1. General concepts

1.1. The policy of ELTIVO LIMITED regarding the processing of personal data (hereinafter referred to as the Policy) was developed in accordance with regulations and rules of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR).

1.2. This Policy defines the procedure for processing personal data of users of the site https://easycourses.shop/ (hereinafter referred to as the Site), the conditions and principles for processing personal data, the rights of Users and obligations of “ELTIVO LIMITED“, information on the measures taken to protect the processed personal data.

1.3. This Policy applies to all personal data that “ELTIVO LIMITED” receives from users of the Site (hereinafter – Users, User).

1.4. In case of disagreement with the terms of the Policy, the User must immediately stop any use of the Site.

2. Terms and definitions

2.1. The following terms are used in the Policy:

Site – an Internet site located at https://easycourses.shop/;

Personal data (hereinafter – PD) – any information relating directly or indirectly to a specific or identifiable natural person (PD subject);

PD blocking – temporary suspension of PD processing (except when processing is necessary to clarify PD);

Depersonalization of PD – actions as a result of which it is impossible to determine, without the use of additional information, whether PD belongs to a specific PD subject;

PD processing – 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, changing), extraction, use , transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of PD;

Operator – ELTIVO LIMITED independently organizes and carries out the processing of PD, and also determines the purposes of processing the PD, the composition of the PD to be processed, the actions (operations) performed with the PD;

Personal account – a set of secure pages of the Site created as a result of registration of the User and available when entering his authentication data (e-mail address and password) in the fields provided for this on the Site;

Provision of PD – actions aimed at disclosing PD to a certain person or a certain circle of persons;

Distribution of PD – actions aimed at disclosing PD to an indefinite number of persons (PD transfer) or familiarizing with personal data of an unlimited number of persons, including publication of PD in the media, posting in information and telecommunication networks or providing access to personal data to any or in any other way;

User – a visitor to the Site, a subject of PD;

ISPD – personal data information system;

Destruction of PD – actions as a result of which it is impossible to restore the content of PD in the ISPD, and (or) as a result of which the material media of PD are destroyed;

Cookies (cookies) – data that is automatically transmitted to “ELTIVO LIMITED” during the use of the Site using the software installed on the User’s device, including IP address, geographic location, information about the browser and type of operating system of the User’s device, technical characteristics equipment and software used by the User, date and time of access to the Sites.

By accepting the terms of the Policy, you agree to the use of cookies;

3. Legal grounds and purposes of the processing of personal data

3.1. The legal grounds for processing PD “ELTIVO LIMITED” are:

● Civil Code of the European Union;

● GDPR of 27 April 2016;

● Other applicable regulatory legal acts of the European Union (hereinafter referred to as EU);

● Local legal acts “ELTIVO LIMITED”;

● Consent of the User to the processing of personal data.

3.2. “ELTIVO LIMITED” processes the User’s PD exclusively for the following purposes:

3.2.1. Registration and identification of the User on the Site, providing the User with the opportunity to fully use the Site.

3.2.2. Displaying the User’s profile for other Users of the Site;

3.2.3. Establishing and maintaining communication between the User and “ELTIVO LIMITED”, consulting on the provision of “ELTIVO LIMITED” services;

3.2.4. Conclusion of agreements and fulfillment of “ELTIVO LIMITED” obligations to the User under them (in particular, the User Agreement  and other agreements). Fulfillment of obligations, in particular, includes informing about the date and time of classes, sending certificates, etc.;

3.2.5. Direction “ELTIVO LIMITED” To the User of advertising messages, newsletters about products, services of “ELTIVO LIMITED” and its partners, about special offers, promotions, sweepstakes, competitions, surveys to the User’s email address, by the User’s phone number (User’s name) in instant messengers “WhatsApp”, “Viber”, “Telegram”, by mail, SMS messages, push notifications;

3.2.6. Posting on the Site, in official groups of social networks, other advertising and

information sources, for purposes not related to identifying the User: − Video materials received during the provision of services, − Reviews left by the User about the services provided by “ELTIVO LIMITED”.

