This PRIVACY AND PERSONAL DATA PROTECTION POLICY (hereinafter referred to as the Policy) is developed in accordance with the requirements of Directive 2002/58/EC of the European Parliament and of the Council of July 12, 2002 on the processing of personal data and the protection of privacy in the electronic communications sector (the "Privacy and Electronic Communications Directive") and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (the "Law").
This Policy establishes the procedure for the Contractor, Dmytro Anatoliiovych Diuh, Individual Entrepreneur, EDRPOU Code 3462104356 (hereinafter referred to as the Company or "Foror University"), to process personal data provided by customers who use the website https://navchalnya.fooror.com/ and its individual services to receive or provide services (hereinafter referred to as Users and the Website, respectively). The Policy determines the types of personal data collected, the purpose of using such personal data, the Company's interaction with third parties, security measures to protect personal data, conditions for access to personal data, as well as contact information for the user to access, amend, block or delete their personal data and handle any questions that may arise regarding personal data protection practices.
The Company has great respect for the confidential (personal) information of all persons, without exception, who have visited the Website https://navchalnya.fooror.com/, as well as those who use the services provided by the Website: in this regard, the Company strives to protect the confidentiality of personal data (information or a set of information about an individual who is identified or can be specifically identified), thereby creating and ensuring the most comfortable conditions for using the Website services for each user.
The text of the Policy is available to Users on the Internet at https://navchalnya.fooror.com/privacy-policy. In case of disagreement with the terms of the Policy, the User must immediately stop using the Website.
1. Terminology and abbreviations
The terminology used in this Policy means the following:
1.1. Personal Data - Any information relating directly or indirectly to a specific or identified individual (personal data subject).
1.2 User/Customer - A person who accesses the information posted on the Website by the Contractor
1.3. Contractor - Individual entrepreneur Diuh Dmytro Anatoliyovych EDRPOU code 3462104356 (hereinafter referred to as "Fooror University")
1.4. Processing of personal data - Any action or set of actions performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.5. Automated processing of personal data - Processing of personal data by means of computer technology. Despite this, automated processing of personal data does not contain an automatic processing system, including profiling, which creates legal consequences in relation to the User, or which in a similar way significantly affects the User.
1.6. Dissemination of personal data - Actions aimed at disclosing personal data to an indefinite number of persons.
1.7. Provision of personal data - Actions aimed at disclosing personal data to a specific person or a specific circle of persons.
1.8. Blocking of personal data - Temporary suspension of the processing of personal data (except when processing is necessary to clarify personal data).
1.9. Use of personal data - Actions (operations) with personal data performed by the Company in order to make decisions or perform other actions that generate legal consequences in relation to the subject of personal data or other persons or otherwise affect the rights and freedoms of the subject of personal data or other persons and are within the limits of the current Legislation of Ukraine.
1.10 Depersonalization of personal data - actions as a result of which it becomes impossible to determine the ownership of personal data to a specific subject of personal data without the use of additional information. https://navchalnya.fooror.com/#courses
1.13. Online platform - The Company's software, which is a set of interconnected web services and modules that make up a single space for providing services to consumers on the Internet
1.14. Free lesson - Audiovisual material (webinar), access to which, as well as to all materials, is provided by the Company free of charge to all users who have registered for participation. The Company conducts free classes for all interested users. The free training is not a full or partial educational program, but only serves as a demonstration (introductory) function. User Agreement - An agreement posted on the Internet at https://navchalnya.fooror.com/oferta, which is an offer of Fooror University to enter into an agreement with any third party using the Site on the terms and conditions provided for by the User Agreement.
1.16. Site - A set of information, texts, graphic elements, design, images, photos and videos, reviews and other results of intellectual activity, as well as computer programs contained in an information system that provides access to such information on the Internet via a network connection.
1.17. Personal Account - a section of the Website to which the User gets access after his/her registration on the Website by entering a unique login and password.
1.18. Cookies - Data that is automatically transmitted to the Company in the process of using the Site using the software installed on the User's device, including IP address, geographical location, information about the browser and the type of operating system of the User's device, technical characteristics of the equipment and software used by the User, date and time of access to the Site. Cookies can be eternal (called persistent cookies) and stored on the computer until the user deletes them, or temporary (such cookies are called session cookies), that is, they are stored only until the browser is closed. In addition, cookies are divided into first-party cookies (they are set directly by the visited Website) and third-party cookies (set by other websites when the relevant data is entered).
1.19. "IP address" is a numerical designation used by computers on a network to identify a computer each time it accesses the Internet.
