I, private entrepreneur Liubchuk Alona, Unified State Register Сode 3222913761 (hereinafter — the “Company”), am the owner of an educational platform that provides thematic courses, trainings, seminars, conferences, master classes, lectures, consultations in online format, as well as other remote activities or their recordings (hereinafter referred to as "Services"). The Company recognizes the importance of your privacy and takes the protection of your rights seriously. This Privacy Policy governs your use of the Company's website available at https: https://vsquad.school/ (the "Website") and explains how the Company collects and processes personal data received both from users of the Website and from and from users of the Services (hereinafter referred to as "Clients").  
Statement on the processing and protection of personal data
The company strives to ensure the protection of personal data that it receives and processes. When processing personal data, the Company undertakes to take all necessary technical and organizational measures in accordance with the requirements of data protection legislation and in accordance with the best global practices. This Policy applies to persons whose personal data is processed or may be processed in the future by the Company as a data owner. This includes, but is not limited to, individuals who use the Company's Website, submit registration forms to the Company, contact the Company with inquiries, order the Company's Services, or attend the Company's online events that involve the collection of personal data. If the Company controls the methods of collecting personal data and determines the purposes of their use, it acts as the owner of personal data in accordance with the Law of Ukraine "On the Protection of Personal Data" dated June 1, 2010 (hereinafter - the "Law"). By using the Company's Website or the Company's Services, or by providing separate consent to the processing of your data, you agree to this Policy. If you do not agree to the processing of your personal data in accordance with this Policy, please do not provide the Company with your data. In accordance with applicable law and this Policy, you have the right to request the deletion of your personal data. Please note that the Company Policy may be updated from time to time, including when required by applicable law. We recommend that you periodically review this Policy to be aware of changes. Your continued use of the Website or receipt of Company Services following any changes to the Policy will constitute your acceptance of such changes. 
1. What the Company collects and how it receives personal data
The Company collects and processes only the information about you that is necessary to fulfill the purposes specified in this Policy, including to respond to your inquiries, to allow you to use the Website and to provide the Company's Services. By signing up for the Company's newsletter or marketing, you consent to the collection of your first and last name and contact information. In addition, the Company may process other personal data if you voluntarily provide it to us Personal data that the Company may collect and process to provide you with Services: • Name and surname (sometimes also patronymic);• Contact data, including email address, phone number, postal address;• Date of birth;• Photos and videos with your participation;• Recordings of conversations during communication;• Data collected from a feedback form or survey.
You provide this data primarily when registering for the Company's educational events, participating in them, and communicating with the Company's support team. The Company also conducts customer satisfaction surveys with our Services. These surveys can be conducted through various communication channels (email, calls, Discord messages). The Company usually records communications with you and your responses to survey questions. With your permission, the Company may publish your feedback on the Website and/or in marketing materials. 
1.2. Information the Company may obtain when you use the Website
The Company may collect the following information about you when you use the Website: • Information about your device, including model, operating system version, and mobile network• Internet protocol address (IP address);• Version and settings of your browser;• Account details such as username and password (for authentication and access);• Information about how you use our Website (using cookies and similar technologies).
The Company may use cookies and similar technologies to manage the Website, provide you with functionality and personalized messages. Please refer to our Cookie Policy to learn more about cookies and to use the Company's cookie settings tool. 
1.3. Information that the Company receives from your request or completed registration form
When you fill out a registration or contact form, for example to receive information about the Company's Services, the Company asks for your full name, email address and telephone number. These contact details are necessary for the Company to provide the response and information you request. The Company may contact you through various communication channels such as email, phone calls, Discord messages, social media, etc. After the Company starts communicating with you, it may receive and store additional information about you, including personal data. In particular, the Company may record and store our communications with you (recorded telephone conversations or email correspondence). 
1.4. Processing of information received from third parties
The Company may collect your personal data from third parties from time to time, mainly when your employer orders and pays for our educational Services on your behalf. In addition, the Company may collect certain information about you when you register or if you provide your social network account information (such as Facebook, LinkedIn, Twitter, etc.) in your account on the Company's Website or when you use the Company's Services. The Company may also collect certain information about potential customers from third parties in order to assess market demand for the Company's services and to adjust its marketing strategy. The information collected is de-identified (eg, age, industry, country groups, etc.) and is not considered personal data. 1.5 Processing of special categories of data
The company does not collect or process any personal data that pose a particular risk to the rights and freedoms of data subjects. Such data include: • Information about racial or ethnic origin.• Political, religious or ideological beliefs.• Membership in political parties and trade unions.• Conviction to criminal punishment.• Data on health, sex life.• Biometric or genetic data.