3.2.7. Improving the quality of service for the User and modernizing the Site by processing requests and applications from the User, as well as for the purpose of recording telephone conversations with “ELTIVO LIMITED”, to improve the quality of service, to preserve evidence in case of disputes between “ELTIVO LIMITED” and the User;

3.2.8. Statistical and other studies based on anonymized information provided by the User;

3.3 The specific volume of personal data processed for the above purposes is defined in section 5 of the Policy.

4. Conditions and procedure for providing consent to the processing of personal data in “ELTIVO LIMITED”

“ELTIVO LIMITED” does not check the PD provided by the User. In this regard, “ELTIVO LIMITED” assumes that when providing PD on the Site, the User:

4.1.1. Is a capable person. In the event of incapacity of the person using the Sites, consent to the processing of personal data is provided by the legal representative of the User, who has read and accepted the conditions for processing personal data specified in this Policy.

4.1.2. Indicates reliable information about himself or about the represented incapacitated person (clause 4.1.1) to the extent necessary to use the Site. The user independently keeps the provided personal data up to date. The consequences of the User providing false or insufficient information are defined in the User Agreement.

4.1.3. Understands that information on the Site posted by the User about himself may become available to other Users of the Site and may be copied and distributed by such Users in cases provided for in the Policy.

4.2. The user accepts the terms of the Policy and gives “ELTIVO LIMITED” informed and conscious consent to the processing of his personal data under the conditions provided for by the Policy and the Law:

4.2.1. When registering and identifying on the Site – for personal data that the User provides “EASY COURSES”: by filling out the registration form located on the Internet at the addresses https://easycourses.shop/student-registration/ and  https://easycourses.shop/instructor-registration/. The user is considered to have given consent to the processing of his personal data at the moment he clicks the “Register” button.

4.2.2. When entering or changing PD in the “Settings” section of your Personal Account – when editing or adding information in the “Settings” section. At the User’s request, the following information may be indicated in the Personal Account: gender; image (photo uploaded through the Sites or a link from a social network / other electronic service); links to profiles on social networks. The specified PD can be used to fulfill the “ELTIVO LIMITED” obligations stipulated by the User Agreement and the terms of use of the Site’s services. The user is considered to have given consent to the processing of his newly entered or changed personal data at the time of completion of their editing. After filling out any of the fields specified in the “Settings” section, the PD is updated automatically.

4.2.3. When filling out the feedback form, including applications for courses, professions, applications for using other services of the Site – for personal data that the User provides “ELTIVO LIMITED” when filling out the feedback form on the Internet on the Site and electronic services. The user is considered to have given consent to the processing of his personal data entered in the fields of the feedback form at the moment he clicks the button confirming the submission of the application.

4.2.4. When subscribing to receive information, advertising and news materials from “EASY COURSES” – by filling out the newsletter subscription form located on the Internet at https://easycourses.shop /frequently-asked-questions/. The user is considered to have given consent to the processing of his personal data when clicking on the “Subscribe Now” button

4.2.5. For any use of the Site – for personal data that is automatically transferred to “ELTIVO LIMITED” during the use of the Site using the software installed on the User’s device. The user is considered to have given consent to the processing of his personal data at the time of starting to use the Site.

4.3. By performing the actions specified in clause 4.2 of this Policy, the User gives “ELTIVO LIMITED” consent to the processing of the relevant PD, the list of which is specified in section 5 of this Policy, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision to third parties, access), depersonalization, blocking, deletion, destruction of PD with or without the use of automation tools in accordance with the purposes specified in Section 3 of this Policy.

4.4. The consent to PD processing provided by the User in accordance with this Policy is valid from the date of provision of such consent and for the period necessary to achieve the purposes of PD processing or until the User withdraws this consent, unless otherwise provided by the current legislation of the European Union. The consent to the processing of personal data provided by the User in accordance with this Policy may be withdrawn by the User at any time. The user may revoke the previously provided “ELTIVO LIMITED” consent to the processing of personal data in one of the following ways:

● By sending the corresponding application by mail to the address: 1 Apriliou, 52 Athienou, 7600, Larnaca, Cyprus;

● By sending a corresponding application in the form of an electronic document to

email address: support@easycourses.shop.

