Privacy Policy

Version dated 22 January 2026

This Privacy Policy (hereinafter — the Policy) sets out in detail how Users’ personal data is collected, processed, used and stored. It applies exclusively to information or data collected automatically on the Website learnwithkateryna.ae (hereinafter — the Website) or provided by users voluntarily while using the Website.

The Website is managed by Individual Entrepreneur Ivanova Kateryna Viacheslavivna (hereinafter — the Administration), who is recognised as the controller and holder of personal data.

Before using the Website, we ask users to review the Policy to understand the principles and methods of processing the User’s data. If any provisions of the Policy are unclear to you, write to our email svirkate22@gmail.com.

1. Definitions

1.1. The Policy uses the following terms with the meanings below:

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

1.1.2. Personal data — information that directly or indirectly relates to a specific individual as a personal data subject.

1.1.3. Service/Course — a set of information and consulting services and services granting access to digital content, provided to the Consumer under the Public Offer Agreement, which may include elements defined on the Website.

1.1.4. Cookies — a small piece of data that the Website stores on the User’s device (computer, phone, tablet, etc.) while visiting the Website.

2. General provisions

2.1. The Policy establishes the purpose, grounds and procedure for processing personal data and cookies, the composition of personal data, the procedure for using third-party services, and for sending mailings.

2.2. The Policy applies to personal data received by the Administration from users while visiting the Website and completing the feedback form.

2.3. The User has the right to know how and for what purpose their personal data is collected, where and for how long it is stored, who processes it, to whom it is transferred and on what terms.

2.4. The Administration undertakes not to disclose and to ensure the confidentiality of personal data that the user provides when completing feedback forms and/or through means of communication with the Administration.

3. Scope of subjects

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

3.2. If a person lacks a sufficient level of legal capacity, the Administration will treat the consent given to process such a person’s personal data as given by their parents, guardians (custodians) or adoptive parents.

4. Sources and methods of obtaining personal data

4.1. Sources from which personal data is obtained:

• registration forms — by the User completing feedback forms on the Website or with a manager;
• email — by receiving/sending emails when interacting with the Administration or a manager;
• interaction with advertising — interaction with advertisements about the Administration’s services on third-party sites;
• data from other sources: social networks; search engines (for example, Facebook, Telegram, Google); marketing research; third-party data aggregators; public and other sources from which the Administration or a manager obtained access to personal data.

5. Collection and processing of personal data

5.1. The Website Administration collects exclusively the personal data voluntarily provided by the user for using the Website and communicating with the Administration.

5.2. When using the Website and receiving services, the user’s personal data is processed, which may include, but is not limited to:

• surname, first name, patronymic;
• email address;
• contact phone number;
• date of birth.

5.3. The Administration makes efforts to protect personal data that may be transmitted automatically while visiting the Website, including but not limited to: IP address, information from cookies, browser information (or other program accessing the Website), access time, addresses of visited pages, etc.

5.4. During the user’s contact with the Administration (in particular, via the feedback form, email), recordings and logging of communications may be made in order to improve the quality of the services.

5.5. The Administration has the right to publish on the Website the user’s reviews of the services it provides and which the user consumes under the public offer.

5.6. The User is directly responsible for the accuracy of the personal data voluntarily provided to the Administration and for all related consequences.

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

6. Purpose of using personal data

6.1. To properly provide services, the Administration collects and uses the user’s personal data, in particular:

• phone number — to make calls to communicate with the Administration or a manager;
• email — to grant the user access and enable communication on the Website supporting audio and video; to provide effective technical support; to grant access to materials provided within the services;
• surname, first name, patronymic — to store data in databases, including in Google services, for quality control of the services provided; to send the User mailings and other information; to conduct statistical and other research based on anonymised user data.

6.2. The User’s personal data may be used only to the extent necessary for the Administration to properly perform its obligations under the Public Offer, even if such purposes are not expressly provided for in the Policy.

7. Third-party services

7.1. To maintain the proper functioning of the Website, communicate with users and process payments, the Administration may use third-party services, including but not limited to:

• Google services for analytics and advertising;
• services for communication (in particular, messengers, email, WhatsApp, Telegram);
• databases, cloud services for data storage;
• the Stripe electronic payment service;
• services for automating work with users.

7.2. When using such services, the User’s personal data is processed in accordance with their privacy policies, consent to which the User gives independently and at their own discretion.

7.3. The Website Administration does not directly transfer Users’ personal data to these services; however, information entered by the user or stored through the said services may be processed according to their terms, of which the user is fully informed.

8. Consent to personal data processing

8.1. By using the Website to receive a service and answering the mandatory questions, the user confirms giving the Administration consent to process personal data and confirms that they are fully legally capable.

8.2. Consent to process personal data is given by:

• completing the feedback form and ticking the mark confirming familiarity with the Policy;
• communicating with the Administration by email correspondence during the provision of services.

8.3. The User agrees to the processing of personal data, in particular collection, recording, storage, updating or modification, anonymisation, use, distribution, granting of access, blocking, deletion or destruction of personal data, for the purpose of building a database of Users, compiling statistical reporting, conducting marketing research and interacting with the User, including sending SMS messages and emails, until such consent is withdrawn or cancelled.

8.4. The User agrees that the Administration may interact with them through direct contact via means of communication (including but not limited to): email, messengers.

8.5. The User is solely responsible for the use of third parties’ personal data that they receive, publish or provide to others using the Website, and confirms that they have the third party’s consent to provide such data to the Administration.

8.6. The user’s consent to process personal data specified in this section may be withdrawn by the user at any time by sending an email to the Administration at the address indicated on the Website.

9. Storage of personal data

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

9.2. Collected personal data is accumulated by entering it into a corresponding database stored electronically on the server hosting the Website.

