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  • - PRIVACY AND PERSONAL DATA PROTECTION POLICY

PRIVACY AND PERSONAL DATA PROTECTION POLICY

This Privacy and Personal Data Protection Policy (hereinafter - the Policy) was developed in accordance with the requirements of Directive 2002/58 / EC of the European Parliament and the Council as of July 12, 2002, concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications) and Regulation (EU) 2016/679 of the European Parliament and the Council of April 27 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and the repealing Directive 95/46 / EC (hereinafter - the Law).

This Policy establishes the procedure for ELVTR US LLC (hereinafter referred to as the Company) for processing personal data provided by customers who use the website https://uk.elvtr.com and its separate services to receive or provide services (hereinafter - Users and the WebSite, respectively ). The Policy defines the types of personal data to be collected, the purpose of using such personal data, the Company's interaction with third parties, security measures to protect personal data, conditions for accessing personal data, as well as contact information for the user regarding access, modification, blocking or removal of their personal data and dealing with any questions that may arise regarding the practice personal data protection.

The company treats the confidential (personal) data of all persons, without any exception, who visited the website https://uk.elvtr.com , as well as those who use the services provided by the WebSite. Therefore, the Company strives to protect the confidentiality of personal data (information or a set of information about a natural person who is identified or can be specifically identified), thereby creating and ensuring the most comfortable conditions for using the WebSite's services for each user.

The text of the Policy is available to Users on the Internet at https://uk.elvtr.com/privacy . In case of disagreement with the terms of the Policy, the User shall immediately stop any use of the WebSite.

1. Terminology and Abbreviations

The terminology used in this Policy means the following:

  • 1.1. Personal data means any information which relates directly or indirectly to a specific natural person (subject of personal data).
  • 1.2. Company is ELVTR US LLC, registered at the following address: 300 Spectrum Center Dr, Suite 400, Irvine, CA 92618.
  • 1.3. Processing of personal data – any action or set of actions performed with personal data with or without the use of automation devices, including collection, recording, systematization, accumulation, storage, validation (updating, alteration), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, removal, and destruction of personal data.
  • 1.4. Automated personal data processing means the processing of personal data using computer equipment and machines. However, automated personal data processing does not contain a system of automatic processing, including profiling, which creates legal consequences for the User, or which significantly affects the User.
  • 1.5. Distribution of personal data constitutes actions aimed at disclosing personal data to an indefinite number of persons.
  • 1.6. Provision of personal data means actions aimed at disclosing personal data to a certain person or a certain circle of persons.
  • 1.7. Blocking personal data means temporary interruption of personal data processing (except when processing is necessary to clarify certain personal data).
  • 1.8. Use of personal data constitutes actions (operations) that involve personal data and are carried out by the Company for the purpose of making decisions or performing actions that might translate into legal consequences in relation to the owner of personal data or other persons, or otherwise affecting the rights and freedoms of the subject of personal data or other persons.
  • 1.9. Depersonalization of personal data means actions, as a result of which it is impossible to identify without the use of additional information whether the personal data belong to a specific User or other subject of personal data.
  • 1.10. Destruction of personal data constitutes actions that result in making the existing private data, in the information system of personal data, unrecoverable and/or result in eliminating the private data carriers.
  • 1.11. The online program is an educational program that involves solely the use of distance learning technologies on the Company's Online Platform, available at: https://uk.elvtr.com .
  • 1.12. Online platform means the Company's software, which represents a set of interrelated web services and modules that make up a single space for providing services to consumers on the Internet.
  • 1.13. Free lesson means audiovisual content (webinar), access to which, as well as to all materials, is provided by the Company free of charge to all Users who have registered to participate in such a webinar. The Company conducts free lessons for all interested Users. Such free lessons do not constitute a part of the paid educational program.
  • 1.14. User Agreement is an agreement posted on the Internet at https://uk.elvtr.com/terms , which is an offer by the Company to enter into an agreement with any third party using the WebSite on the terms stipulated for the user in the User Agreement.
  • 1.15. Website constitutes a set of information, texts, graphic elements, design, images, photos and video materials, and other products of intellectual property, as well as computer programs contained in the information system, which ensures the availability of such information on the Internet available at: https://uk.elvtr.com .
  • 1.16. A personal account is a section of the WebSite, accessibility to which is granted to the User upon completion of the registration on the WebSite by entering a unique login and password.
  • 1.17. Cookies mean data, which is automatically transferred to the Company in the process of using the WebSite with the help of the software installed on the User's device, including the IP address, geographic location, information about the browser, and type of operating system of the User's device, specifications of the equipment and software used by the User, date and time of access to the WebSite. Cookies can be permanent (they are called persistent cookies) and be stored on the computer until the User deletes them, or temporary (such cookies are called session cookies), which are stored only until the browser is closed. In addition, cookies can be divided into first-party (they are installed directly by the visited WebSite) and third-party (installed by other sites).
  • 1.18. "IP address" is a numerical designation used by networked computers to identify the computer each time it accesses the Internet.

