1. DEFINITION OF TERMS

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In this Privacy Policy, the following terms are used:

1.1. "Administration of the Resource https://www.up.university/" (hereinafter referred to as the Administration, Operator) – authorized employees managing the Resource, acting on behalf of Upgrade People LLP, UK, OC443065, registered at the address: 61 BRIDGE STREET, KINGTON HEREFORDSHIRE, UNITED KINGDOM, HR5 3DJ, which organizes and/or carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

1.2. "Personal data" - any information related directly or indirectly to a specific or identifiable individual (subject of personal data), including:

1.2.1. Personal information that the User provides about themselves independently during registration (account creation, filling out a course application, writing a review, etc.) or in the process of using the Services, including the User's personal data. Information required for the provision of Services is marked in a special way. Other information is provided by the User at their discretion.

1.2.2. Data that is automatically transmitted to the Site's services in the process of their use through the software installed on the User's device, including IP address, cookie data, information about the User's browser (or other programs used to access the services), technical characteristics of the hardware and software used by the User, date and time of access to the services, addresses of requested pages, and other similar information.

1.3. "Processing of personal data" - any action (operation) or set of actions (operations) performed using automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

1.4. "Confidentiality of personal data" - a mandatory requirement for the Operator or other persons who have gained access to personal data to prevent their distribution without the consent of the subject of personal data or other legal grounds.

1.5. "Resource https://www.up.university/" (hereinafter referred to as the Resource) - a collection of interconnected web pages located on the internet at a unique address (URL): https://www.up.university/, as well as all its subdomains.

1.6. "Subdomains of the site https://www.up.university/" - are pages located at the addresses:

1. https://lms.nekrasov.space/;

2. https://www.coachingup.university/;

3. https://www.coaching.up.university/;

4. https://www.life.up.university/;

and other temporary pages, at the bottom of which contact information may be indicated: Upgrade People LLP, UK, OC443065, registered at the address: 61 BRIDGE STREET, KINGTON HEREFORDSHIRE, UNITED KINGDOM, HR5 3DJ; Email address: tanya@coachingup.university.

1.7. "User of the Resource https://www.up.university/" (hereinafter - User) - a person who has access to the Resource via the internet and uses the information and materials of the Resource https://www.up.university/.

1.8. "Cookies" - a small piece of data sent by a web server and stored on the user's computer, which the web client or web browser sends to the web server each time in an HTTP request when attempting to open a page of the corresponding site.

1.9. "IP address" - a unique network address of a node in a computer network built using the IP protocol.

1.10. "Actual threats to the security of personal data" - a set of conditions and factors that create a current risk of unauthorized, including accidental, access to personal data during their processing in an information system, which may result in the destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful actions.

 

2. GENERAL PROVISIONS
 

2.1. The use of the Resource by the User means acceptance of this Privacy Policy and the terms of processing the User's personal data.

2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the Resource.

2.3. This Privacy Policy applies to the Resource https://www.up.university/ and all its subdomains.

2.4. The Resource does not control and is not responsible for third-party websites to which the User may go through links available on the Resource https://www.up.university/.

2.5. The Administration does not verify the accuracy of the personal data provided by the User of the Resource https://www.up.university/.

 

3. SUBJECT OF THE PRIVACY POLICY
 

3.1. This Privacy Policy establishes the obligations of the Administration for non-disclosure and ensuring the confidentiality of personal data that the User provides at the request of the Administration when registering on the Resource or otherwise using the Resource, as well as when placing an order to purchase a product or service.

3.2. The personal data permitted to be processed under this Privacy Policy is provided by the User by filling out the registration form or feedback form on the Resource and includes the following information:

3.2.1. the User's last name, first name, middle name;

3.2.2. User's contact phone number;

3.2.3. User's email address (e-mail);

3.2.4. User's place of residence (upon request of the Administration).

3.3. The Resource protects Data that is automatically transmitted during the viewing of advertising blocks and when visiting pages where a statistical system script ("pixel") is installed:

3.3.1. IP address;

3.3.2. information from cookies;

3.3.3. information about the browser (or another program that provides access to the display of advertisements);

3.3.4. access time;

3.3.5. address of the page on which the advertisement block is located;

3.3.6. referrer (address of the previous page).

