ПОЛИТИКА ЗА ПОВЕРИТЕЛНОСТ

Version of January 21, 2025

1. GENERAL PROVISIONS
1.1 This Privacy and Personal Data Processing Policy provides the User with information about the processing of his/her personal data by the administrator of the LEARN2GO Service (hereinafter referred to as the “Service”) - LLC "LINKLEND" (hereinafter referred to as the “Administrator”), including information required by the legislation of Ukraine on the protection of individuals regarding the processing of personal data.
1.2. Please read the Privacy Policy carefully before using the Service, as the use of the Service involves the collection, processing, use and storage of personal data, as well as the transfer of personal data to third parties (including cross-border data transfer).
1.3. This Privacy and Personal Data Processing Policy (hereinafter referred to as the “Policy”) is an integral part of the User Agreement (hereinafter referred to as the “Agreement”) between the Administrator and the Users, available at https://bg.learn2go.net/user-agreement.
1.4. The owner (controller) of the personal data of the Users of the Service is LLC "LINKLEND", registration number: 45071805, address for correspondence: 02002, Ukraine, Kyiv, Dniprovska embankment, building 26zh, office 26.
1.5. For all questions regarding the processing (including collection, use and storage) of personal data, as well as the transfer of personal data, Users can contact: data_protection@linklend.com.ua.
 
2. WHAT IS PERSONAL DATA?
2.1. Personal data (hereinafter referred to as “Data”) means any information about the User that allows the User to be identified directly or indirectly, such as name, user ID in the Service, location information, online identifiers (indicators of the User's actions in the Service), or other information about the User.
2.2 The information specified by the User in the Account (surname, name, patronymic, mobile phone number, e-mail, postal address) is his/her personal data. If the User specifies the personal data of a third party in the Account, the User guarantees the legitimacy, disposes of and authorizes the Administrator to use the third party's data.
3. WHAT USER DATA DOES THE ADMINISTRATOR PROCESS?
The Administrator may process various categories of User Data, namely:
3.1. Data provided by the User:
3.1.1. The User's first and last name, nickname, e-mail address, telephone number, gender, age, photo (avatar), payment data, data on payment methods, contacting the support service. You provide such data in several ways, for example, during registration and/or use of the Service, interaction with the support service and/or participation in promotional activities conducted by the Administrator (both independently and with the help of partners).
3.1.2. Information provided when posting a review and/or marking “Like”/“Dislike” a particular piece of Content on the Service and/or other information that you provide while using the Service.
3.2. Data collected by the Administrator, including through the use of cookies.
3.2.1. Data about the User's activity on the Service, such as browsing history, search history, etc.
3.2.2. Data on the type of device, model, device id and its operating system used to access the Service; Internet browser used to access the web version of the Service. n case when software applications of the Service are used on devices to access the Service, data on the location of the device (up to the city) is collected.
3.2.3. Details of interaction with the support service, such as the date, time and reason for contacting the support service, a transcript of any conversation with the support service staff.
3.2.4. Data that we receive through cookies, web beacons and other similar technologies. You can read more about this in the paragraph on cookies.
3.2.5. Results of marketing/advertising activities.

4. UNDER WHAT CONDITIONS CAN THE ADMINISTRATOR PROCESS CHILDREN'S DATA?
4.1 The LEARN2GO Service may be used by children only under the supervision of a parent or other legal guardian. The User must be at least 18 years old to use the Service independently.
4.2. The User must be old enough to make a decision to provide their Data to the Administrator. If the User is under 18 years of age, the consent to the processing of his/her data must be given or approved by one of his/her parents, guardian or other legal representative.

