1. General Provisions.

This Privacy Policy describes how the online English language school (hereinafter referred to as the School) collects, uses, and protects the personal data of Users who use the website and educational services.

This applies exclusively to information or data that is automatically collected on the Website https://karpaty.school/ (hereinafter referred to as the Website) or voluntarily provided by users in the course of using the website and educational services.

The Website is administered by Once Agency, which is recognized as the controller and owner of personal data.

Before using the Website, users are kindly asked to review this Policy in order to understand the principles and methods of processing User data.

By using the School’s website, the User agrees to the terms of this Policy.

2. Definitions of Terms.

2.1. The following terms are used in this Policy with the meanings specified below: 

2.1.1 User – a subject of personal data who has access to the Website, in respect of whom personal data is collected, stored, processed, and transferred.

2.1.2 Personal data – information that directly or indirectly relates to a specific natural person as a subject of personal data.

2.1.3 Service/Course – a set of informational and consulting services and services providing access to digital content delivered to the User under the Public Offer Agreement and which may include elements defined on the Website.

2.1.4 Cookies – a small fragment of data that the Website stores on the User’s device (computer, phone, tablet, etc.) when visiting the Website.

3. Collection of Personal Data.

3.1. A User of this Policy and the Website, and accordingly a subject of personal data, may be a person with full legal capacity under the legislation of the state of their citizenship.

3.2. If a person does not have sufficient legal capacity, the School shall consider the consent to the processing of personal data of such person as having been provided by their parents, guardians (custodians), adoptive parents, or legal representatives.

3.3. Sources from which personal data is obtained:

• Registration forms completed by the User to receive feedback on the Website or from the School;
• Email: by receiving/sending electronic messages when interacting with the School;
• Interaction with advertising materials about the School’s services on third-party websites;
• Data from other sources (social networks; search engines; marketing research; third-party data aggregators; public and other sources from which the School has obtained access to personal data).

3.4. The School collects only those personal data that were voluntarily provided by the User for using the Website, educational services, and communication with the School.

3.5. When using the Website and receiving services, the User’s personal data may be processed, including but not limited to:

• last name, first name, patronymic;
• email address;
• contact phone number;
• login details for the personal account.

3.6. The School makes efforts to protect personal data that may be automatically transmitted during a visit to the Website, including but not limited to: IP address, information from cookies, information about the browser (or other software used to access the Website), payment data (via payment providers), access time, addresses of visited pages, etc.

3.7. During communication between the User and the School (in particular, via feedback forms or email), records and logging of communications may be carried out to improve the quality of services.

3.8. The School has the right to publish User reviews regarding the services provided and consumed by the User under the public offer.

3.9. Responsibility for the accuracy of personal data voluntarily provided by the User to the School and all consequences related thereto rests directly with the User.

3.10. The School does not collect data prohibited or restricted from collection under the Law of Ukraine “On Personal Data Protection” and does not process personal data that pose a special risk to the rights and freedoms of Users.

4. Purpose of Using Personal Data.

4.1. For the proper provision of services, the School collects and uses the User’s personal data, in particular, for:

• registering the User and creating an account;
• providing access to educational materials;
• technical support and communication;
• processing payments and accounting;
• informing about updates, new courses, and service messages;
• improving platform performance and analytics;
• conducting statistical and other studies based on anonymized user data.

4.2. The User’s personal data may be used exclusively within the scope necessary for the proper fulfillment by the School of its obligations under the Public Offer, even if such purposes are not expressly provided for in this Policy.

5. Third-Party Services.

5.1. In order to ensure proper functioning of the Website, communication with Users, and payment processing, the School may use third-party services, including but not limited to:

• Google services for analytics and advertising;
• communication services (including messengers and email);
• databases and cloud services for data storage;
• electronic payment services;
• services for user relationship automation;
• cloud services.

5.2. When using such services, the processing of the User’s personal data is carried out in accordance with their privacy policies, consent to which the User provides independently and at their own discretion.

5.3. The School does not directly transfer Users’ personal data to these services; however, information entered by the User or stored through such services may be processed in accordance with their terms, of which the User is fully informed.

5.4. The School does not transfer or sell Users’ personal data to third parties for advertising purposes. All data processed by the services specified in clause 5.1 of this Policy are collected automatically in compliance with this Policy, in accordance with browser settings and permissions granted by the User.

6. Protection of Personal Data.

6.1. The School takes all necessary technical and organizational measures to protect the User’s personal data from unlawful or accidental access by third parties, destruction, blocking, distribution, copying, etc. Such measures include:

• encryption of connections (HTTPS);
• restriction of access to data;
• use of secure servers and services;
• regular security checks.

6.2. In the event of a data breach or unlawful distribution of personal data caused by third parties, the School shall immediately, upon discovering the breach and/or unlawful distribution, notify the User by sending a message to the email address provided by the User or by any other available means of communication.