3.4. Disabling cookies may result in the inability to access parts of the Resource that require authorization.

3.5. The Resource collects statistics on the IP addresses of its visitors. This information is used to identify and resolve technical problems, as well as to control the legality of financial transactions.

3.6. Any other personal information not specified above (purchase history, operating systems, etc.) is subject to secure storage and non-disclosure, except as provided in clauses 5.2. and 5.3. of this Privacy Policy.

 

4. PURPOSES OF PROCESSING USER'S PERSONAL INFORMATION

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4.1. The Resource (Site) collects and stores only the personal information necessary for the provision of services or the execution of agreements and contracts with the User, except in cases where the law requires mandatory storage of personal information for a certain period.

4.2. The personal data of the User may be used by the Administration of the Resource https://www.up.university/ for the following purposes:

4.2.1. Identifying the User registered on the Resource to process orders and/or conclude, for example, a Contract-offer for the provision of information and consulting services remotely.

4.2.2. Providing the User with access to personalized data on the Resource.

4.2.3. Establishing feedback with the User, including sending notifications, requests related to the use of the Resource, providing services, processing requests, and applications from the User.

4.2.4. Determining the location of the User to ensure security and prevent fraud.

4.2.5. Confirming the accuracy and completeness of the personal data provided by the User.

4.2.6. Creating an account if the User has agreed to create an account.

4.2.7. Sending notifications to the User of the Resource (if necessary).

4.2.8. Processing and receiving payments, confirming tax or tax benefits, disputing payments, determining the User's eligibility for a credit line.

4.2.9. Providing the User with effective customer and technical support in case of problems related to the use of the Resource.

4.2.10. With the User's consent, providing updates on products, special offers, pricing information, newsletters, and other information on behalf of the Resource or its partners.

4.2.11. Conducting advertising activities with the User's consent.

4.2.12. Providing the User with access to the Resource's partner websites or services to obtain products, updates, and services.

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5. METHODS AND TERMS OF PROCESSING PERSONAL INFORMATION

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5.1. The processing of the User's personal data is carried out for no longer than is necessary for the purposes of processing personal data, using any lawful methods, including in personal data information systems using automation tools or without the use of such tools.

5.2. The User agrees that the Administration has the right to transfer personal data to third parties, in particular to courier services, postal organizations, telecommunications operators, solely for the purpose of fulfilling the Contract-offer, to which the User has agreed on the Resource.

5.3. The User's personal data may be transferred to authorized state authorities of Ukraine only on the grounds and in the manner prescribed by the legislation of Ukraine.

5.4. In the event of loss or disclosure of personal data, the Administration informs the User about the loss or disclosure of personal data.

5.5. The Administration takes the necessary organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties.

To perform work on ensuring the security of personal data during their processing in the information system, the Resource administration may contract a legal entity or individual entrepreneur who has, if necessary, a license for activities related to the technical protection of confidential information.

The security measures implemented within the personal data protection system, considering current threats to personal data security and the applied information technologies, include the following measures, but are not limited to:

- Identification and authentication of access subjects and access objects;

- Management of access subjects' access to access objects;

- Limitation of the software environment;

- Protection of machine-readable media on which personal data is stored and/or processed (hereinafter referred to as machine-readable personal data media);

- Registration of security events;

- Antivirus protection;

- Detection (prevention) of intrusions;

- Control (analysis) of personal data security;

- Ensuring the integrity of the information system and personal data;

- Ensuring the availability of personal data;

- Protection of the virtualization environment;

- Protection of technical means;

- Protection of the information system, its resources, communication, and data transmission systems;

- Detection of incidents (one event or a group of events) that may lead to malfunctions or disruption of the information system and/or pose a threat to the security of personal data (hereinafter referred to as incidents) and response to them;

- Configuration management of the information system and the personal data protection system;

- Checking system and/or application software, including source code, for the absence of undeclared capabilities using automated tools and/or without such tools;

- Testing the information system for penetration;

- Using system and/or application software developed with secure programming methods in the information system.

5.6. The Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

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6. RIGHTS AND OBLIGATIONS OF THE PARTIES

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6.1. The User has the right to request the Administration of the Resource to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights.