2. Personal Data Processing by the Company and User’s Consent

  • 2.1. The User accepts the terms of the Policy and gives the Company informed and conscious consent to the processing of his/her personal data under the conditions stipulated by the Policy and the Law:
  • 2.1.1. During registration on the WebSite the User provides personal data to the Company by:
    • by filling out the registration form, which can be found online, the User is considered to have given consent to the processing of the User’s personal data when the checkbox in the field "I accept the terms of the Offer Agreement and agree with the personal data processing policy" is ticked at the time of clicking the "Register" button;
    • by agreeing to share and authorization the use of personal data indicated by the User in social networks or electronic services. It is considered that the User has given his/her consent to the processing of the User’s personal data at the moment of clicking the button that displays the social network or electronic service selected for authorization.
    • By clicking the button ‘Register’, the User gives consent to the transfer of all User’s personal data, which was made through procedures generally available to everyone, and by indicating it in the account of the relevant social network or electronic service.
  • 2.1.2. While entering or editing personal data in the "Personal Data", and "My Interests" sections in the personal account. The User provides personal data to the Company while editing information in the "Personal Data", "My Interests" sections in the personal User’s account. The User is considered to have given consent to the processing of the User’s newly entered or changed personal data at the time of clicking the "Save" button.
  • 2.1.3. While filling out the feedback form. The User provides personal data to the Company when filling out an online feedback form on the WebSite and through electronic services (Google, etc.). 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 of clicking the button confirming the submission of the application (these buttons may be labeled as "Send", or "Submit a request" and in other similar ways).
  • 2.1.4. When signing up for a subscription to receive information and news materials from the Company, the User provides personal data to the Company by filling out a form for subscribing, which can be found online. The subscription form becomes available after completing the registration procedure. The User is considered to have given consent to the processing of his personal data by ticking the "I hereby give consent to the processing of my personal data" box at the time of clicking the "Subscribe" button.
  • 2.1.5. Registration for training under the Online Program by filling in the application fields for registration for training, which can be found online. The User is considered to have given consent to the processing of the User’s personal data by ticking the box in the "Register for training" form at the time of clicking the "Enroll" button.
  • 2.1.6. While sending a scanned copy of the completed consent form for the processing of personal data by email. The User provides personal data to the Company in order to receive educational services on the Site under the program of further professional education. The User is considered to have given consent to the processing of his personal data at the time of sending a scanned copy of the consent to the email address with the domain name @uk.elvtr.com.
  • 2.1.7. By signing up for a free class and by filling in the fields of the online registration application. It is considered that the user has given his consent to the processing of his personal data when the User ticked the box in the "Register for training" form at the time of clicking the "Enroll" button.
  • 2.1.8.While using the WebSite for any purpose, personal data is automatically transferred to the Company during the use of the WebSite by using the software installed on the User's device. It is considered that the user has given the User’s consent to the processing of the User’s personal data at the time of the start of using the Website.
  • 2.2. The User's consent to the processing of his personal data by the Company is valid since the date of giving consent to its processing (clause 2.1 of the Policy) and for the period necessary for achieving the goals of personal data processing (section 5 of the Policy).
  • 2.3. The User has the right to withdraw consent to the processing of his personal data in the form and procedure, provided for in section 9 of the Policy.