7. Components and Processing of Cookies.

7.1. The School collects Cookies to improve the operation of the Website and identify Users, track Website visit statistics, and enable optimization and adaptation to the interests of each User.

7.2. This Privacy Policy provides for the processing of “session” and “persistent” Cookies:

• “session” Cookies are temporary and are stored only until the browser session ends;
• “persistent” Cookies remain on the User’s device hard drive or electronic storage until the User deletes them.

7.3. The School may process:

• Necessary Cookies that help make the Website usable by enabling basic functions such as page navigation and access to secure areas of the Website. The Website cannot function properly without these Cookies.
• Statistical Cookies that help the School understand how Users interact with the Website by collecting and reporting information anonymously.
• Marketing Cookies are used to track Users of the Website. The goal is to display advertisements that are relevant and engaging for the individual User.

7.4. The User has the right to refuse the use of Cookies by changing the settings in their browser software or by sending an email to the School’s email address.

7.5. If Cookies are refused, the User may not be able to fully use all Website features.

8. Consent to the Processing of Personal Data.

8.1. Consent to the processing of personal data is granted in the following ways:

• by filling out a feedback form and marking acknowledgment of this Policy;
• by communicating with the School via email during the provision of services.

8.2. The User agrees to the processing of personal data, including collection, recording, storage, updating or modification, anonymization, use, distribution, granting access, blocking, deletion, or destruction of personal data, for the purpose of forming a User database, compiling statistical reports, conducting marketing research, and interacting with the User, including sending SMS messages and emails, until such consent is withdrawn or revoked.

8.3. The User agrees that the School may contact them through direct communication channels, including but not limited to email and messengers.

8.4. The User is solely responsible for the use of personal data of third parties that they obtain, publish, or provide to others using the Website and confirms that they have obtained the consent of such third parties to provide their data to the School.

8.5. The User’s consent to the processing of personal data specified in this section may be withdrawn by the User at any time by sending an email to the School at the address indicated on the Website.

9. Processing and Storage of Personal Data.

9.1. The School collects personal data from the sources provided for in this Policy.

9.2. The School processes personal data using automated processing and/or manually, and/or with the involvement of third parties.

9.3. The User is informed that third parties provide services or perform duties on behalf of the School, including technical support, user service, marketing, and conducting surveys. 

9.4. The accumulation of collected personal data occurs by entering them into an appropriate database stored electronically on the server where the Website is hosted.

9.5. The User’s personal data is stored for as long as necessary to achieve the purposes of this Policy, for the duration of the provision of educational services under the Public Offer Agreement, and in accordance with applicable accounting and reporting legislation, or until deletion upon the User’s request.

10. Disclosure, Modification, and Deletion of Personal Data.

10.1. The User is aware that the School may be required to disclose the User’s personal data upon a lawful request of public authorities where legal grounds exist.

10.2. The User has the right to request changes to their personal data.

10.3. The basis for making changes to personal data is a written request from the User sent from the email address provided by the User in the feedback form on the Website to the School’s email address specified in the contact details.

10.4. Changes are promptly made to the personal data database upon establishing non-compliance in accordance with the stated requirements.

10.5. The User has the right to request termination of processing of their personal data, deletion of data, or restriction of processing.

10.6. The User may withdraw consent to the processing of personal data.

10.7. Grounds for deletion and destruction of personal data:

• withdrawal of consent to the processing of personal data submitted by the User in the form of a written request sent to the School’s email address from the email address provided by the User in the feedback form or provided in any other way;
• expiration of the personal data processing period.

10.8. The School informs the User of the consequences of withdrawing consent.

10.9. Upon withdrawal of consent or expiration of the storage period, the School deletes or destroys the User’s personal data without delay.

10.10. In the event that personal data is deleted as a result of withdrawal of consent to processing, the School has the right to terminate the provision of services under the Public Offer.

11. Liability.

11.1. In the event of loss or disclosure of personal data, the School shall not be liable if such personal data:

• became or were public prior to their loss or disclosure;
• were obtained from a third party before being received by the School;
• were disclosed with the User’s consent.

11.2. The School shall not be liable for the processing of personal data in the following cases:

• use of third-party services that ensure the operation of the Website and communication;
• Users navigating to third-party websites via links posted on the Website.

11.3. The User and the School resolve all disputes and disagreements arising from relations governed by this Policy through negotiations.

12.Final Provisions.

12.1. This Privacy Policy comes into force from the moment it is posted on the Website.

12.2. Informed consent to mailing lists, the Cookies Notice, and other provisions in any form regarding the processing of personal data posted on the Website are integral parts of this Privacy Policy.

12.3. The provisions of this Policy apply exclusively to the Website.

12.4. The School reserves the right to make changes to this Policy in the event of changes in the method, procedure, or purpose of collecting, processing, using, or storing personal data.

12.5. The Policy is valid in the version effective at the time of its adoption and publication on the Website.

12.6. All questions regarding the collection, processing, storage, and protection of personal data should be sent to: info@karpaty.school