PRIVACY POLICY OF THE "IN THE REAR" PLATFORM REGARDING THE PROCESSING AND PROTECTION OF PERSONAL DATA
GENERAL PROVISIONS1.1. This document (hereinafter referred to as the Policy) defines the policy of the "Mentors in the Rear" platform (hereinafter referred to as the Administrator or Company) regarding the processing and protection of personal data of data subjects that may be obtained by the Company when the data subject uses the services, non-exclusive licenses provided, including through the website, services, applications used by the Company.
A personal data subject is understood to be an individual who has voluntarily provided personal information about themselves while using the website, services, or during the registration process (creating a Personal Account and/or Profile), for the realization or purchase of services through the Website at the Internet address: "mentory.v-tylu.com" and its services, as well as for other purposes (hereinafter referred to as the User).
1.2. This Policy is developed in accordance with the requirements of Article 16 of the Law of Ukraine "On Personal Data Protection" dated 01.06.2010 No. 2297-VI (hereinafter referred to as the Personal Data Law).
1.3. The terms present in Article 16 of the Law of Ukraine "On Personal Data Protection" are used in this Policy with the same meaning.
1.4. This Policy applies to all operations performed by the Administrator with personal data using automation tools or without using such tools.
1.5. By registering on the website identified on the Internet by the domain name "mentory.v-tylu.com" (hereinafter referred to as the Site) and using the Site and the Site's services, the User fully agrees to the processing of their personal data during registration on the Platform and with the terms of this Policy.
1.6. If the User disagrees with the terms of this Policy, the use of the Site and/or any Services available when using the Site should be immediately terminated.
1.7. If the User disagrees with receiving information or promotional messages from the Company and/or Affiliates, the User may unsubscribe by sending a written request to .moc.liamg%40ulytv.yrotnem The request should contain information allowing the identification of the personal data subject. The Administrator is obliged to review the request and send a response or a reasoned refusal within 30 (thirty) working days from the date of receipt of the request.
1.8. Main rights and obligations of the Administrator.
1.8.1. The Administrator has the right to:
receive from the personal data subject accurate information and/or documents containing personal data;require the personal data subject to timely update the provided personal data.1.8.2. The Administrator is obliged to:
process personal data in accordance with the current legislation of Ukraine;review requests from the personal data subject (or their legal representative) regarding the processing of personal data and provide reasoned responses;provide the personal data subject (or their legal representative) with the opportunity for free access to their personal data;take measures to update, delete the personal data of the personal data subject according to their (or their legal representative) requests with legitimate and justified demands;organize the protection of personal data in accordance with the requirements of the legislation of Ukraine.1.9. Main rights and obligations of personal data subjects:
1.9.1. Personal data subjects have the right to:
complete information about their personal data processed by the Administrator;access to their personal data, including the right to receive a copy of any record containing their personal data, except as provided by law;update their personal data, block, or delete them if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared processing purpose;withdraw consent for the processing of personal data;take measures provided by law to protect their rights;delete the personal information provided within a certain account. However, deleting an account may make it impossible to use certain services of the Site;exercise other rights provided by the legislation of Ukraine.1.9.2. Personal data subjects are obliged to:
provide the Administrator with only accurate information about themselves;provide documents containing personal data to the extent necessary for processing purposes;notify the Administrator about the update (renewal, change) of their personal data.1.9.3. Persons who provided the Administrator with inaccurate information about themselves or information about another personal data subject without their consent are liable in accordance with the legislation of Ukraine.