3. User’s consent for Personal Data provision

The Company proceeds from the premise that when providing personal data on the WebSite, the User:

  • 3.1. Confirms that he/she has all the necessary rights that allow him/her to obtain and exercise civil rights independently, as well as to create civil obligations by his/her actions, independently fulfill them, and bear responsibility in case of failure to fulfill these.
  • 3.2. Indicates accurate information about himself/herself in the amounts necessary to use the services of the Site, and maintains the provided data up to date.
  • 3.3. In case of uploading the User's Image via his/her personal account of the WebSite, the User agrees to the use of this image on a free-of-charge basis for purposes that are not related to the establishment of the User’s identity. The User undertakes not to provide photos of third parties as an image of the User.
  • 3.4. Acknowledges that information on the WebSite posted by the User about himself/herself may become available to other Users of the WebSite, and may be copied and distributed by such Users in the cases and under the conditions specified in clause 6.7 of this Policy.
  • 3.5. Realizes that any phone conversations conducted by him/herself with an employee of the Company are automatically recorded in order to control the quality of service provided to Users, as well as to resolve disputes and conflict situations that may arise during such phone calls. At the same time, the User gives his consent to the automatic recording of phone conversations and storage of such records in accordance with the terms of this Policy.
  • 3.6. Acknowledges that the User understands this Policy and expresses his/her informed and conscious consent to it.

4. Personal Data Processed by the Company

  • 4.1. The personal data of the User processed by the Company include the following:
    • full first name, last name, and patronymic name (if applicable);
    • cell phone number;
    • e-mail address;
    • data of accounts on social media and E-services (links to User profiles in VKontakte, Facebook, Linkedin, Skype, Google, Twitter, etc.);
    • image;
    • place of work;
    • country, city;
    • birth date;
    • professional occupation;
    • professional experience and held positions;
    • IP address;
    • cookies;
    • parameters and settings of web browsers (User-agent);
  • 4.2. The Company protects Data, which is automatically transmitted while viewing advertising units and while browsing pages with installed system statistical script (referred to as "pixel") on it. This shall include:
    • IP address;
    • data from cookies;
    • data on the web browser (or other program, which gains access to the advertisement display);
    • access time;
    • the address of the web page on which the ad unit is located;
    • referrer (URL of the previous web page);
  • 4.3. All Site login sessions are recorded during each visit to the website. Other user traffic information is not processed or stored.
  • 4.4. The Company does not collect any information processing which requires certain requirements established by law, such as information about racial or ethnic origin, political, religious, or ideological beliefs, membership in political parties and professional unions, criminal record, and proceeding, as well as data pertaining to health, sexual life, biometric or genetic data.
  • 4.5. The Company collects data regarding the statistics of website sessions. The data may contain information about connections, traffic, the user's web browser, as well as the date, time, and duration of online work and surfing the WebSite.
  • 4.6. Any other personal information that is not specified above (browsing history, web browsers and operating systems used, etc.) is subject to safe storage and non-distribution.

5. Use of Cookies

  • 5.1. The Company cares about its Users and tries to make the use of the WebSite as comfortable as possible. In order to ensure this the Company uses cookies to analyze the behavior, preferences, and interests of the User. Such an analysis helps the Company to improve the experience of interaction with the WebSite to determine the most convenient interface and navigation through the Service.
  • 5.2. According to the classification of the International Chamber of Commerce, the Company uses the following categories of cookies:

Strictly necessary cookies are needed for the user to browse the web page and use certain services, for example, to access protected pages, register, authorize, logging, and perform a search on the Website. They also store the history of the user's previous actions while transferring to the previous page in the same session.

Operational (Performance) cookies aggregate information about how the website is used. This data is stored on the User's device between sessions of the web browser. The following metrics can be examples of such data: time spent surfing the WebSite, the most frequently visited web pages, understanding which sections and services of the WebSite were most interesting to the User, how effective this or that advertising and/or marketing campaign is, etc.

