changes are made by the Operator's executive directive.
8.3. By using the Site, the User agrees to this Policy terms. If the User disagrees with this Policy terms, he/she shall immediately cease using the Site.
8.4. The law of the Russian Federation shall apply to this policy and to the relations between the User and the Operator arising in connection with this policy application.
8.5. This policy is permanently publicly available on the Operator's website at the following link: https://morkurs.ru/ documents/35/.
8.6. The User has the right to send any offers or questions regarding this policy to the Operator's User Support Service by sending an email to the email address: info@morkurs.ru.
9. DETAILS
MARINE COURSE LLC
Legal address: 127006, Moscow, 34 Dolgorukovskaya St., bldg. 2
Actual (postal) address: 127006, Moscow, 34 Dolgorukovskaya St., bldg. 2, office 404
TIN/TRRC [Taxpayer Identification Number/Tax Registration Reason Code]: 9707039746/770701001
PSRN [Primary State Registration Number]: 1247700740418
Phone: +7 988 573-87-47