PRIVACY
POLICY
1. DEFINITION OF TERMS
This Privacy Policy contains the following terms:
1.1. "Administration of the Resource https://www.up.university/" (hereinafter - the Administration, the Operator) - authorized employees to manage the Resource, acting on behalf of the Individual Entrepreneur Kostyuk Alexander Dmitrievich, who is registered in the Uniform State Register of Legal Entities, Individual Entrepreneurs and Public Formations of Ukraine dated 07. 10.2020 under the number 2000650000000066400 (Tax Identification Number 2076800053), which organizes and (or) performs processing of personal data, and defines the purpose of processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data.
1.2 "Personal data" - is any information relating to a directly or indirectly identified or identifiable individual (the subject of personal data), including:
1.2.1 Personal information that the User provides about himself/herself when registering (creating an account, filling out an application for a course, writing a review, etc.) or in the process of using the Services, including the User's personal data. The information required to provide Services is marked in a special way. Other information is provided by the User at their discretion.
1.2.2 The data automatically transmitted to the Website services in the course of their use with the software installed on the User's device, including the IP-address, cookie files, information about the User's browser (or other program used to access the services), hardware and software specifications used by the User, date and time of access to the services, requested pages addresses, and other similar information.
1.3 "Personal data processing" means any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.4. "Confidentiality of personal data" - a mandatory requirement for the Operator or other person who obtained access to personal data to prevent its dissemination without the consent of the subject of personal data or availability of other legal grounds.
1.5 "Resource https://www.up.university/" (hereinafter referred to as the "Resource") is a set of interconnected web pages located in the Internet at the unique address (URL): https://www.up.university/, as well as its sub-domains.
1.6. "Subdomains of https://www.up.university/" are the pages located at the addresses:
1) https://lms.nekrasov.space/;
2) https://webinar.coachingup.university/;
3) https://www.mk.coachingup.university/;
4) https://www.it.coachingup.university/;
and other temporary pages, at the bottom of which you can find contact information: Individual Entrepreneur Oleksandr Kostyuk; Tax Identification Number: 2076800053; Address: Ukraine, 02072, Kyiv, 1b/6 Borysa Gmyry Str., Apartment 295; Phone: +38 (067) 504 56 22; E-mail address: tanya@coachingup.university.
1.7. "User of the https://www.up.university/ Resource" (hereinafter referred to as "User") means a person who has access to the Resource via the Internet and uses the information and materials of the https://www.up.university/ Resource.
1.8. "Cookies" - is a small piece of data sent by a web-server and stored on the user's computer, which the web-client or web-browser sends to the web-server each time in an HTTP-request when trying to open a page of the corresponding website.
1.9. "IP address" is the unique network address of a node in a computer network built using the IP protocol.
1.10. "Current threats to the security of personal data" - a set of conditions and factors that create a current risk of unauthorized, including accidental, access to personal data during their processing in the information system, which may result in the destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful actions.
2. GENERAL PROVISIONS
2.1 The User's access to the Website means consent to this Privacy Policy and the terms of processing of the User's personal data.
2.2 If the User does not agree with the terms of the Privacy Policy, the User must stop using the Website.
2.3 This Privacy Policy applies to https://www.up.university/.
2.4 The Website has no control over and bears no responsibility for any third party websites to which the User may go through the links available on the https://www.up.university/ Website.
2.5 The Administration does not verify the accuracy of the personal data provided by the User of the https://www.up.university/ Resource.
3. THE SUBJECT OF THE PRIVACY POLICY
3.1 This Privacy Policy sets forth the Administration's obligations regarding nondisclosure and ensuring the protection of personal data, which the User provides at the request of the Administration when registering on the Website or using the Website in any other way, as well as when placing an order for the purchase of goods or services.
3.2 Personal information which may be processed under this Privacy Policy is provided by the User by filling in the registration or feedback form on the Website and includes the following information:
3.2.1. the User's last name, first name, and patronymic;
3.2.2. the User's contact phone number. 3.2.3;
3.2.3. the User's email address.
3.2.4. the User's place of residence (at the request of the Administration).
3.3 The resource protects the Data, which is automatically transmitted in the process of viewing ads and when visiting pages on which the system's statistical script ("pixel") is installed:
3.3.1. IP address;
3.3.2. information from cookies;
3.3.3. information about the browser (or other program that accesses advertising);
3.3.4. access time;
3.3.5. address of the page on which the ad unit is located;
3.3.6. referrer (address of the previous page).