9.3. The User’s personal data is stored for as long as necessary to achieve the purpose of the Policy, for the period of providing services under the Public Offer Agreement, or until deleted at the User’s request, but no longer than 3 (three) years.

10. Personal data processing

10.1. The Website Administration processes personal data by automated processing and/or personally, and/or by involving third parties.

10.2. The User is informed that third parties provide services or perform duties on behalf of the Website Administration, including technical support for users, servicing them, marketing and conducting surveys.

10.3. Using an automated system, the Administration keeps records of operations related to processing the User’s personal data.

10.4. The User has the right to verify the correctness of the processing of their personal data and to learn how the automated processing of their data works.

11. Protection of personal data

11.1. The Administration takes all necessary technical and organisational measures to protect the User’s personal data from unlawful or accidental access by third parties, destruction, blocking, distribution, copying, etc.

11.2. In the event of a leak or unlawful distribution of personal data caused by third parties, the Administration immediately, from the moment the leak and/or unlawful distribution is discovered, notifies the User by sending a message to the email address they provided or by any other available means of communication.

12. Distribution of personal data

12.1. The User is aware that the Administration may be compelled to distribute the user’s personal data at the lawful request of state authorities where there are legal grounds.

12.2. The Administration has the right to amend this Policy and to indicate its right to distribute the personal data provided for by it to third parties.

12.3. The Administration notifies Users of changes regarding the distribution of their personal data by sending a message to the User’s email. The User agrees to the updated version of the Privacy Policy by tacit consent.

12.4. If the User does not agree with the updated version of the Policy, the User is obliged to withdraw consent in the manner and order provided for by the Policy.

12.5. Cross-border transfer of personal data occurs if such transfer:

• is necessary on important grounds of public interest;
• is necessary for the establishment, exercise or defence of legal claims;
• is necessary to protect the vital interests of the user or other persons, if the user is physically or legally incapable of giving consent.

13. Changing personal data

13.1. The User has the right to demand that their personal data be changed.

13.2. The basis for making changes to personal data is a written application from the user, sent from the email address the User indicated in the feedback form on the Website, to the Administration’s email specified in the details.

13.3. Changes are made to the personal data database without delay from the moment a discrepancy is established in accordance with the stated requirements.

14. Destruction of personal data

14.1. The User has the right to demand the cessation of processing of their personal data, the deletion of data and the restriction of its processing.

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

14.3. Grounds for deletion and destruction of personal data:

• withdrawal of consent to process personal data, sent by the user as a written demand to the Administration’s email from the email address the User indicated in the feedback form on the Website or provided in any other way;
• expiry of the personal data processing period.

14.4. The Administration informs the User of the consequences of withdrawing consent.

14.5. Upon withdrawal and upon expiry of the storage period, the Administration deletes or destroys the user’s personal data without delay.

14.6. If personal data is deleted as a result of withdrawing consent to process personal data, the Administration has the right to stop providing the services under the Public Offer and not to refund the amount paid by the User for the services.

14.7. The Administration notifies the User of the change, deletion or destruction of personal data within 10 (ten) business days.

15. Mailings

15.1. The Administration may send electronic, text and/or multimedia messages to the email address, contact phone number, etc., with commercial and/or non-commercial offers from the Administration and/or third parties.

15.2. The purpose of the mailing is to grant access to materials and to inform the user about the Administration’s products, services and events. In addition, the mailing may contain anonymous surveys to collect feedback on the services.

15.3. The User confirms consent to receive mailings by giving consent to the processing of personal data in accordance with the Policy.

15.4. The User has the right to opt out of receiving mailings. To do so, the user must send an email declining the mailing to the Administration’s email.

16. Composition and processing of Cookies

16.1. The Website Administration collects Cookies to improve the operation of the Website and identify users, track Website visit statistics, and enable its optimisation and adaptation to each User’s interests.

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

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

16.3. Information created by Cookies is transmitted to and stored on a Google server in the United States of America. The IP address transmitted from the User’s browser will not be merged with other data held by Google.

16.4. The Website Administration may process:

• necessary Cookies that help make the Website usable by providing 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 Administration understand how Users interact with the Website by collecting and anonymously reporting information;
• marketing Cookies used to track Website Users in order to show ads that are relevant and appealing to the individual User.

16.5. 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 Administration’s email.

16.6. If the user refuses the processing of Cookies, they will not be able to fully use all functions of the Website.

17. Liability

17.1. The Website Administration is liable for losses incurred by the User in connection with the unlawful use of personal data, except in cases provided for by the Policy.

17.2. In the event of loss or disclosure of personal data, the Website Administration is not liable if such personal data:

• became or was public at the moment of loss or disclosure;
• was obtained from a third party before it was received by the Website Administration;
• was disclosed with the User’s consent.

17.3. The Website Administration is not 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 following links to third-party sites placed on the Website.

18. Dispute resolution

18.1. The User and the Administration resolve all disputes and disagreements arising from relations covered by this Policy through negotiations.

18.2. The User may send a written claim to the Administration’s email.

18.3. The Website Administration undertakes to consider the claim and send a reasoned written response to the same email address from which the claim was received, within 15 (fifteen) business days.

18.4. Disputes not settled by the Parties are subject to resolution in court. Claims are brought before the court at the location of the Administration.

19. Final provisions

19.1. The new Privacy Policy takes effect from the moment it is posted on the Website, unless otherwise provided by the new version of the Privacy Policy.

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

19.3. The provisions of the Policy apply exclusively to the Website.

19.4. The Website Administration reserves the right to amend the Policy in the event of changes to the method, procedure or purpose of collecting, processing, using or storing personal data.

19.5. The Policy is valid in the version in force at the moment of its adoption and publication on the Website.

20. Administration details

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