2. User's consent to the processing of personal data by Fooror University
2.1. The User accepts the terms of the Privacy Policy and gives the Company an informed and conscious consent to the processing of his/her personal data under the conditions provided for by this Policy and the current Legislation of Ukraine:
2.1.1. When registering on the Website - for personal data provided by the User to the Company:by filling out the registration form located on the Internet, it is considered that the User has given consent to the processing of his personal data when he ticks the box "I accept the terms of the Offer Agreement and agree to the personal data processing policy" at the moment of clicking the "Register" button;by authorization using personal data provided by the User in social networks or electronic services. It is considered that the User has given his/her consent to the processing of his/her personal data at the moment of clicking the button displaying the social network or electronic service selected for authorization or other generally available method of communication with the Contractor. By clicking the specified button, the User agrees to transfer to the Company all personal data that he/she has made publicly available by indicating in the profile of the relevant social network or electronic service.
2.1.2. When entering or changing personal data in the "Personal Data" section in the personal account - for personal data that the User provides when editing information in the "Personal Data" section in the personal account. The User is considered to have consented to the processing of his/her newly entered or changed personal data at the moment of clicking the "Save" button.
2.1.3. When filling out the feedback form - for personal data that the User provides to the Company when filling out the feedback form through the Internet search engine on the Website and electronic services (e.g. Google, etc.). The User is automatically deemed to have consented to the processing of his personal data entered in the fields of the feedback form at the moment of clicking the button confirming the submission of the application (the buttons may be called "Send", "Leave a request" and other similarly named).
2.1.4. When subscribing to receive information and news materials from the Company - by filling out the form for subscribing to the newsletter located on the Internet. The subscription form becomes available after the registration procedure. The User is considered to have consented to the processing of their personal data when they tick the box "I hereby consent to the processing of personal data" at the time of clicking the "Subscribe" button.
2.1.5. Enrollment in the Online Program by filling in the fields of the application for enrollment located on the Internet. It is considered that the user has given consent to the processing of his/her personal data when he/she ticks the "Enrollment" form at the moment of clicking the "Register" button.
2.1.6. Enrollment in a Free Class - by filling in the fields of the application form located on the Internet. The user is considered to have consented to the processing of his/her personal data when he/she ticks the "Enrollment" form at the moment of clicking the "Register" button.
2.1.7. During any use of the Website - for personal data that is automatically transferred to the Company in the process of using the Website using the software installed on the User's device. It is considered that the User has given consent to the processing of their personal data when they start using the Website from the moment of transition to it, after creating a corresponding search query on the Internet.
2.2. The User's consent to the Company's processing of his/her personal data is valid from the date of granting consent to their processing (clause 2.1 of the Policy), and for the period necessary to achieve the purposes of processing personal data (section 5 of the Policy).
2.3. The User has the right to withdraw consent to the processing of personal data in the form and manner prescribed in Section 9 of the Policy.
3. Consent to the provision of personal data by the User
The Company assumes that when providing personal data on the Website, the User:
3.1. Confirms that he/she has legal capacity and possesses all the necessary civil rights and obligations that allow him/her to enter into civil transactions and perform them independently, as well as is able to assume responsibility for their independent performance, i.e. is tortious and may be liable in accordance with the Legislation arising in case of failure to perform them;
3.2. Provide accurate information about themselves to the extent necessary to use the Site and keep the provided personal data up to date.
3.3. If the User uploads his/her image through the personal account of the Website, he/she agrees to use this image for purposes not related to the identification of the User free of charge. The User undertakes not to provide photographs of third parties as the User's image.
3.4.The User is aware that the information on the Site posted by the User about himself/herself may become available to other users of the Site, may be copied and distributed by such Users in the cases and under the conditions specified in clause 6.7 of the Policy.
3.5. CONSENT TO RECEIVE MESSAGES AND CALLS
By submitting your data, you agree to receive messages from the Company and its employees. The Company and its employees may call or send messages via:
-e-mail;
-SMS messages and calls to a mobile number;
-messages and calls to messengers (Viber, Telegram, WhatsApp, etc.)
3.6. The User realizes that any telephone conversations held by him/her with an employee of the Company are automatically recorded in order to control the quality of user service, as well as to resolve controversial and conflict situations that may arise in such telephone conversations. At the same time, the User agrees to such automatic recording of telephone conversations and storage of such records in accordance with the terms of this Policy.
