Marketing communications consent

LARNES does not send advertising messages until the user separately consents through an active channel.

There are no active advertising channels. The product cannot currently collect advertising consent, and viewing this page does not create consent.

Current outbound email and SMS are used only for OTP and security notices. Telegram is used only for internal technical team alerts.

Consent is given separately under Article 18(1) of Federal Law No. 38-FZ on Advertising and Articles 9 and 15 of Federal Law No. 152-FZ on Personal Data.

Offer acceptance, registration, payment, free-workspace use, adult or child data consent, and continued website use do not mean advertising consent.

Refusal does not limit registration, learning, classroom, free features, purchase, or paid access. Preselected boxes and mandatory advertising subscription are not used.

The advertiser, personal-data controller, and sender is the LARNES owner whose full name, tax and registration numbers, and address appear in Company details.

Consent covers LARNES advertising from that specific person only. It does not permit schools, teachers, ad platforms, “partners”, or other third parties to advertise their own services.

If the actual advertiser or sender changes, prior consent does not transfer automatically; a new clearly identified recipient choice is required.

An adult user consents for their own verified email or phone. LARNES links the action to a specific account and recipient.

Entering another person's contact, holding a family role, acting as school staff, or consenting to child data does not subscribe another person.

Child-profile contacts, learning performance, assignments, behaviour, and interests are not used for advertising messages.

The sole purpose is to promote LARNES functions, tariffs, and programmes through direct advertising contact with an adult recipient.

A message may offer paid access or describe a new programme or feature, discount, promo code, campaign, or another LARNES commercial offer.

Consent excludes political promotion, third-party advertising, contact sale, cross-site tracking, and child advertising profiles.

Each available channel uses a separate initially unchecked box. Email consent does not permit SMS, and SMS consent does not permit email.

This Consent covers no active channel while advertising communications are disabled.

Telephone and automated calls, push, WhatsApp, Viber, Telegram, and other messengers are outside this Consent. “Other means” is not used.

Minimum channel data comprises adult account user ID, verified email or phone, name where needed for address, language, selected channel, Consent version, and consent, send, and opt-out history.

Birth date, city, payment data, family relations, and child learning data are unnecessary for advertising delivery.

Pseudonymous date/time, IP, user-agent, and session/device ID are recorded only to the minimum extent needed to prove the specific choice and prevent substitution.

Automated collection, recording, organisation, storage, correction, retrieval, and use are permitted to verify consent and send the selected message.

The strictly necessary contact and message may be provided to a delivery processor; channel blocking, suppression, deletion, and destruction are also permitted.

Data is not disclosed publicly or supplied to the delivery processor for its own advertising.

For an enabled channel, LARNES may instruct a delivery provider listed in the Privacy Policy. Whether it is used for live user data, its legal entity, country, and cross-border status appear in its service card.

The delivery provider acts only on instructions and receives no independent consent to advertise its or another person's services.

A contact is not sent to an ad system or foreign service absent from the Privacy Policy or failing applicable localisation and cross-border requirements.

Before confirmation, the user sees the word “advertising”, the specific sender, selected contact, channel, link to this version, and an optional unchecked box.

Consent arises only from a separate positive action for a specific channel. A general registration, payment, or profile-save button does not create it.

If LARNES cannot link the action to a specific user, verified contact, channel, sender, and version, no advertising is sent.

Without advertising consent, LARNES may send messages objectively necessary for a selected action, security, or agreement performance.

The current product uses OTP for registration, recovery, and contact change, plus password- or contact-change security notices.

A service message contains no discount, promo code, programme purchase offer, referral prompt, or other advertising insert. Calling an actual offer “informational” does not change its advertising nature.

Channel consent runs from the recorded positive action until withdrawal, LARNES termination of that mailing, or loss of the right to use the contact, whichever occurs first.

Changing email or phone does not transfer consent to the new contact. The new verified contact requires a new separate action.

Account inactivity, silence, and absence of complaint do not create or extend consent.

Without giving reasons, the user may stop one channel or all advertising through the channel control made available or the operator contacts in Company details.

Upon receiving the request, LARNES immediately stops advertising on that channel and places the contact in suppression until queue and provider deletion completes.

Advertising withdrawal does not close the account, agreement, or necessary service messages. Re-enablement requires a new positive user action.

LARNES bears the burden of proving prior consent. The ledger stores user ID, verified contact, channel, UTC time, screen and action, text version and hash, initially unchecked state, IP/user-agent/session/device ID, status, and withdrawal time.

Before every send, the system rechecks active consent and suppression. It records the exact template, advertiser, channel, recipient, time, delivery result, and applied consent version.

Minimum consent and withdrawal evidence is retained during consent and for three years after the last send or withdrawal. Advertising materials and distribution agreements are retained for at least one year after last distribution or agreement end.

The LARNES CRM accepts inbound leads and keeps an internal activity feed; it sends no automated advertising email, SMS, messenger message, or call to leads.

A school, centre, or teacher independently using a contact outside LARNES is responsible for its own ground and consent as a separate advertiser and controller.

Contact transfer to a school or lead appearance in CRM is not consent to LARNES advertising. A blanket “LARNES and partners” consent is not used.

LARNES does not advertise to a child or use a child profile's contact, learning history, or interests for marketing.

Adult consent covers only that adult's verified contact and does not permit messages to the child.

Adult advertising does not exploit a child's trust, encourage the child to pressure parents to buy, or discredit parents or teachers.

A new channel, advertiser, purpose, data category, or independent recipient requires a new version and new separate user choice.

Changing the Privacy Policy, Offer, or this page does not expand prior consent. Silence is not acceptance of new terms.

The accepted version remains available; a new version applies only to a later positive action.

Using the operator contacts, a user may request consent and send records, withdraw a channel, correct a contact, stop processing, or request deletion absent another ground.

Advertising complaints may be filed with the Federal Antimonopoly Service; personal-data complaints with Roskomnadzor; court protection is also available.

Withdrawal operates independently of deletion: waiting for technical data deletion does not permit continued advertising.