3.4 Disabling cookies may result in the inability to access the parts of the Resource that require authorization.
4. PURPOSES OF USER'S PERSONAL INFORMATION PROCESSING
4.1 The Resource ("Website") collects and stores personal information only as necessary for providing services or performing agreements and contracts with the User, except for cases when the law requires the mandatory storage of personal information for the period specified by the law.
4.2 The Administration of the Resource https://www.up.university/ may use the User's personal information for the purposes of
4.2.1 Identification of the User registered on the Website in order to place an order and (or) conclude, for example, an Offer Agreement for the provision of information and consulting services by remote means.
4.2.2 Providing the User with access to the personalized data of the Website.
4.2.3 Providing feedback to the User, including sending notices, requests regarding the use of the Website, provision of services, processing of requests and applications from the User.
4.2.4 Determining the User's location for security purposes, fraud prevention.
4.2.5 Confirming the accuracy and completeness of the personal data provided by the User.
4.2.6. Creating an account, if the User has agreed to create one.
4.2.7. Directing notifications to the User of the Resource (if necessary).
4.2.8. Processing and receiving payments, confirming tax or tax benefits, disputing a payment, determining the User's eligibility for a credit line.
4.2.9. Providing the User with effective customer and technical support when encountering problems related to the use of the Website.
4.2.10. Provide to the User with their consent product updates, special offers, pricing information, newsletters and other information on behalf of the Website or on behalf of the Website's partners.
4.2.11. Performing advertising activities with the consent of the User.
4.2.12. Providing the User with access to the websites or services of the Website's partners in order to receive products, updates and benefits.
5. METHODS AND TERMS OF PERSONAL INFORMATION PROCESSING
5.1 Processing of the User's personal data shall be carried out for no longer than the period, corresponding to the purposes of personal data processing, by any lawful means, including in information systems of personal data with or without the use of automation means.
5.2 The User agrees that the Administration may transfer personal data to third parties, in particular, to courier services, postal organizations, telecommunication operators, solely for the purposes of execution of the Offer Agreement, to which the User has joined the Website.
5.3 Personal data of the User may be disclosed to the authorized governmental bodies of Ukraine only on the grounds and in the manner prescribed by the laws of Ukraine.
5.4 In case of loss or disclosure of personal data, the Administration shall inform the User about the loss or disclosure of personal data.
5.5 The Administration shall take necessary organizational and technical measures for protection of personal information of the User from unauthorized or accidental access, destruction, change, blocking, copying, distribution, as well as from other unlawful actions of third parties.
In order to ensure security of personal data during their processing in the information system in accordance with the laws of Ukraine, the administration of the resource may engage on a contractual basis a legal entity or individual entrepreneur, having, if necessary, a license for activities on technical protection of confidential information.
Personal data security measures implemented as part of the personal data protection system, taking into account current threats to personal data security and applied information technologies, include the following measures, including, but not limited to
identification and authentication of the subjects of access and access objects;
access control of the access subjects to the objects of access;
restriction of the software environment;
protection of machine data carriers, on which personal data is stored and (or) processed (hereinafter referred to as personal data machine carriers)
registration of security events;
anti-virus protection;
intrusion detection (prevention);
control (analysis) of security of personal data;
ensuring integrity of information system and personal data;
ensuring availability of personal data;
protection of the virtualization environment;
protection of technical means;
protection of the information system, its facilities, communication and data transmission systems;
detection of incidents (a single event or a group of events) that may lead to failures or disruptions
operation of the information system and/or the emergence of threats to personal data security (hereinafter - incidents), and responding to them;
configuration management of information systems and personal data protection systems.
system and/or application software check, including software code, for absence of undeclared capabilities with and/or without the use of automated means;
testing of the information system for penetration;
use of system and (or) application software in the information system, developed using methods of protected programming.
5.6. The Administration together with the User takes all necessary measures to prevent damages or other negative consequences caused by the loss or disclosure of personal data of the User.
6. RIGHTS AND OBLIGATIONS OF THE PARTIES
6.1 The User has the right to demand that the Administration of the Website clarify its personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated processing purpose, as well as to take statutory measures to protect its rights.