5. Personal data processed in “ELTIVO LIMITED”

5.1. Processing of User PD is carried out under the following conditions:

6. Processing of personal data

6.1. “ELTIVO LIMITED” processes personal data based on the following principles:

● Legality and fairness;

● Limiting the processing of personal data to the achievement of specific, predetermined and legitimate purposes;

● Preventing the processing of personal data incompatible with the purposes of collecting personal data;

● Preventing the merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;

● Processing only those personal data that meet the purposes of their processing;

● Compliance of the content and volume of processed PD with the stated purposes of processing;

● Preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;

● Ensuring the accuracy, sufficiency and relevance of PD in relation to the purposes of PD processing;

● Destruction or depersonalization of PD upon achievement of the purposes of their processing or in the event of loss of the need to achieve these goals, receipt from Users of a request for the destruction of PD, receipt from the User of withdrawal of consent to the processing of PD.

6.2. “ELTIVO LIMITED” processes Users’ personal data (recording, systematization, accumulation, storage, clarification (updating, changing), retrieving) using databases on the territory of the European Union.

6.3. Processing of Users’ PD is carried out in “ELTIVO LIMITED” both with and without the use of automated means.

6.4. “ELTIVO LIMITED” and other persons who have access to personal data are obliged not to disclose to third parties or distribute PD without the consent of the PD subject, unless otherwise provided by federal law.

6.5. Processing of the User’s PD includes the following actions: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision to third parties, access), depersonalization, blocking, deletion, destruction.

6.6. Users’ personal data is stored on electronic media. When processing PD in order to fulfill obligations under agreements with the User, “ELTIVO LIMITED” can extract PD and store them on tangible media. The storage of such PD is carried out for the period established by the legislation of the European Union on education and archiving. PD is stored (depending on which event occurs first):

● Until they are deleted by the User in the “My Profile” and “Settings” sections in the personal account on the Site:

● Until their destruction “ELTIVO LIMITED” – in the event that the User receives a withdrawal of consent to the processing of PD or a request for the destruction of PD;

● Until the consent expires (clause 4.4 of the Policy).

6.7. “ELTIVO LIMITED” has the right to transfer PD in accordance with the requirements of the legislation of the European Union or the consent of the subject of PD processing to third parties, namely:

6.7.1. Partners, such as site and application owners, advertising networks and other partners who provide ELTIVO LIMITED services related to the placement and display of advertising on sites, programs, products or services owned or controlled by such partners;

6.7.2. Partners engaged by “EASY COURSES” to provide services to Users on the “EASY COURSES” platform at https://easycourses.shop/;

6.7.3. Partners to provide Users with specialized offers on concluding civil contracts;

6.8. The transfer of personal data to third parties specified in clause 6.7 of the Policy is subject to the following conditions:

● A third party processes personal data using databases on the territory of the European Union;

● The third party ensures the confidentiality of personal data during their processing and use, undertakes not to disclose to other persons, and also not to distribute the 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: the use of information security tools, detection and recording of facts of unauthorized access to personal data and taking measures to restore personal data, restricting access to personal data, registration and recording of actions with personal data, monitoring and assessing the effectiveness of measures taken to ensure PD security;

● List of permitted methods for processing personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction;

● A third party is prohibited from transferring and distributing PD.

7. Measures taken by ELTIVO LIMITED to protect personal data

7.1. “ELTIVO LIMITED” takes necessary and sufficient legal, organizational and technical measures to protect information provided by Users from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties with it. Such actions include, but are not limited to:

● Application of organizational and technical measures to ensure the security of personal data during their processing in information systems;

● Monitoring instances of unauthorized access to personal data and taking measures to prevent similar incidents in the future;

● Monitoring the measures taken to ensure the security of personal data and the level of security of personal data information systems.