VOLUME AND CATEGORIES OF PROCESSED PERSONAL DATA, CATEGORIES OF PERSONAL DATA SUBJECTS2.1. The Administrator may process personal data of the following categories of personal data subjects:
registered Users of the Company's Site;visitors to the Company's site(s) (hereinafter referred to as the Site and Sites).2.2. The personal data processed by the Administrator includes:
surname, name, and patronymic of the personal data subject;date of birth;place of residence (region/city);specialty/professional interests, work experience;information about education;payment information;mobile phone number;email address (e-mail);photographs;video images;information automatically obtained when accessing the Site, including through the use of cookies. IP address, type of operating system, type of browser, geographical location, Internet service provider;browsing and query history on the Site and its services (for Site visitors);date, time, and number of visits, information about the visited pages, used functionality, transitions from other resources, viewed advertisements, sent requests, feedback, and questions;data on online payments (information about the time, method, and amount of payment). Other information, including but not limited to, regarding the bank card, is processed by the payment system based on the approved rules of this payment system;other information (the provided list may be shortened or expanded depending on the specific case and processing purposes).2.3. The Administrator ensures that the content and volume of the processed personal data correspond to the declared processing purposes and, if necessary, takes measures to eliminate their redundancy in relation to the declared processing purposes.
2.4. The Administrator processes biometric personal data with the written consent of the respective personal data subjects, as well as in other cases provided by the legislation of Ukraine.
2.5. The processing of special categories of personal data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, intimate life by the Administrator is not carried out.
2.6. Cross-border transfer of personal data by the Administrator is not carried out.
PURPOSES OF PERSONAL DATA COLLECTION3.1. Personal data is processed by the Administrator for the following purposes:
identification of the party within the framework of offers, agreements, and contracts concluded with the Company and/or Affiliates; fulfillment of obligations under agreements concluded based on offers placed on the Site; provision of services to the User, non-exclusive licenses, access to the Site, Site services;processing of personal data subjects' requests;communication with the User, sending transactional letters to the User upon receipt of a registration application on the Site or payment from the User, once the User performs these actions, sending the User notifications, requests;sending the User promotional and/or informational messages;preventing cases of fraud and other abuses, as well as investigating such cases;conducting statistical and marketing research, as well as targeting (highlighting the target audience) advertisements based on anonymized personal data;verifying, researching, and analyzing such data to maintain and improve services and sections of the Site, as well as to develop new services and sections of the Site;resolving disputes;collecting feedback;fulfilling the requirements of the legislation of Ukraine.PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA4.1. Personal data processing by the Administrator is carried out by the following methods:
non-automated processing of personal data;automated processing of personal data with the transfer of received information via information and telecommunication networks or without such transfer;mixed processing of personal data.4.2. The list of actions performed by the Administrator with personal data: collection, systematization, accumulation, storage, updating (renewal, modification), use, distribution (including transfer), anonymization, blocking, destruction, as well as any other actions in accordance with the current legislation of Ukraine.
4.3. Personal data processing is carried out by the Administrator with the consent of the personal data subject (hereinafter referred to as Consent), except for cases provided by the legislation of Ukraine when personal data processing can be carried out without such Consent.
4.4. The personal data subject decides to provide their personal data and gives Consent freely, by their own will, and in their interest.
4.5. Consent is given in any form that allows confirming the fact of its receipt. In cases provided by the legislation of Ukraine, Consent is given in writing.
4.6. The condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, the expiration of the Consent, or the withdrawal of Consent by the personal data subject, as well as the detection of unlawful processing of personal data.
4.7. Consent may be withdrawn by sending a written notification to the Company's address by registered mail. The Consent must contain information allowing the identification of the personal data subject.
4.8. The Company provides access to the User's personal data to employees, contractors, and Affiliates who need this information to ensure the functioning of the Site, Services, and provision of Services, sale of goods, and obtaining a non-exclusive license by the User.
4.9. The Company has the right to use the information provided by the User, including personal data, to ensure compliance with the current legislation of Ukraine (including to prevent and/or stop illegal and/or unlawful actions of Users). Disclosure of the information provided by the User may be made only in accordance with the current legislation of Ukraine at the request of the court, law enforcement agencies, as well as in other cases provided by the legislation of Ukraine.