5. ON WHAT BASIS DOES THE ADMINISTRATOR PROCESS THE DATA? FOR WHAT PURPOSE DOES THE ADMINISTRATOR PROCESS THE DATA?
5.1. The legal grounds for processing personal data are:
5.1.1. conclusion and execution of the User Agreement, to which the User is one of the parties, as well as to perform actions necessary to conclude the Agreement and register Users in the Service, to receive payments from Users and to communicate with Users regarding the above actions.
Here are some examples:
-    Identification of Users while using the Service. The Administrator may use the information to confirm the User's access to the Service.
-    Fulfillment of requests for Content accessed as part of the use of the Service.
-    Individualization of the User's use of the Service, based on the model of behavior and the User's area of interest. The Administrator may profile personal data to increase the level of its relevance. Profiling is any form of automated processing of personal data, including the use of personal data to assess certain personal characteristics of a person, in particular to analyze or predict aspects related to this person in the context of his or her activities. When using the Service, such as personal preferences, interests and location. The Administrator does not make any decisions that may have legal or other important consequences for the User, including those based on data profiling. The possible automatic processing, including profiling, will be intended solely for the analysis and prediction of the User's preferences in order to prepare individual offers to the User.
-    Ensuring that important notifications are sent, such as changes to the User Agreement and/or the Privacy and Personal Data Policy.

5.1.2. the User's consent to the processing of personal data;
Here are some examples:
-    Using personal data to increase the relevance of advertising materials and more accurate targeting.
-    We use cookies and similar technologies to provide content and the best user experience through the user's device. For more information, please see the section on cookies.
5.1.3. the legitimate interest of the Administrator to carry out direct marketing, for example, to send, push notifications and other messages, in particular in the Service interface, of an informational and advertising nature, as well as legitimate interests to counteract fraudulent activities, including those related to the test period of using the Service.
      The legitimate interest of the Administrator to ensure the operation of loyalty programs and integration of the Service, as well as the legitimate interest to improve the user experience and promote the Service for its development and the development of the business of LLC "LINKLEND" as a whole.
For example:
-    Analyzing and researching the actions of Users within the Service to improve the quality of services provided in the Service, as well as the ways of interacting with Users.
-    Preventing fraudulent activities, including during the test period of using the Service.
-    If the User participates in any advertising campaign, contest, loyalty program, promotion, other marketing activity or similar event, in particular by fulfilling certain predetermined conditions or requirements (for example, registration, following a link, providing data, performing certain actions), the Administrator has the right to use and process personal data provided by the User (for example, phone number, e-mail address), as well as other data (for example, user ID, subscription information of the User)  to ensure the proper conduct of the relevant event, in particular for moderation, verification of the User's right to participate and provision of relevant benefits (discounts, etc.)
-    -The Administrator may profile personal data to improve the quality of services. The Administrator does not make any decisions that may have legal or other important consequences for the User, including on the basis of data profiling. Possible automatic processing, including profiling, will be intended only for the analysis and prediction of the User's preferences for direct marketing.
-    Informing Users about the appearance of new Content on the Service, promotions or other news about the Service by e-mail, push notifications or other means of communication. The User has the right to refuse to receive such information by independently disabling the function of receiving newsletters by clicking on the special link specified in the email; by sending an email to the Administrator's email address data_protection@linklend.com.ua by disabling push notifications in the settings of mobile devices;
 5.1.4. the need to fulfill the obligation of the owner of personal data, which is provided for by law.

6. HOW LONG IS THE USER'S PERSONAL DATA STORED?
6.1. We store and process your data for no longer than is necessary to achieve the purposes for which it was collected. The retention periods are determined on a case-by-case basis and depend on things like the nature of the data, why it is collected and processed, and the relevant legal or operational storage needs. Please note that we may also retain and use your information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.
6.2. After the expiration of the retention period for processing your data, we may aggregate or delete the data to the point where the User can no longer be identified and process it solely in a statistical form. After taking precautions to protect against the risks of re-identification, the data is no longer considered personal, as it does not allow the User to be identified.