All information collected with the help of operational cookies can be used for statistical and analytical purposes. Some cookie data may be provided to third parties, who obtained permission from the web resource, and solely for the aforementioned purposes.

Functional cookies are used to save settings or configurations that are stored on the user's device between sessions of the web browser. The following metrics can be examples of such data: username, account photo, information on posted comments, site language, location, information about whether the user was previously provided with any information or selected benefits, as well as other WebSite settings.

These cookies also allow users to watch videos, take part in interactive activities (quizzes, polls), and interact with social networks.

In order to improve the experience after visiting the resource, these cookies store the information provided by the User, which helps to increase the efficiency of interaction with the WebSite.

Some cookie data may be provided to third parties, who have obtained permission from the web resource, and solely for the aforementioned purposes.

Targeting cookies are used for providing content that may be of interest to the user. This data is stored on the User's device between sessions of the web browser. The following metrics can be examples of such data: tracking recommended text, graphics, audio, and video materials in order to avoid re-displaying, managing targeted advertising, evaluating the effectiveness of advertising campaigns, and information about the User's visits to other resources during transitions, as well as other WebSite settings.

The Website may share this information with other parties, including media clients, advertisers, agencies, and related business partners, so these partners and stakeholders can provide quality targeted advertising.

Third-party and analytics service cookies:

In order to ensure prompt delivery, better display, and detailed analysis of the content on the WebSite, the Company uses services that are the property of other third-party companies, such as Facebook, Twitter, Instagram, Alphabet Inc., Gemius, and others.

The above-listed companies, given as an example, may use cookies on the User's device while browsing the WebSite.

It’s worth noting that the WebSite cannot affect the work of the cookies used by these services. All the necessary information on their use can be found by visiting the appropriate resource. Google Analytics Terms of Use - https://marketingplatform.google.com/about/analytics/terms/us/

Cookie management:

The main web browsers (listed below) are set to automatically accept cookies. In order to disable them, use the help function in your web browser. The help function can be activated via the menu or using the F1 button.

Microsoft Edge — https://support.microsoft.com/en-us/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd

Mozilla Firefox — https://www.mozilla.org/en-US/privacy/websites/

Google Chrome — https://www.google.com/intl/en_uk/chrome/privacy/

Opera — https://www.opera.com/secure-private-browser

Safari for macOS — https://www.apple.com/legal/privacy/

Important:

  • cookie settings configuration for mobile web browsers may be different;
  • it is crucial to remember that full-fledged and uninterrupted work (browsing) with the WebSite is available only in case of using cookies;
  • disabled cookies may lead to restriction of access to content and to the malfunctioning of the Website services.

To contact the Company regarding the use of cookies, one shall send an email to privacy@elvtr.com. If the User does not enable the use of cookies or deliberately deletes all cookies from his web browser, then during the next visit to the WebSite the User will be asked to enable the use of cookies again.

Information about Users, which is obtained while using cookies, is not sold or distributed in the public domain. It is also the property of the company that owns the resource.

6. Purposes of Personal Data Processing

The Company processes Users' personal data solely for the following purposes:

  • 6.1. Registration of the User by the Company on the Website, and providing the User with the opportunity to fully use the website services.
  • 6.2. Displaying of the User profile on the WebSite in his/her personal account.
  • 6.3. Establishing and maintaining communication between the User and the Company, advising on the provision of services, and providing customer and technical support in case of problems associated with the use of the WebSite.
  • 6.4. Fulfillment of Company obligations to the User who signed up for learning under the Online Program, for a Free lesson, under agreements with the Company.
  • 6.5. Sending emails containing commercials to the email address of the User; targeting advertising materials.
  • 6.6. Improving the service quality for Users and modernizing the Company's WebSite by processing Users’ requests and applications.
  • 6.7. Statistical and other research based on depersonalized information provided by the User.
  • 6.8. Posting the following information on the Company's Online Platform, which is available at: https://uk.elvtr.com , in official social media groups and other communities of the Company online, other advertising and information sources, for purposes that are not related to the identification of the User:
    • video materials obtained while providing services;
    • User’s comments regarding the services provided by the Company.