1. Purposes and legal basis of data processingThe company processes your personal data exclusively in accordance with current legislation. Personal data may be processed for the following purposes on the following legal grounds: • Registration and access to Services: To register a user on the Website, create a personal account and provide access to the Company's Services, including educational activities (conclusion and/or execution of a contract). • Offering Services: To offer Services that you request or may be of interest to you in the future (conclusion of a contract, legitimate interest). • Website Maintenance: To maintain the Company's Website, including the educational platform (performance of contract, legitimate interest). • Customer information: To notify you of changes and important information related to the Services(contract performance, legitimate interest). • Fulfillment of obligations: To fulfill obligations during the provision of Services in accordance withthe terms of the Public Offer (fulfilment of the contract, in some cases legitimate interest). • Development and improvement: To carry out internal research, development, testing and improvement of the features and functions of the Services (legitimate interest). • Communication: To establish and maintain contact with users/customers, including advice and technical support (contract performance). • Processing of requests and complaints: To process (consider) requests or complaints of users/customers (consent, legitimate interest). • Improving the quality of Services: To improve the quality of Services for customers and users of the Website (legitimate interest, in some cases consent).• Internal and external audit: To comply with internal and external audit requirements, including information security (contract performance, legitimate interest).• Security: To protect against malicious actions, detection and investigation of crimes, and other security considerations (legitimate interest, compliance with legal requirements). • Analytics: For analytical and statistical purposes (legitimate interest).• Collecting feedback: To receive your feedback or participate in surveys (legitimate interest, consent). • Marketing: For marketing purposes (consent).• Personalization: To personalize the user experience of the Website using cookies and similar technologies (consent, in some cases legitimate interest). • Cooperation with regulatory bodies: To respond to the requests of regulatory and law enforcement agencies (compliance with legal requirements). • Other legitimate interests: To ensure other legitimate interests of the Company, for example, preparing claims or responding to claims (legitimate interest). Where the Company relies on legitimate interests as a legal basis for processing your personal data, it ensures that those interests are balanced against your rights and freedoms in accordance with applicable law and industry practices. 
2. Marketing advantages
The Company may send you marketing information through various channels, including email, telephone, text messages (including through Discord) and online (while using the Website). The Company respects your marketing preferences and complies with applicable data protection legislation. Marketing materials are only sent with your express consent or based on a legitimate interest within the scope of direct marketing. The company must not send information that is against your interests. For example, we may advertise Services that we believe may be of interest to you based on your past activity. You have the right to opt out of receiving marketing communications, even if you have previously given your consent. To unsubscribe from marketing, you can use the "unsubscribe" link included in every marketing email or contact our Head of Data Protection at tra.dauqsv%40loohcs. Regardless of whether you have opted out of receiving marketing communications, the Company may send you business or service communications, as well as important transactional information related to the Services you have requested or purchased. This is necessary for the performance of the contract between us. 
3. Security
The company takes complex physical, administrative and technical measures to protect personal data in accordance with the current legislation of Ukraine. These measures are regularly reviewed and updated to ensure their effectiveness.First, the Company uses server and network equipment in one of the largest European licensed data centers, which guarantees high security, smooth operation and protection against unauthorized interference.  The company adheres to the principle of data minimization, providing access to personal data to its employees only on the basis of business necessity — that is, only to those who need access to perform their duties. Our employees receive regular training on the processing and protection of personal data, as well as data security practices. When transferring personal data outside the Company, we use encryption. 