8. User Rights

8.1. The user decides to provide his personal data and consents to their processing freely, of his own free will and in his own interest. The user expresses his consent to the processing of personal data in the manner described in clause 4.2 of this Policy.

8.2. The user has the right to receive from ELTIVO LIMITED information regarding the processing of his personal data.

8.3. The user has the right to send “ELTIVO LIMITED” his requests and demands (hereinafter referred to as the Appeal), including regarding the use of his personal data, as well as the withdrawal of consent to the processing of personal data. The appeal can be sent in the following ways:

8.3.1. In writing to the address “ELTIVO LIMITED” (clause 4.4 of the Policy);

8.3.2. In the form of an electronic document (scan, photocopy of the document). The document must be sent from the User’s email address specified when registering on the Site to the “EASY COURSES” email address: support@easycourses.shop.

9. Updating, correction, deletion and destruction of personal data

9.1. “ELTIVO LIMITED” undertakes to inform the User or his representative in the manner prescribed in article 20 of the GDPR, information about the availability of PD related to this User, as well as provide the opportunity to review these PD when contacted by the User or his representative within 10 (ten) days from the date of receipt of the request of the User or his representative. This period may be extended, but not more than by 5 (five) working days, after a reasoned notice is sent to the User indicating the reasons for the extension.

9.2. “ELTIVO LIMITED” undertakes to provide, free of charge, the User or his representative with the opportunity to familiarize himself with the PD relating to this User.

9.3. Within a period not exceeding 7 (seven) working days from the date the User or his representative provides information confirming that the PD is incomplete, inaccurate or irrelevant, “ELTIVO LIMITED” undertakes to make the necessary changes to them.

9.4. Within a period not exceeding 7 (seven) business days from the date the User or his representative provides information confirming that such PD is illegally obtained or is not necessary for the stated purpose of processing, “ELTIVO LIMITED” undertakes to destroy such PD. “ELTIVO LIMITED” also undertakes to notify the User or his representative about the changes made and measures taken and to take reasonable measures to notify third parties to whom the PD of this User has been transferred.

9.5. If it is confirmed that the PD is inaccurate, “ELTIVO LIMITED”, based on the information provided by the User or his representative or the authorized body for the protection of the rights of PD subjects, or other necessary documents, undertakes to clarify the PD or ensure their clarification (if the processing of PD is carried out by another person acting on behalf of “ELTIVO LIMITED”) within 7 (seven) working days from the date of submission of such information and remove the blocking of PD.

9.6. “ELTIVO LIMITED” undertakes to stop processing PD or ensure that the processing of PD is stopped by a person acting on behalf of “ELTIVO LIMITED”:

● In case of detection of unlawful processing of personal data carried out by OOO or a person acting on behalf of “ELTIVO LIMITED”, within a period not exceeding 3 (three) working days from the date of this detection;

● If the User withdraws consent to the processing of his personal data;

● If the purpose of processing personal data is achieved.

9.7. “ELTIVO LIMITED” undertakes to destroy the User’s PD or ensure its destruction (if PD processing is carried out by another person acting on behalf of “ELTIVO LIMITED”) within a period not exceeding 30 (thirty) days from the date the purpose of PD processing is achieved.

9.8. If it is not possible to destroy PD within the period specified in clause 9.7 of the Policy, “ELTIVO LIMITED” blocks such PD or ensures their blocking (if the processing of PD is carried out by another person acting on behalf of “ELTIVO LIMITED”) and ensures the destruction of PD within a period not more than 6 (six) months, unless another period is established by federal laws.

10. Policy change

10.1. ELTIVO LIMITED reserves the right to make changes to the Policy. The User is obliged to familiarize himself with the text of the Policy each time he uses the Site.

10.2. The new version of the Policy comes into force from the moment it is posted in the appropriate section of the Site “ELTIVO LIMITED”. Continued use of the Site or its services after the publication of a 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 Site and its services.

10.3. Please direct all questions regarding this Policy to the email address “EASY COURSES” support@easycourses.shop.