This Policy details the personal data we receive about you, how we process it and your rights and obligations in relation to your personal data.
“EDUCAR” LLC, a company registered at Ukraine, Kyiv, Heroiv Dnipra Street 7, 04209 (“we”, “us” or “our”) is the data controller for the purposes of the General Data Protection Regulation and any relevant local legislation (“Data Protection Laws”).
YOU ARE REQUIRED TO READ THIS POLICY TO UNDERSTAND HOW WE COLLECT AND PROCESS YOUR PERSONAL DATA AND WHAT SECURITY MEASURES ARE BEING APPLIED.BY USING OR ACCESSING OUR OFFICIAL IOS AND ANDROID MOBILE APPLICATIONS, YOU AGREE TO THE TERMS OF THIS POLICY.
Capitalized terms not defined here have the meanings set forth in the Terms of Service located at insert the link.
This Policy is meant to help you understand how we collect and use the personal data you provide us in our official iOS and Android mobile applications (“Applications”). This Policy explains:
- what information we collect and why we collect it;
- how we use and share that information;
- the choices we offer you to protect your privacy and the rights you have, including how you can access and update your information;
- how to contact us if you have questions or concerns.
- Principles Relating to the Processing of Personal Data
We process your personal data in accordance with the fundamental principles stated in the relevant Data Protection Laws. These are as follows:
- lawfulness, fairness and transparency– personal data shall be processed lawfully, fairly and in a transparent manner in relation to you;
- purpose limitation– personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- data minimisation– personal data shall be adequate, relevant and limited to what is necessary for relation to the purposes for which they are processed;
- accuracy– personal data shall be accurate and, where necessary kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed are erased or rectified without delay;
- storage limitation– personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for achieving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Data Protection Laws in order to safeguard the rights and freedoms of the data subject;
- integrity and confidentiality– personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures;
- accountability– controller shall be responsible for, and be able to demonstrate compliance with all of these principles both in the processing it currently carries out and as part of the introduction of new methods of processing.
3. Personal Data We Collect. Purposes of Processing
3.1. We need to collect certain information about you to provide you with Educar Services or the support you request. The types of personal data we collect depend on how you register an account in Applications. We process your personal data for the following purposes:
|Provided to us by filing a registration form||
|Provided to us from yourFacebook account||
|Provided to us from yourGoogle account||
|Information we get automatically||
3.2. We may associate your device IDwith your account to help us provide you with the Educar Services and support your request.
3.3. When you purchase a subscription you may be asked by third parties to provide additional information in order to complete the financial transaction. We do not collect such information and do not control, supervise or respond for the processing of such information. Any request regarding such personal data should be directed to such third parties.
3.4. We do not collect and process the personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
3.5. We may process data for any other purposes disclosed to you in connection with the Educar Services from time to time. If we intend to process your personal data for a purpose other than set out above and which is not compatible with the original processing purpose, we will provide you with relevant information prior to such processing and will obtain your consent where necessary.
- Lawfulness of Processing
4.1. We process your personal data provided by filling a registration form and from Facebook or Google accounts based on your explicit consent. We process your device ID when you access Applications, so such processing is necessary for the purposes of our legitimate interests in order to ensure the use of Applications. We may also process your device ID based on explicit consent.
4.2. We are located in Ukraine that does not ensure an adequate level of protection for the personal data as determined by the European Commission. However, we shall implement appropriate technical and organizational measures to ensure an adequate level of security of your personal data in accordance with Data Protection Laws. The main enforceable rights and effective remedies set out in Data Protection Laws are available for you.
4.3. We obtain explicit consent from you by offering an explicit consent screen that contains the sign “I, hereby, consent to the processing of my data” and “Yes” and “No” check boxes.
- Your Age
5.1. We provide the Educar Services intended for use by people age 16 and over.
5.2. By using or accessing Applications, you acknowledge that you are 16 years old and have all rights necessary to provide us with the explicit consent for the processing of your personal data.We shall not be liable for any consequences if it becomes clear that you have not reached the age of 16 at the moment of the consent is being provided.
5.3. If you know that we process data of individuals under 16 years old, please inform us of it by sending email to: insert the email.
- Period of Storage
6.1. We process and store your personal data within the period needed for achieving the purposes of processing, specified in this Policy.
6.2. Your personal data is securely stored in Holland.
6.3. Taking into account the nature, scope and purposes of the processing, the storage period is as follows:
|PERSONAL DATA||STORAGE PERIOD|
||based on when you were last active|
6.4. After the end of the storage period, we are obliged to delete your personal data or ask you to provide us with a new or an additional consent, if the necessity of processing remains actual for us or another purpose of processing appears.
6.5. We are entitled to delete your personal data at any time if such data is no longer needed for the purposes stated in this Policy. We are obligated to notify you of the deleting of your personal data.
6.6. We may keep storing the personal data if subsequent processing is foreseen by law and is deemed relevant for a purpose which is not compatible with the original purpose of processing stated in this Policy.