3.7. Having read this Policy, the User expresses his/her informed and conscious consent to it.
4. Personal data processed by Fooror University
4.1 The personal data of the User processed by the Company includes: surname, name, patronymic; mobile phone number; e-mail address; data of accounts in social networks and electronic services (links to the User's profiles in Instagram, Facebook, Linkedin, Zoom, Google, Twitter, Telegram, Viber, etc. etc.);image;place of work;country, city;date of birth;profession;data on work experience and position;IP address;cookies;parameters and settings of Internet browsers (User-agent).
4.2. The Company protects the Data that is automatically transmitted during the viewing of ad units and when visiting pages on which the system statistical script ("pixel") is installed: IP address; information from cookies; information about the browser (or other program that provides access to the display of advertising); access time; address of the page on which the ad unit is located; referrer (address of the previous page).
4.3. When visiting the Website, all logins to the system are recorded. Other information on user traffic is not processed or stored.
4.4. The Company does not collect any information for the processing of which certain requirements are established by law, such as information on racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, data on legal liability or conviction to criminal punishment, as well as data related to health, sexual life, biometric or genetic data.
4.5. The Company collects data on website traffic statistics. The information may contain information about the connection, traffic, user's browser, as well as the date, time, duration of work on the Internet and stay on the Site.
4.6. Any other personal information that is not specified above (history of visits, browsers and operating systems used, etc.) is subject to reliable storage, protection and non-disclosure to a circle of persons not specified by law.
5. Use of cookies
5.1. Foror University cares about its users and tries to make their stay on the Site as comfortable as possible, and for this purpose the Company needs to analyze the behavior, preferences and interests of the user using cookies. Such analysis will help the Company to improve the User's experience of interaction with the Website, to determine the most convenient interface and navigation of the Service for the User.
5.2. According to the classification of the International Chamber of Commerce, the Company uses the following categories of cookies:
- Strictly necessary (mandatory) cookies - required for the user to move around the web page and use certain services, for example, to access secure pages, register and authorize, search the Site. They also memorize the user's previous actions when going to the previous page in the same session.
- Performance cookies - aggregate information about how the Website is used. This data is stored on the user's device between web browser sessions. Examples of such data may include the following metrics: time spent on the Site, most frequently visited pages, understanding which sections and services of the Site were most interesting to the user, how effective a particular advertising and/or marketing campaign is, etc. All information collected through performance cookies is intended for statistical and analytical purposes. Some cookie data may be provided to third parties that have permission from the website and solely for the purposes specified above.
- Functional cookies - used to save parameters or configurations that are stored on the user's device between web browser sessions. Examples of such data may include the following metrics: username, profile photo, information on comments left (namely, on the company's social networks, online classes, chat bots), language of the site, location, information about whether the user has been provided with any information or selected preferences before, as well as other settings of the Site.These cookies also allow users to watch videos, participate in interactive activities (polls, voting) and interact with social networks.To make the experience more pleasant after
- Targeting cookies - used to provide content that may be of interest to the user. This data is stored on the user's device between web browser sessions. Examples of such data may include the following metrics: tracking recommended text, graphics, audio and video material in order to avoid repeated display, managing targeted advertising, evaluating the effectiveness of advertising campaigns, information about user visits to other resources during transitions, as well as other settings of the Site.The Site may share this information with other parties, including media clients, advertisers, agencies and related business partners in order to provide quality targeted advertising.
Cookies of third-party services and analytics services:
For prompt delivery, better display and detailed analysis of content on the Site, the Company uses services owned by other third-party companies, such as Facebook, Twitter, Instagram and others.The companies listed as an example may use cookies on the user's device while working on the Site.
Please note that the Website cannot influence the operation of cookies used by these services. All the necessary information about their use can be found by visiting the corresponding resource.Google Analytics Terms of Use - http://www.google.com/analytics/terms/ru.html
Cookie Management:
The main web browsers (listed below) are set to automatically accept cookies. To disable them, use the help function in your browser. Help can be accessed through the menu or by pressing F1.
Microsoft Edge —
https://privacy.microsoft.com/uk-ua/privacystatementMozilla Firefox—
https://www.mozilla.org/en-US/privacy/websites/ Google Chrome —
https://support.google.com/chrome/answer/95647?hl=ukOpera —
http://help.opera.com/Windows/11.50/ua/cookies.htmlSafari for macOS —
https://support.apple.com/kb/PH21411?locale=en_US
Please note: the configuration of cookie settings for mobile device web browsers may differ;it should be recalled that full-fledged work with the Site is available only if cookies are used;disabling cookies may lead to restrictions on access to the content and the full functioning of the Site's services.To contact the Company regarding the use of cookies, send an e-mail to info@fooror.com. If the user does not enable the use of cookies or deliberately deletes all cookies from his/her web browser, the user will be offered to enable and use cookies again during subsequent visits to the Site.Information about users obtained through cookies is not sold or distributed in the public domain, and is the property of the company that owns the resource.