4.10. The Company does not verify the accuracy of the information provided by the User and assumes that the User, within the framework of good faith, provides accurate and sufficient information, and takes care of timely changes to the previously provided information if necessary, including but not limited to, changing the phone number.
4.11. The Administrator, during the processing of personal data, takes or ensures the taking of necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data.
4.12. Personal data storage is carried out in a form that allows identifying the personal data subject for no longer than it is required for the purposes of personal data processing, except in cases when the period of personal data storage is established by law, an agreement, which the personal data subject is a party, beneficiary, or guarantor.
4.13. When storing personal data, the Administrator uses databases located on the territory of Ukraine.
UPDATING, CORRECTING, DELETING, AND DESTROYING PERSONAL DATA, RESPONDING TO REQUESTS FROM PERSONAL DATA SUBJECTS FOR ACCESS TO PERSONAL DATA5.1. In the event of confirmation of the inaccuracy of personal data or the unlawfulness of their processing, personal data shall be updated by the Administrator or their processing shall be terminated accordingly.
5.2. The fact of the inaccuracy of personal data or the unlawfulness of their processing can be established by the personal data subject or by competent state authorities of Ukraine.
5.3. Upon a written request from the personal data subject or their representative, the Administrator is obliged to provide information about the processing of personal data of the specified subject. The request must contain the number of the main document identifying the personal data subject and their representative, information about the date of issuance of the specified document and the body that issued it, information confirming the participation of the personal data subject in relations with the Administrator (contract number, date of conclusion of the contract, conditional verbal designation, and (or) other information), or information that otherwise confirms the fact of personal data processing by the Administrator, the signature of the personal data subject or their representative. The request may be sent in the form of an electronic document signed with an electronic signature in accordance with the legislation of Ukraine.
5.4. If the request of the personal data subject does not contain all the necessary information or the subject does not have the right to access the requested information, a reasoned refusal is sent to them.
5.5. In the manner provided for by clause 6.3, the personal data subject has the right to demand from the Administrator to update their personal data, block, or destroy them if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared processing purpose, as well as to take the measures provided by law to protect their rights.
5.6. Upon achieving the purposes of personal data processing, as well as in the event of the withdrawal of Consent by the personal data subject, personal data shall be destroyed if:
the Administrator has no right to process personal data without the Consent of the personal data subject;otherwise not provided by the contract, which the personal data subject is a party, beneficiary, or guarantor;otherwise not provided by another agreement between the Administrator and the personal data subject.CONDITIONS OF USE OF THE SITE6.1. By using the Site, the User confirms that:
they have all the necessary rights allowing them to register (create an account) and use the Site's Services;they provide accurate information about themselves to the extent necessary for the use of the Site's Services, mandatory fields for the subsequent provision of the Site's Services are marked in a special way, all other information is provided by the User at their discretion;they understand that the information on the Site, posted by the User about themselves, may become available to third parties not specified in this Policy and may be copied and distributed by them;they are familiar with this Policy, agree with it, and assume the rights and obligations specified therein. Familiarization with the terms of this Policy and ticking the checkbox under the link to this Policy is the User's written consent to the collection, storage, processing, and transfer of personal data provided by the User to third parties.6.2. The Company does not verify the accuracy of the information received (collected) about Users, except in cases where such verification is necessary to fulfill obligations to the User.
FINAL PROVISIONS7.1. All relations related to the processing of personal data that are not reflected in this Policy are regulated in accordance with the provisions of the legislation of Ukraine.
7.2. The Administrator has the right to change this Policy. When changes are made, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment it is posted on the Site unless otherwise provided by the new version of the Policy. The current version is always available on the Site at the address https://v-tylu.com/privacy-policy.
FEEDBACK8.1. Questions and suggestions regarding the posted Policy on the processing and protection of personal data should be sent in writing to the postal address: 207 Horodotska Street, office 400, Lviv, Ukraine, 79000, recipient - the "In the Rear" platform, or by email to .moc.liamg%40ulytv.yrotnem