6.2. If the User believes that the Resource Administration is processing their personal data in violation of Ukrainian legislation on personal data or otherwise violating their rights and freedoms, the User has the right to appeal the actions or inaction of the operator to the authorized body for the protection of personal data subjects or in court, including claiming damages and/or compensation for moral harm in court.

6.3. The User has the right to withdraw consent to the processing of personal data by sending a notification to the Resource Administration at the email address: tanya@coachingup.university (the site administrator’s email). 

6.4. The User is obligated to:

6.4.1. Provide information about personal data necessary for using the Resource.

6.4.2. Update and supplement the provided personal data information in case of changes.

6.5. The Resource Administration is obligated to:

6.5.1. Use the obtained information solely for the purposes specified in Section 4 of this Privacy Policy.

6.5.2. Ensure that confidential information is kept secret, not disclosed without the prior written consent of the User, and not sold, exchanged, published, or disclosed by any other possible means of the User's personal data, except for the provisions of sections 5.2. and 5.3. of this Privacy Policy.

6.5.3. Take precautions to protect the confidentiality of the User's personal data according to the procedure commonly used to protect this type of information.

6.5.4. Block personal data related to the respective User from the moment of the User's request or inquiry, or their legal representative, or the authorized body for the protection of personal data subjects, for the period of verification, in case inaccurate personal data or unlawful actions are identified.

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7. LIABILITY OF THE PARTIES

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7.1. The Resource Administration, which has failed to fulfill its obligations, is liable for losses incurred by the User due to unlawful use of personal data, in accordance with the legislation of Ukraine, except in cases provided for in sections 5.2., 5.3., and 7.2. of this Privacy Policy.

7.2. In case of loss or disclosure of Confidential Information, the Administration is not responsible if this confidential information:

7.2.1. Became public domain before its loss or disclosure.

7.2.2. Was received from a third party before it was obtained by the Resource Administration.

7.2.3. Was disclosed with the User's consent.

7.3. The User is fully responsible for complying with the laws of Ukraine, including laws on advertising, copyright and related rights protection, trademark protection, but not limited to, and including full responsibility for the content and form of materials.

7.4. The User acknowledges that the responsibility for any information (including but not limited to data files, texts, etc.) to which they may have access as part of the Resource lies with the person who provided such information.

7.5. The User agrees that the information provided to them as part of the Resource may be the subject of intellectual property rights, which are protected and belong to other Users, partners, or advertisers who place such information on the Resource https://www.up.university/. The User has no right to modify, rent, lease, loan, sell, distribute, or create derivative works based on such Content (in whole or in part), except when such actions have been explicitly permitted in writing by the owners of such Content under the terms of a separate agreement.

7.6. Regarding textual materials (articles, publications freely available on the Resource), their distribution is allowed provided that a link to the site (or any other resource) and the author's full name (pseudonym, nickname) is given.

7.7. The Administration is not responsible to the User for any loss or damage incurred by the User due to the deletion, failure, or inability to save any Content and other communication data contained on the Resource or transmitted through such a Resource.

7.8. The Administration is not responsible for any direct or indirect damages caused by: the use or inability to use the site or individual services; unauthorized access to the User's communications; statements or behavior of any third party on the site.

7.9. The Administration is not responsible for any information posted by the user on the Resource, including but not limited to information protected by copyright, without the direct consent of the copyright owner.

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8. DISPUTE RESOLUTION

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8.1. Before filing a lawsuit regarding disputes arising from the relationship between the User of the Resource https://www.up.university/ and the Administration, it is mandatory to file a claim (a written proposal for voluntary settlement of the dispute).

8.2. The recipient of the claim must notify the claimant in writing of the results of the claim review within 30 calendar days from the date of receipt of the claim.

8.3. If an agreement is not reached, the dispute will be submitted to the court at the location of the Administration.

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9. ADDITIONAL CONDITIONS

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9.1. The Resource Administration has the right to make changes to this Privacy Policy without the User's consent.

9.2. The new Privacy Policy comes into effect from the moment it is posted on the Resource, unless otherwise provided by the new version of the Privacy Policy.

9.3. All suggestions or questions regarding this Privacy Policy should be sent to: tanya@coachingup.university.

9.4. The current Privacy Policy is posted on the page at https://www.up.university/.

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