4. Place of storage and term of storage of personal data
We take all necessary security measures to protect your personal data from unauthorized access, loss, disclosure or alteration. Your data processed by us is stored or used in secure information technology systems owned or operated by the Company, as well as in a large data center in Europe.  We retain personal data only for the period necessary to achieve the purposes for which it was collected, in particular to fulfill the requirements of law, accounting or tax reporting, as well as to ensure the performance of transactions concluded with customers for the provision of services. When determining the retention period of personal data, we take into account the purposes of processing, the nature and categories of data, the potential risk of harm from unauthorized use or disclosure, as well as the relevant legal requirements. As a general rule, the Company retains basic information about customers for three (3) years after they cease to be customers (for tax and legal purposes).  If the law of the customer's country of residence specifies statutes of limitations that require the storage of evidence of the legal relationship, we may process your data during this period. Over time, we may minimize the amount of data or anonymize it (for research or statistical purposes) so that it can no longer be associated with you. Anonymized data can be stored indefinitely because it is no longer personal.If the Company processes personal data in accordance with your consent to the processing (in particular for marketing purposes), you have the right to withdraw your consent at any time or to request the deletion of the data or the temporary suspension of the data processing. To do this, contact the Company, in particular, by sending an email to (hidden) 
5. Disclosure and transfer of personal data
We may transfer personal data to third parties or provide them with remote access to this data in the following cases: • Third Party Consultants and Service Providers: We may share your personal data with third partyservice providers and consultants who work on our behalf and need access to your data to perform their duties, such as website maintenance, billing, accounting and legal support, CRM system management, etc. These service providers have the right to use your data only to the extent necessary to provide the services.• State, local, and regulatory authorities: We may disclose your personal information to state, local, or other regulatory, administrative, or law enforcement authorities, as well as judicial authorities, if (1) disclosure is reasonably necessary to comply with legal requirements or to participate in legal proceedings; (2) we have received a relevant court order, administrative action, or government request (such as a search warrant, subpoena, court order, etc.), (3) it is necessary to protect the security or integrity of the website, or (4) to protect our company and our customers from harm or illegal activity.• Other Circumstances: We may disclose your information (1) in emergency situations where disclosure is necessary to prevent serious personal injury or death, or (2) when you have requested that we share your information with a specific third party. We may transfer your personal data to third countries or territories whose privacy laws may differ from those of your country of residence. Some data recipients may be located in Ukraine, while others may be located in the countries of the European Economic Area. Transfer of data outside Ukraine is carried out only if necessary and in accordance with the purposes specified in this Policy, in compliance with the relevant requirements for the protection of your rights and freedoms. We ensure compliance with the requirements of Art. 29 of the Law of Ukraine on the Protection of Personal Data and we will require all data recipients to ensure an adequate level of protection. You should know that the Company does not sell your data to third parties. In the event of a merger, reorganization, or sale of a company or part of its assets, collected information, including personal data, may be transferred to another company (in the event of a merger or acquisition). All such data transfers will be made in accordance with the laws and obligations set out in this Policy. 
6. Rights of data subjects
We guarantee you the exercise of your rights to the protection of your personal data in accordance with current legislation, in particular Art. 8 "Rights of the subject of personal data" of the Law of Ukraine on the protection of personal data.  As a subject of personal data, you have the following rights: 1. Know the sources and purpose of processing: You have the right to know about the sources of collection of your personal data, their location, the purpose of processing, as well as the location or place of residence of the owner or manager of the data. You can also instruct authorized persons to receive this information if required by law.2. Receive information about access: You have the right to receive information about the conditions for providing access to your personal data, in particular, about third parties to whom this data is transferred.3. Access to data: You have the right to access your personal data.4. Receive confirmation of processing: You have the right to receive an answer about whether your personal data is being processed, as well as the content of this data within thirty calendar days from the date of receipt of the request (except for cases provided by law).5. Objection against processing: You have the right to submit a reasoned claim against the processing of your personal data.6. Change or destruction of data: You can submit a reasoned request for the change or destruction of your personal data if these data are processed illegally or are unreliable.7. Protection against illegal processing: You have the right to protection of personal data against illegal processing, accidental loss, destruction, damage, as well as protection against inaccurate information that may affect your honor, dignity or business reputation, which is regulated by Article 8 of the Law of Ukraine " On the protection of personal data".8. Legal remedies: You have the right to apply legal remedies in case of violation of the legislation on the protection of personal data, according to Article 22 of the Law of Ukraine "On the Protection of Personal Data"9. Withdrawal of consent: You have the right to withdraw your consent to the processing of your personal data at any time.10. Mechanism of automatic processing: You have the right to know about the mechanism of automatic processing of your personal data.11. Protection against automated decisions: You have the right to protection against automated decisions that may have legal consequences for you.Please note that in order to process your request, you need to go through an identification process and provide specific requirements. This is necessary so that we can provide a response on legal grounds and avoid disclosing data to the wrong people. The Company may ask you to provide proof of identity. Only in this way can the Company avoid disclosing your data to a person who can impersonate you, that is, the identification process is carried out in your interests. Any additional information collected for verification purposes will only be used to verify identity.  We process requests as quickly as possible, but the process may take up to a month or more.If we need more time to prepare a response, we will let you know. According to Art. 15 "Removal or destruction of personal data" of the Law of Ukraine on the protection of personal data, personal data is subject to deletion or destruction in the following cases: • Expiration of the data storage period determined by consent to processing or by law.• Termination of the legal relationship between you and the owner or controller of the data, unless otherwise provided by law.Entry into legal force of a court decision to delete or destroy personal data. 
7. Our contacts
If you have any questions regarding the processing of your personal data, comments on this Policy or wish to exercise your right in accordance with Article 8 of the Law of Ukraine "On the Protection of Personal Data", please send your request to the email address tra.dauqsv%40loohcs