7. WHAT RIGHTS DOES THE USER HAVE REGARDING THEIR PERSONAL DATA?
7.1. The user has the following rights regarding his/her personal data:
a)    to know about the sources of collection, location of their personal data, the purpose of their processing, location (stay) of the owner or manager of personal data or to give an appropriate order to obtain this information to persons authorized by them, except in cases established by law;
b)    to receive information on the conditions for granting access to personal data, including information about third parties to whom his/her personal data is transferred;
c)    to have access to their personal data;
d)    to receive a response on whether his/her personal data is processed no later than thirty (30) calendar days from the date of receipt of the request, except as provided by law, and to receive the content of such personal data;
e)    to submit a reasoned request to the personal data controller with an objection to the processing of their personal data;
f)    to make a reasoned request to change or destroy their personal data by any owner and administrator of personal data if such data is processed illegally or is unreliable;
g)    to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or discrediting to the honor, dignity and business reputation of an individual;
h)    to file complaints against the processing of their personal data with the Human Rights Commissioner or a court;
i)    apply for legal remedies in case of violation of the legislation on personal data protection;
j)    make reservations regarding the restriction of the right to process their personal data;
k)    withdraw consent to the processing of personal data;
l)    to know the mechanism of automatic processing of personal data;
m)    to be protected against an automated decision that has legal consequences for him/her.
7.2. To exercise their rights, the User can contact the Administrator by e-mail - by writing a letter to the address: data_protection@linklend.com.ua
7.3. If the User requests the deletion of Personal Data, the Administrator shall ensure the deletion of the account and personal data associated with such account.
7.4. The deletion of personal data may also be restricted in accordance with the requirements of applicable law. In particular, such restrictions may provide for the Administrator's obligation to retain the information deleted by the User for the period established by applicable law and to transfer such information in accordance with the legally established procedure of a state body. In addition, the Administrator has the right to restrict the right to delete in order to protect its own interests from any legal claims within the statute of limitations. If the right to delete data is restricted, the User may request that the Administrator limit the processing of data to storage only.
7.5. The exercise of other rights may be similarly restricted in accordance with the requirements of applicable law.
7.6. The User's request to exercise the above rights will be evaluated taking into account the circumstances of the individual case. Please note that the Administrator may store and use information if it is necessary to comply with legal obligations, resolve disputes and enforce agreements.
 
8. WHAT ARE COOKIES AND HOW DO WE USE THEM?
8.1. The web version of the Service, mobile applications and advertisements may use cookies and other similar technologies. These technologies store identification text files on the User's device - pieces of program code that allow you to store information about the User and identify him or her in the future use of the Service.
8.2. The types of cookies placed by the Service and third parties are listed here. In addition to the cookies strictly necessary for the provision of the Service, they contain information about cookies that may be used by third parties to assist the Service Administrator in providing the Service. The Service cookies are permanent, temporary or session cookies by their validity period.
Essential cookies - these cookies are essential for the functioning of the Service and cannot be disabled in the Service systems. They are set in response to actions performed by the User that constitute a request for services, such as setting up, registering, logging in or filling out an account. If you configure your browser to block these cookies, it may result in some parts of the Service not working. Such cookies on the Service include functionality, performance, analytics (e.g., content personalization, recommendation system; fraud monitoring), security, User account authentication cookies, as well as User session cookies on the Service.
Analytics cookies - these cookies collect information about how Users use the website, such as which pages Users visit most often and whether they receive error messages from web pages. Also, these cookies are used to provide statistical information, which is commonly used to measure performance and make improvements. This is also known as “analytics”. Analytics includes activities such as counting page visits, time spent, metrics, preferences. The electronic communications of the Service may use “click-through URLs” that are associated with certain materials in the Service, and when clicked on, the User is directed to the target page. At this point, the Service also collects analytical data, as they provide information about the most popular topics and the level of interaction with the User. Sometimes analytics services are provided by third parties and specialized software that may use first-party and third-party cookies. Some third-party software services embedded on the site may use analytics services to measure the effectiveness of the services. The Service uses Google Analytics to count traffic and traffic sources in order to measure and improve the effectiveness of the Service. They help us to find out which pages are the most and least popular and to see how Users navigate the site. To view the privacy policy of Google Analytics cookies, please follow the link: https://support.google.com/analytics/answer/6004245. 
Targeted cookies - these cookies are used to provide advertising that is more relevant to the User and the User's interests. For example, information about viewing certain Content using the User's computer or mobile device allows us to make the Service's advertising messages and materials more relevant to the User's interests. In addition, special pixel tags allow you to determine whether an email sent by the Service has been opened and read. The Service may also use this information to reduce or eliminate emails. Targeted cookies are also used to determine the effectiveness of an advertising campaign. Targeted cookies can be set on the Service website by advertising partners. These cookies remember that the User has visited a particular website, and this information is transmitted to other organizations, such as advertisers. If the User does not allow these cookies, he/she will still see general advertisements that are not based on the User's interests.
Third party cookies - these cookies are set by third parties for marketing, analytical and functional purposes. For example, when you log in through external partner resources, certain cookies may be set for the correct functioning of the features. If such cookies are blocked, certain parts of the service functionality may not work properly. The list and name of such cookies may be dynamically changed by the relevant third party.
8.3. The User can always restrict the use of cookies while using the Service and withdraw their consent to their use. To change the settings of cookies, the User can use the settings of their Internet browser or mobile device.