- Data Subject Rights
7.1. You have the following rights:
- right to be informed –the right to information on data is being collected, how it is being used, how long it will be kept and whether it will be shared with any third parties. This information must be provided concisely and in plain language;
- right of access – the right to ask us for copies of your personal data;
- right to rectification– the right to ask us to rectify information you think is inaccurate. Youalso have the right to ask us to complete information you think is incomplete;
- right to erasure– the right to ask us to erase your personal data in certain circumstances;
- right to restriction of processing– the right to ask us to restrict the processing of your personal data in certain circumstances;
- right to object to processing – the right to object to the processing of your personal data in certain circumstances;
- right to data portability – the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances;
- right to not be subject to automated decision making and profiling– the right to object to any automated profiling that is occurring without consent. You have the right to obtain human intervention on the part of the controller.
7.2. You can exercise any of the rights described above by sending a request to the email address: firstname.lastname@example.org. Your request must include your name, contact information, right that you want to exercise, personal data processed by us, details and reason/justification for such request.
7.3. Each of these rights is supported by appropriate procedures that allow the required action to be taken within the timescales stated below.
|The right to be informed||When data if collected|
|The right of access||One month|
|The right to rectification||One month|
|The right to erasure||Without undue delay|
|The right to restrict processing||Without undue delay|
|The right to date portability||One month|
|The right to object||On receipt of objection|
|The right to not be subject to automated decision making and profiling||Not specified|
- Withdrawal of Consent. Complaint Lodgement.
8.1. You are entitled to withdraw consent at any time you wish, without affecting the lawfulness of processing based on consent before the withdrawal.
8.2. You have the right to lodge a complaint with us if you consider that the processing of your personal data infringes the relevant Data Protection Laws.
8.3. You may exercise the rights to withdraw consent or lodge a complaint by sending a request/complaint to the email address: email@example.com.
8.4. The complaint/request for withdrawal of consent shall be verified within 72 hours since the respective complaint or request was received. We shall inform you of the progress and the outcome of the request/complaint.
- Managing Your Account
You remain in control of the information you provide to us. You may delete your account in Applications at any time. If you delete your account, all information you provided us and the study achievements will be also deleted in accordance with our data retention practices.
10.1. The security of personal data is important to us and we take all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of personal data.These efforts include:
- the security and integrity of the Applications. This includes investigating, detecting and preventing or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited or illegal activities or to otherwise help protect your account;
- protecting our and third parties’ rights and property and enforcing our Terms of Service or other applicable agreements or policies;
- verifying your identity. In some cases, we may need to verify your identity in order to protect the security and integrity of your account;
- complying with any relevant Data Protection Laws. This includes appropriately responding to lawful requests for information from the government or third parties through the legal process;
- contacting you to provide assistance.
10.2. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.If you have any questions about security measures taken by us, you can contact us firstname.lastname@example.org.
10.3. If we know or have reason to know of a systems security breach by an unauthorized party of your data where that data is being or is likely to be used for an unauthorized purpose, we will promptly notify you so that you can take appropriate steps.
11.1. In the course of processing of your personal data, we may engage processors that act only in accordance with our written instructions, contractsand any other appropriate confidentiality, security or other requirements in order to comply with the relevant Data Protection Laws. The processors are not entitled to define any additional purposes for the processing of personal data that are not specified in this Policy. Processors that get personal data from us are located in .
11.2. Your personal data may be processed by such processors to provide you with the information and support you request, including technical notices, security alerts, and other administrative messages to provide assistance for problems you may encounter with your account.
- Data Breach Notification
12.1. We comply with relevant Data Protection Laws. We take all reasonable steps to minimize the risk of the personal data breach involved by the processing of personal data.
12.2. If a personal data breach is likely to result in a risk to your rights and freedoms, the relevant supervisory authority will be informed within 72 hours.
12.3. If a personal data breach is likely to present high risks to your rights and freedoms, we are obligated to inform you of such breacheswithout undue delay, so that you can take appropriate steps.
- Data Transfer
13.1. The transfers of personal data will be carefully reviewed prior to the transfer to ensure that they fall within the limits imposed by the relevant Data Protection Laws.
13.2. We do not sell or trade your personal data to any legal or natural persons.
13.3. We reserve the right to transfer your personal data to the processors in accordance with the terms specified in this Policy.
- Changes to this Policy
We reserve the right to modify this Policy at any time, so please review it frequently. If we materially change how we use your personal information, we will notify by email and/or by means of a notice in Applications prior to the change becoming effective. If you disagree with these changes, you can delete your account at any time and/or stop using the Applications. Your continued use of the Applications constitutes your acceptance of any amendments to this Policy.
- Contact Us
If you have questions or wish to send us comments about this Policy, please contact us email@example.com or write to us:
Heroiv Dnipra Street, house 7
Kyiv, 04209, Ukraine