The User reserves the right to unsubscribe from marketing email. If the User unsubscribes, then his/her name and email address will be automatically deleted from the database. In order to unsubscribe, the User shall click on the corresponding item, which can be found in each received email.

7. Personal Data Processing

  • 7.1. The processing and storage of the provided personal data are carried out in data centers where the installed equipment ensures the functioning of the WebSite's services. The personal data provided is processed and might be stored in the Personal Data Database, or in a separate table (section) of the WebSite Database. Since the Company's servers are located in different parts of the world, the information of a particular User may be processed in a country other than the country of the User’s current location. The level of information protection and legislation may differ in different countries. Regardless of where exactly the User's data is processed, the Company uses the same security measures outlined in this Policy. The company also adheres to a number of data transmission legislation, including the US-EU Privacy Shield Framework and the US-Switzerland Privacy Shield Framework
  • 7.2. Personal data is processed with the use of automated systems, except, when non-automated personal data processing is required due to legal requirements.
  • 7.3. The processing of the User's personal data includes the following actions performed by the Company: collection, recording, systematization, accumulation, storage, validation (updating, alteration), extraction, use, transmission (distribution, provision, access), depersonalization, blocking, removal, and destruction.
  • 7.4. The collection of the User's personal data shall be carried out in the cases stipulated in clause 2.1 of the Policy.
  • 7.5. The storage of personal data shall be carried out (whichever occurs first):
    • until they are deleted by the User in the "My profile and programs" and "Settings" sections of the personal account;
    • until the moment of personal data destruction carried out by the Company. In case the Company receives the User’s withdrawal from consent to personal data processing or a request for the removal of personal data;
    • until the consent expires (clause 2.2 of the Policy), or the goals of personal data processing are achieved.
  • 7.6. Validation of personal data can be carried out by the User independently in the "Personal data" and "My interests" sections of the Personal Account or by the Company at the request of the User.
  • 7.7. Distribution of personal data might be carried out by the Company only in the following cases:
  • 7.7.1. When processing personal data in order to display the User's profile for other WebSite Users in order to maintain communication, including while providing services remotely. In this case, the User's personal data may be available to Users, who are registered on the Site in accordance with clauses 2.1.4, 2.1.8.
  • 7.7.2. In order to post User’s comments about the services provided by the Company through various sources of information.
  • 7.7.3. For the purpose of posting video materials obtained in the process of providing services through various sources of information.
  • 7.8. The Company has the right to transfer personal data to third parties (Company’s Processors) subject to the following conditions:
    • a third party ensures the confidentiality of personal data while processing and using personal data; undertakes not to disclose to other persons, and also not to distribute personal data of Users without their consent;
    • the third party guarantees compliance with the following measures to ensure the security of personal data during its processing: (1) the use of information security tools; (2) detection and recording of the facts of unauthorized access to personal data and taking measures to restore personal data; (3) access restriction to personal data; (4) registration and record of actions with personal data; (5) control and evaluation of the efficiency of the measures taken for ensuring personal data security;
  • 7.9. The Company shall provide the removal of personal data in the following cases:
    • removal of personal data by the User in the "My Profile and Programs" and "Settings" sections of the personal account;
    • receipt of the User’s withdrawal from the consent for personal data processing;
    • receipt of the request for the removal of the User’s personal data;
    • expiration of consent (clause 2.2 of the Policy).
  • The Company never transfers personal data to third parties, except when such transfer is required by the Law, at the request of the owner of personal data, or in other cases outlined in this Policy. The Company acknowledges that personal data is valuable and integral content, including the personal non-property rights of any individual. Therefore, the Company takes all possible measures to protect the User’s personal data, which is voluntarily and consciously transferred to the Company.
  • 7.10. Cross-border transfer of personal data
  • The Company is responsible to ensure that the foreign state where the personal data are to be transferred ensures adequate protection of the personal data subjects' rights before commencing such transfer.
  • Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of subjects of personal data may be carried out in the following cases
    • the availability of personal data owner’s written consent to the cross-border transfer of User’s personal data;
    • execution of an agreement to which the subject of personal data is a party. to which the personal data owner is a party.