9. WITH WHO DO WE SHARE YOUR DATA?
9.1. For the proper and high-quality provision of services to the User, support of various functions of the Service and ensuring its operation, for the provision of marketing and advertising services or for transactions by various payment methods within the Service, we enter into agreements with independent contractors, as well as cooperate with other service providers, companies and organizations. As part of this involvement of contractors and service providers, the User's data may be transferred to third parties (who are personal data managers).
9.2. The Administrator has the right to transfer personal data of Users across borders under the conditions provided for in this Policy. The User is notified and agrees that in case of cross-border transfer of his/her personal data, the recipients of such data may be located in foreign countries that do not provide adequate protection of personal data within the meaning of the Law of Ukraine “On Personal Data Protection”, namely, are not parties to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data. At the same time, the Administrator undertakes to take all necessary measures to ensure the confidentiality and security of any personal data transferred to the territory of any foreign countries.
9.3. Among other things, we involve partner companies (hereinafter referred to as “Partners”) to provide access to the Media Service, provide technical support to Users and make decisions on improving the service for Users. The Administrator provides the Service on the territory of Ukraine. Services for providing access to the LEARN2GO Service in other countries are provided or may be provided to the User by partner companies with whom the Administrator has an agreement, whose online services operate under the domain names without limiting the hierarchy levels of such websites and software applications.

Partner Functions:
-    accepting payments from Users;
-    advertising
-    direct marketing;
-    engaging contractors for the proper and high-quality provision of services to the User.9.4. In particular, but not limited to, the Administrator may use:
9.4.1. the services of a data center that processes data exclusively in encrypted form and guarantees the confidentiality of this data;
9.4.2. services of a cloud platform for SaaS solutions (SaaS - software as a service);
9.4.3. services of a content delivery network (CDN) provider The content delivery network allows you to significantly speed up the download of content to the User's device;
9.4.4. Services of other providers of information and consulting services;
9.4.5. services of companies for analyzing and statistical research of the use of the Service in order to improve the quality of services and operation of the Service, as well as targeting (personalization of display) of advertising materials and content recommendation system and providing the User with personalized and recommendation services of the Service;
9.4.6. services of companies for communication with the User, including sending notifications, requests and information regarding the use of the Service, as well as processing requests and applications from the User.
9.5. Please note that if you send a message to the Administrator on its official pages and accounts in such services and programs as Facebook, Instagram, Telegram, Viber, iMessages or send a letter to the Administrator's e-mail, you use the services of these services and/or the services of your e-mail operator at your own risk and agree that the providers of these services may have access to your personal data and be independent controllers of your data along with the Administrator. The Administrator does not control the use of personal data by the service providers listed in this paragraph.
9.6. Other third parties may also be involved by the Administrator, for example, to provide marketing and advertising services or to carry out transactions by bank cards or other payment methods within the Service. The list of these third parties is provided by the Administrator upon written request of the User.