6.2 If the User believes that the Administration of the resource carries out the processing of their personal data in violation of the Ukrainian legislation on personal data or otherwise violates their rights and freedoms, the User has the right to appeal the action or inaction of the operator to the competent authority to protect the rights of subjects of personal data or in court, including for damages and (or) compensation of moral damages in a judicial procedure.
6.3 The User has the right to withdraw their consent to the processing of personal data by sending a notice to the Website Administration at e-mail: tanya@coachingup.university (mail of the website administrator). The Website Administration stops processing personal data within the time frame stipulated by the applicable laws of Ukraine.
6.4 The User shall:
6.4.1 Provide information about personal data necessary to use the Resource.
6.4.2 Update, supplement the provided information about personal data in case of changes in this information.
6.5 The Resource Administration shall:
6.5.1 Use the obtained information solely for the purposes specified in Section 4 of this Privacy Policy.
6.5.2 Keep confidential information secret, not disclose it without the prior written permission of the User, and not sell, exchange, publish, or disclose by any other possible means the User's personal data, except for clauses 5.2 and 5.3 of this Privacy Policy.
6.5.3. Take precautions to protect the confidentiality of personal data of the User in accordance with the procedure generally used to secure this kind of information, as provided by the Law of Ukraine "On Protection of Personal Data" from 01.06.2010 № 229.
6.5.4. To block personal data related to the relevant User from the moment of application or request of the User, or its legal representative or authorized body for protection of the rights of subjects of personal data for the period of inspection, in case of unreliable personal data or unlawful actions.
7. LIABILITY OF THE PARTIES
7.1 The Website Administration which failed to fulfill its obligations shall be liable for losses incurred by the User due to illegal use of personal data in accordance with the legislation of Ukraine, except for the cases stipulated by paragraphs. 5.2, 5.3. and 7.2. of this Privacy Policy.
7. 2. In the case of loss or disclosure of Confidential Information, the Administration shall not be liable if this confidential information:
7.2.1. Was in the public domain prior to its loss or disclosure.
7.2.2. Was received from a third party prior to its receipt by the Website Administration.
7.2.3. Was disclosed with the User's consent.
7.3 The User is fully responsible for compliance with the laws of Ukraine, including, but not limited to, the laws on advertising, copyright and related rights, trademark protection, including full responsibility for the content and form of materials.
7.4 The User acknowledges that any information (including, but not limited to data files, texts, etc.) which the User may have access to as part of the Website is the responsibility of the person who provided such information.
7.5 The User agrees that the information provided to it as part of the Content may be an object of intellectual property, the rights to which are protected and belong to other Users, partners or advertisers who place such information on the Resource https://www.up.university/. The User may not modify, rent, lease, loan, sell, distribute or create derivative works based on such Content (in full or in part), unless such actions have been expressly permitted in writing by the owners of such Content pursuant to the terms of a separate agreement.
7.6 The text materials (articles, publications which are in free public access on the Website) may be distributed under the condition that the link to the website (any other resource) and the full name (Pseudonym, Nickname) of the author of this text material are provided.
7.7 The Administration shall not be liable to the User for any losses or damages suffered by the User as a result of deletion, failure or inability to store any Content or other communication data contained in the Website or transmitted via such Website.
7.8. Administration is not responsible for any direct or indirect losses occurring because of: use or inability to use the website or individual services; unauthorized access to User's communications; statements or behavior of any third parties on the website.
7.9. The Administration is not responsible for any information posted by the User on the Website, including, but not limited to, the information protected by copyright, without the express consent of the copyright owner.
8. DISPUTE RESOLUTION
8.1 The claim (written offer to voluntarily resolve a dispute) shall be filed prior to recourse to court for any disputes arising out of relations between the User of the Resource https://www.up.university/ and the Administration.
8.2 The recipient of the claim shall notify the claimant in writing about the results of consideration of the complaint within 30 calendar days from the date of receipt.
8.3 If no agreement is reached, the dispute will be transferred to the court at the location of the Administration.
8.4 The current legislation of Ukraine shall apply to this Privacy Policy and the relations between the User and the Administration of the Resource.
9. ADDITIONAL CONDITIONS
9.1 The Website Administration may make changes to this Privacy Policy without the User's consent.
9.2 A new Privacy Policy shall become effective upon its posting on the Website, unless otherwise provided by the new version of the Privacy Policy.
9.3 Any suggestions or questions regarding this Privacy Policy should be addressed to tanya@coachingup.university.
9.4 The current Privacy Policy is available at https://www.up.university/.