8. Personal Data Protection

The Company takes all the necessary and sufficient legal, organizational and technical measures to protect the User’s personal data from unauthorized or accidental access, removal, modification, blocking, copying, and distribution, as well as from other illegal actions performed by third parties. However, the Company cannot guarantee absolute protection against any threats arising beyond the Company's control.

The Company uses standard methods such as encrypted communication, secured premises, firewall systems, and password-protected systems to ensure the confidentiality of personal data.

The Company provides access to information and personal data only to its authorized employees, who have agreed to ensure the confidentiality of such information and data in accordance with the requirements of the Company.

The Website may contain links to other websites (for informational purposes only). If the User follows a link to browse other websites, this Policy will not apply to such websites. Therefore, the Company recommends users to read the privacy and personal data protection policies of each website before transferring their (User’s) personal data according to which the User can be identified.

9. User Rights

The User has the right to:

  • 9.1. To provide the Company with personal data, at his/her sole discretion, for its processing on the terms stipulated in the Policy. At the same time, some of the personal data is required for the provision in order to finalize the conclusion of the User Agreement. In case this data is not provided the conclusion of such a User Agreement is impossible;
  • 9.2. To make changes and corrections to User’s personal data in the "Personal Data" and "My Interests" sections in User’s personal account, provided that such changes and corrections contain up-to-date and accurate information;
  • 9.3. To delete personal data by editing the "Personal Data" and "My Interests" sections in your personal account;
  • 9.4. To require the Company to clarify his/her personal data, block or remove the data in case the personal data is incomplete, outdated, inaccurate, illegally obtained, or not required for the stated purpose of processing. As well as the User can take legal measures to protect his/her rights;
  • 9.5. To receive an answer on whether personal data is being processed, as well as receive the content of such personal data, but no later than thirty calendar days from the date of receipt of the request by the Company, except as otherwise provided by law;
  • 9.6. To submit a justified claim to the owner of personal data with an objection to the processing of his/her personal data;
  • 9.7. To use the means of legal protection in case of infringement of the legislation on the protection of personal data, including filing a complaint to a supervisory authority;
  • 9.8. To update, access, edit, block, or delete User’s personal data, withdraw his/her consent to the processing of personal data that has been provided to the Company in accordance with this Policy/ In case of any comments, wishes or claims regarding User’s Personal Data, which is being processed by the Company, the request should be sent to the Company’s email info.uk@elvtr.com
  • 9.9. To send the Company User’s requests and requirements, including those 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 writing to the Company address (section 11 of the Policy); or by e-mail (the Document shall be sent from the e-mail address of the User specified by him during registration on the Site or as an authorized e-mail address in the agreement), to the e-mail address info.uk@elvtr.com. The Company considers the Users’ Appeals, provides a response to them, and/or takes the necessary actions within 30 calendar days from the date of receipt of such Appeal.
  • 9.10. In addition to the rights indicated in this Policy, the User has the opportunity to exercise any right provided for by the Law.

10. Modification of this Policy

  • 10.1. The Company reserves the right to periodically make changes, amendments, and modify this Policy, including when legal requirements have changed, and without prior notice to the User.
  • The User is obliged to re-read the text of the Policy every time he uses the WebSite.
  • 10.2. The new edition of the Policy comes into force upon posting by the Company in the relevant section of the Company's website. Continued use of the Website or its services after posting a new edition of the Policy constitutes acceptance of the Policy and its terms by the User. In case of any disagreement with the terms of the Policy, the User shall immediately stop using the Website and its services.
  • 10.3. The Company kindly asks to review the Policy from time to time in order to be aware of any changes, amendments, and modifications.

11. Company Profile and Contact Details.

ELVTR US LLC

Correspondence address: 300 Spectrum Center Dr, Suite 400, Irvine, CA 92618

E-mail address: info.uk@elvtr.com