10. OTHER CASES OF DATA DISCLOSURE
10.1. Personal data may also be disclosed in the following cases:
10.1.1. Disclosure of information in accordance with the order of a competent court or regulatory authority in cases provided for by law.
10.1.2. In the presence of the User's consent to such disclosure.
10.1.3. In case of joint promotional activities with third parties. In this case, the User, by participating in such promotional activities, provides his/her personal data not only to the Administrator, but also to the Administrator's partners regarding such activities. Please note that third parties involved in promotional activities have their own privacy policy and interaction with the personal data of the Users and are responsible for its observance.
10.1.4. In the event of reorganization, restructuring, merger, sale or other transfer of assets, personal data may become part of the transferred information. In the event of such transfer, the party undertakes to ensure a level of personal data protection not less than that provided for in this Privacy Policy.
10.2. Please also note that when using the Service, the User may disclose information about himself/herself and/or the use of the Service by using “share to” plugins for some social platforms (Facebook, X, the terms of use of such buttons and plugins are directly subject to the privacy policies of social platforms).
10.3. Such data specified by the User in the account(s), including profiles, such as name, photo, as well as any social action (for example, commenting) within the Service will be freely available. This means that they can also be viewed by other users within or outside the Service (for example, users, visitors to the Service or users of third-party search engines).
 
11. WHEN CAN THE ADMINISTRATOR CHANGE THE TERMS OF THIS POLICY?
11.1. The Administrator reserves the right to change this Policy. In case of changes to the content of the Policy, the Administrator shall notify the User of the revised Policy. In the event of changes that change the Administrator's rights to use previously collected information, the Administrator, for its part, requires the User's consent to such use, unless otherwise provided by applicable law. In any case, the Administrator shall notify the User of such changes.
11.2. The Administrator undertakes to notify the User of changes to the Policy and the effective date of such changes in a timely manner. The User may continue to use the Service only after providing proper consent to such changes, proper consent to such changes is the continued use of the Service after receiving notification of the changes. If the User does not accept any amendments to the Privacy Policy, the User accordingly refuses to use the Service and is obliged to contact the Administrator to delete his/her account.
 
12. HOW DOES THE ADMINISTRATOR PROTECT PERSONAL DATA?
12.1. The Administrator implements all necessary security measures necessary to protect the User's personal data, for example
-    we provide access to data to a limited number of persons and only when necessary;
-    we use the secure Hypertext Transfer Protocol Secure (HTTPS) protocol to ensure that the use of the Service via the Internet is safe;
-    we train our staff to handle data securely. In particular, we require our employees and contractors to use strong passwords and incorporate multi-factor authentication;
-    we enter into non-disclosure and data processing agreements with our employees and subcontractors;
-    to protect against unauthorized access to data, we have applied a network screen (firewall), hashing of Users' passwords, etc;
-    we also regularly back up data to be able to restore it whenever necessary.
12.2. However, the Administrator cannot guarantee 100% security of all information transmitted and/or collected directly by the Administrator while using the Service, as no method of transmission over the Internet is completely secure. The Administrator cannot guarantee that the data will not be viewed, disclosed, or destroyed as a result of breaking or overcoming any security measures that have been taken by the Administrator.

13. CONTACTING THE ADMINISTRATOR OR THE DATA PROTECTION AUTHORITY
13.1 If you have any questions or concerns about our Privacy Policy, you can always contact us by sending an email to: data_protection@linklend.com.ua 
13.2. You may also lodge a complaint or contact a data protection authority, represented by the Human Rights Commissioner, in accordance with the right granted to you by law.