6. Purposes of personal data processing
The Company processes personal data of Users solely for the following purposes:
6.1. Registration of the User by the Company on the Site, providing the User with the opportunity to fully use the services of the Site.
6.2. Displaying the User's profile on the Site in the personal account.
6.3. Establishing and maintaining communication between the User and the Company, advising on the provision of services, providing customer and technical support in case of problems related to the use of the Site.
6.4. Fulfillment by the Company of its obligations to the User who has enrolled in the Online Program for a Free Class under the agreements with the Company.
6.5. The Company sends advertising messages to the User's e-mail address; targeting of advertising materials.
6.6. Improving the quality of user service and modernization of the Company's Website by processing requests and applications from the User.
6.7. Statistical and other research based on anonymized information provided by the User.
6.8. Posting on the Company's Online Platform, available at https://navchalnya.fooror.com/, in official social media groups and other communities of the Company on the Internet, other advertising and information sources, for purposes not related to the identification of the User: video materials obtained in the course of providing services; feedback left by the User about the services provided by Fior University regarding the social network Facebook: Facebook does not offer a separate data processing agreement for any products. If Facebook processes data on behalf of customers, the terms and conditions of Facebook products are subject to the requirements of the data processing agreement. For more context, Facebook has drafted data processing addendums to clearly track the required provisions set out in Article 28(3) of the GDPR, which governs data processing agreements. Among the key functions where Facebook acts as a data processor for advertisers and processes data from EU users, the data processing addendum (1) limits Facebook's data processing except as specified by the advertiser (in accordance with the applicable product terms); (2) requires Facebook to adopt appropriate technical and organizational measures to protect personal data; and (3) imposes obligations on Facebook to assist advertisers in fulfilling the advertiser's own GDPR obligations as a data controller. Relevant terms can be found here:
Facebook Business Tools Terms
Custom Audience Term
Data Processing Terms.
The user has the right to unsubscribe from the newsletter. In this case, their name and email address will be automatically removed from the database. To do this, just one mouse click on the corresponding item in each received email is enough.
7. Processing of personal data
7.1. The processing and storage of the provided personal data is carried out in data centers where the equipment that ensures the functioning of the Website services is located. The provided personal data is processed and may be stored in the Personal Database or in a separate table of the Website Database. Since the Company's servers are located in different regions around the world, the information of a particular User may not be considered in the country in which he or she resides. The level of information protection and legal regulations in this area may differ from country to country. Regardless of where the User's data is processed, the Company uses the same measures to ensure its security as described in this Policy. The Company also adheres to a number of international legislative norms in the field of data transfer, including the framework agreement between the US and the EU on privacy EU-US Privacy Shield Framework, as well as a similar agreement between the US and Switzerland Swiss-US Privacy Shield Framework.Personal data is processed using automated systems, except when non-automated processing of personal data is necessary in connection with the fulfillment of legal requirements.
7.3. The processing of the User's personal data includes the following actions by the Company: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
7.4. The collection of the User's personal data is carried out in the cases specified in clause 2.1 of the Policy.
7.5. Personal data is stored (depending on which event occurs first): until they are deleted by the User in the "My Profile and Applications" and "Settings" sections of the Personal Account; until they are destroyed by the Company - in case of receipt from the User of a withdrawal of consent to the processing of personal data or a request for the destruction of personal data; until the expiration of the consent (clause 2.2 of the Policy) or the achievement of the purposes of processing personal data.
7.6. The User can clarify personal data independently in the "Personal Data" sections of the Personal Account or by the Company at the request of the User.
7.7. The Company may disseminate personal data only in the following cases:
7.7.1. Subject to the processing of personal data in order to display the User's profile for other users of the Site to maintain communication, including when providing services remotely. In this case, the User's personal data may be available to the Users registered on the Website in accordance with clauses 2.1.4, 2.1.8.
7.7.2. For the purpose of posting reviews of the services provided by the Company, left by the Users, in various sources of information.
7.7.3. In order to place video materials obtained in the process of providing services in various sources of information.
