Effective date: 20/10/2026 · Version: 1.0
1. About this Policy and SAWA
SAWA is a web application for independently creating, storing and sharing organisational, lesson-related and financial records. It is developed by the FedorGolem team as part of the FedorGolem software ecosystem (fedorgolem.com). The application website is sawapanel.com. “SAWA” identifies the application; this Policy does not claim that it is a registered trademark.
Legal service operator and privacy contact: Fedor Goleminov, UAE, Dubai, info@fedorgolem.com. This Policy describes processing by that operator in the shared SAWA installation; separately hosted client installations may be subject to additional terms.
2. Purpose and Responsibilities
SAWA does not provide courses, teach lessons or determine the content of educational services. Teachers or their authorised representatives create records; students may access the portions made available to them.
A teacher or organisation deciding why and which student records are kept will generally act as a controller of those records, while SAWA may process them on the client’s instructions. The SAWA operator may act as a separate controller for account administration, security, licensing, support and technical diagnostics. Actual roles depend on applicable law and the relevant agreement.
3. Account Creation
There is no open public self-registration. The SAWA operator creates teacher accounts. Teachers create student accounts; the operator may create a student account only at the teacher’s request. Access to an account does not by itself constitute consent to every form of personal-data processing.
4. Personal Data Categories
Depending on available features, information may include names, logins, IDs, contact details, profile photos, account roles and preferences; schedules, lesson status and duration, attendance, practice records, teacher comments and student characteristics, certificates and events; charges, recorded payments, balances, payment methods and dates; teacher transfer details including IBAN, bank, account holder and phone number; and interface language, theme, currency and week start.
For security and operation, SAWA may process IP addresses, browser information, login time, session activity, audit events, Inspector diagnostics, errors and issue reports. Exact fields vary by version and installation.
5. Purposes and Legal Bases
We use data to maintain accounts and shared records, display information to teachers and students, record lessons and payments, retain preferences, prevent and diagnose errors, secure the service, provide support, create backups and comply with legal obligations. The applicable legal basis depends on the processing activity and may include contractual necessity, legally required consent, a legal obligation or another basis permitted by applicable law. Acceptance of the Terms does not replace separate consent where required.
6. Minors and the Teacher Declaration
Before entering a student’s personal information, the teacher must ensure that appropriate legal grounds and permissions exist, including parental or legal-guardian consent where required. Before using the application, the teacher accepts a single mandatory declaration in SAWA Settings; SAWA records the account ID, date and declaration version. This covers the teacher’s future student-account creation but is not parental consent itself.
SAWA does not routinely collect parental consent documents when a student account is created. The teacher retains required evidence and assists with verification where a lawful, justified request is made. Special requirements may apply to children under 13, including explicit, documented and verifiable consent and an accessible withdrawal mechanism. A teacher checkbox alone is not treated as a substitute where law requires an additional procedure.
7. Access to Data
Teachers can access records assigned to them; students can access only the information authorised for their role. Authorised SAWA administrators may have limited technical access for support, security and operational checks. The View As feature is intended for controlled technical review. This access does not permit unrelated use of students’ records.
8. Inspector and Logs
Inspector may evaluate technical events, lesson and payment statuses, system errors and user issue reports to support diagnostics, security and service operation, not advertising profiling. Log retention periods and access permissions must be established and followed.
9. Backups
The SAWA operator creates, exports, retains, processes and restores backups. Additional backups or disclosure of data may be arranged upon user request after verifying authority and third-party rights. Backups may contain user records and technical files, and must be protected appropriately, including encryption where provided by the system. The existence of a backup does not guarantee restoration of any arbitrary individual record.
10. Hosting, Vendors and International Transfers
SAWA relies on third-party hosting infrastructure. The hosting provider is Timeweb. International transfers are subject to applicable legal conditions and safeguards. External links provided by teachers may lead to third-party services with separate policies.
11. Retention, Deletion and Export
We retain personal data as necessary to operate the service, meet obligations and lawfully preserve lesson or financial history. Retention periods: account data — up to 12 months after the account is closed; logs — 90 days; backups — 6 months. The operator may extend these periods. Deactivation or soft deletion may not immediately erase associated records. Subject to legal exceptions, valid requests may lead to deletion, restriction or anonymisation. Exports are handled manually by the operator or through an agreed procedure; an automated download button is not promised.
12. Individual Rights and Requests
Subject to applicable law, individuals or their legal representatives may request information, access, correction, deletion, processing restrictions, portability or withdrawal of consent. Identity or authority may need to be verified. Where a teacher controls student records, SAWA will refer or coordinate the request with the teacher and provide necessary assistance. Applicable law determines response deadlines. Contact: info@fedorgolem.com. Withdrawal of permission for a child’s data must be reviewed promptly and processing restricted or ceased where required by law.
13. Security and Incidents
SAWA employs role-based access, password protection, sessions, HTTPS when correctly configured, operational logging and backups. No system can guarantee absolute security. The operator will respond to incidents and provide notices where required by applicable law.
14. Cookies, PWA and External Resources
Essential session cookies, local interface preferences, PWA caching and practice-timer storage support operation of the application. SAWA is not intended to use students’ records for targeted advertising. New analytics or advertising technologies would require a review of this Policy and the relevant lawful bases.
15. Changes and Contact
Revisions will be published at sawapanel.com/privacy with a version and effective date. Material changes will be communicated as required by law or contract.
Developer: FedorGolem team — fedorgolem.com. Application: sawapanel.com. Legal operator: Fedor Goleminov. Privacy and security email: info@fedorgolem.com. Legal address: UAE, Dubai.