7.8. The Company has the right to transfer personal data to third parties (Company Processors) subject to the following conditions:The third party ensures the confidentiality of personal data during their processing and use; undertakes not to disclose to other persons, as well as not to distribute personal data of users without their consent.The third party guarantees compliance with the following measures to ensure the security of personal data during their processing: use of information security tools; detection and recording of facts of unauthorized access to personal data. Destruction of personal data is carried out by the Company in the following cases:deletion of personal data by the User in the section "My profile and applications" and "Settings" of the personal account;receipt from the User of a withdrawal of consent to the processing of personal data;receipt from the User of a request for the destruction of personal data;expiration of the consent (clause 2.2 of the Policy).Foror University does not transfer personal data to third parties, except when such transfer is required by law, at the request of the personal data subject or in other cases. The Company understands that personal information is a value and inalienable content, including the personal non-property rights of any individual, and therefore takes all possible measures to protect the personal information of users voluntarily and knowingly transferred to the Company.
7.10. Cross-border transfer of personal dataThe Company is obliged to make sure that the foreign state to whose territory it is planned to transfer personal data provides adequate protection of the rights of personal data subjects, before starting such transfer.Cross-border transfer of personal data in the territory of foreign states that do not provide adequate protection of the rights of personal data subjects may be carried out in the following cases:the presence of written consent of the personal data subject to the transfer of personal data
8. Protection of personal data
The Company takes the necessary and sufficient legal, organizational and technical measures to protect the information provided by Users from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other illegal actions of third parties. However, despite its best efforts, the Company cannot guarantee absolute protection against any threats arising outside the Company's regulation.
The Company uses standard methods of work: encrypted communication, guarded premises, network protection systems and randomized password protection systems to ensure the confidentiality of personal data.
The Company provides access to information and personal data only to authorized employees who have agreed to ensure the confidentiality of such information and data in accordance with the requirements of the Company.
The Website may contain links to other websites (for informational purposes only). If you follow a link to other websites, this Policy will not apply to such websites. In this regard, the Company recommends that you familiarize yourself with the privacy and personal data policy of each website before submitting personal data that can be used to identify you.
9. Rights of Users
The User has the right to:
9.1. At his/her discretion, provide the Company with personal data for its processing under the conditions specified in the Policy. At the same time, some of the personal data provided is necessary for the conclusion of the User Agreement, and in case of failure to provide it, the conclusion of such an Agreement is impossible;
9.2. Independently make changes and corrections to your personal data in the section "Personal Data", in your personal account, provided that such changes and corrections contain relevant and reliable information;
9.3. Delete personal data by editing the section "Personal data" in the personal account;
9.4. Require the Company to clarify his/her personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect his/her rights;
9.5. Receive a response on whether personal data is processed no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, as well as receive the content of such personal data;
9.6. To submit a reasoned request to the owner of personal data with an objection to the processing of his/her personal data;
9.7. To apply legal remedies in case of violation of the legislation on personal data protection, including filing a complaint with a supervisory authority;
9.8. In order to update, access, amend, block or delete your personal data, revoke the consent to the processing of personal data that you have provided to the Company in accordance with this Policy, or if you have any comments, requests or claims regarding your personal data processed by the Company, please contact the Company by e-mail info@fooror.com
9.9. To send the Company your requests and demands, including those regarding the use of your personal data, as well as withdrawal of consent to the processing of personal data. The Request may be sent in writing to the Company's address (Section 11 of the Policy); or by e-mail (the Document must be sent from the User's e-mail address specified by him/her during registration on the Website or in the Agreement as an authorized e-mail address), to the Company's e-mail address info@fooror.com. The Company shall consider the User's Requests, respond to them and/or take the necessary actions within 30 calendar days from the date of receipt of the Request.
9.10. In addition to the rights listed in this Policy, the User has the opportunity to exercise any right provided for by law.
10. Change of Policy
10.1. The Company reserves the right to periodically and without prior notice to the User to make changes and additions, including in case of changes in the requirements of the law.The User is obliged to familiarize himself with the text of the Policy every time when using the Site.
10.2. The new version of the Policy comes into force from the moment it is posted in the relevant section of the Company's website. Continued use of the Website or its services after the publication of the new version of the Policy means acceptance of the Policy and its terms by the User. In case of disagreement with the terms of the Policy, the User must immediately stop using the Website and its services.
10.3. Please review the Policy from time to time in order to be aware of any changes or additions.
11. Information about the Company "Fooror University"
Individual entrepreneur Diuh Dmitry Anatolyevich
EDRPOU code 3462104356
Recipient's bank Joint Stock Company UNIVERSAL BANKR/r
IBAN: UA883220010000026007310049652
Email: info@fooror.com
Se: https://navchalnya.fooror.com/
