Privacy Policy

The text of the Privacy Policy set out below is developed by JUSTSPEAK LTD, registration number: HE 461589 (hereinafter referred to as "Rightholder" and/or "Company") and addressed to an unspecified group of persons, Users of the Website https://justschool.me/en and/or Mobile application on the Internet and determines the procedure for receiving, collecting, accumulating, storing, processing, using, ensuring protection and disclosure of personal data (hereinafter - "Data") using the Website and/or Mobile application and/or related services and tools. If you do not agree with the terms of this Privacy Policy, or other documents posted by the Rightholder on the Website, do not use the Website and/or the Mobile Application.

1. Terms and Definitions
   
   The website – is a collection of information, texts, graphic design elements, images, photos and video materials and other results of intellectual activity, as well as programs contained in an information system that ensures the availability of such information by network address (domain) on the Internet. Website address on the Internet https://justschool.me/en.
   Mobile application – is a copy of a computer program in the form of a mobile application (app) for mobile devices iOS, Android called "JustSchool - English online", which is provided by the Company to the User (Subject of personal data) for temporary use (during the term of this Agreement) for the functional purpose of the end user as a tool for obtaining access to the Company's services;
   The platform – is a technological platform in the form of an interconnected set of computer programs and electronic data in the form of numbers, letters, symbols, images and their combinations (including graphic information, video information, etc.), which is intended for automated monitoring, provision and/or receipt of Services, collection, processing, distribution, storage, providing data on Orders placed on it by Users and Service offers placed by the Company, providing evaluations, etc. The Platform is the result of computer programming belonging to software products;
   User – is any person who visits the Website and/or Mobile Application for any purpose.
   Parties – Company and/or Rightholder and User.
   Legislation of Ukraine a system of laws and other normative acts adopted by the Verkhovna Rada of Ukraine and higher executive bodies, — resolutions of the Verkhovna Rada, decrees of the President of Ukraine, resolutions and decrees of the Cabinet of Ministers of Ukraine, as well as norms of international legal acts , treaties, agreements, conventions, protocols, consent to the bindingness of which has been granted by the Verkhovna Rada of Ukraine.
   Personal data is information or a set of information about a natural person who is identified or can be specifically identified, any information that directly or indirectly refers to a specific User. This can be: first name, last name, patronymic (if available), information about the type of activity, marital status, education, e-mail address, phone number, region of residence, address of the place of residence/stay, information about the User's actions on On the website and/or in the Mobile application, IP address, device data (computer, browser type, mobile device operating system) used by the User, messages (information contained in the correspondence between the Users and the Company), other information with the help of which communication is carried out, which, at the request of the User, is provided by him in the registration form and/or when filling out his own Account on the Website and/or in the Mobile application, when passing survey (by filling out a questionnaire or in another way), writing a message or feedback, or information received during oral communication between the User and the Company, etc.The information provided when making payment and/or using any service (service) provided by the Company by the User may include the recording of one or more cookies or anonymous identifiers.
   Cookies are files created by websites visited by the User. They make your web experience easier by saving your browsing information. With the help of cookies, you will be able to keep your account on the websites, save the settings of the Website and/or Mobile Application and display the relevant content.
   Personal data database is a named collection of organized personal data in electronic form and/or in the form of personal data files.
   The owner of the personal data base is a natural or legal person who is authorized by law or with the consent of the subject of personal data to process this data, which approves the purpose of processing personal data in this database, establishes the composition of this data and procedures their processing, unless otherwise determined by law.
   Responsible person is a designated person who organizes the work related to the protection of personal data during their processing, in accordance with the law;
   The consent of the subject of personal data is a voluntary expression of the will of a natural person (provided he is informed) regarding the granting of permission for the processing of his personal data in accordance with the stated purpose of their processing, expressed in writing or in a form that enables conclusion on granting consent.
   Processing of personal data is any action or set of actions performed in whole or in part in the information (automated) system and/or personal data files, which are related to the collection, registration, accumulation, storage, adaptation , change, renewal, use and distribution (distribution, implementation, transfer), depersonalization, destruction of information about a natural person.
   Depersonalization of personal data extraction of information that allows for the identification of a person.
   The administrator of the personal data base is a natural or legal person who is authorized by the owner of the personal data base or by law to process this data. A person who is instructed by the owner and/or manager of the personal data base to carry out technical work with the personal data base without access to the content of personal data is not a manager of the personal data base.
   Personal data subject is a natural person whose personal data is processed in accordance with the law.
   Third party is any person, with the exception of the subject of personal data, the owner or manager of the personal data base and the authorized state body for the protection of personal data, to whom the owner or manager of the personal data base transfers personal data, respectively to the law
2. General provisions
   1. This Policy is mandatory for application by the responsible person and employees of the Company who directly process and/or have access to personal data in connection with the performance of their official duties.
   2. Data processing means any action with Data, including, but not limited to: access, provision, distribution, collection, systematization, storage, accumulation, recording, transmission, blocking, deletion, clarification, updating and/or modification , depersonalization and other ways of using Data by the Company.
   3. The Administrator of the Data is JUSTSPEAK LTD.
   4. The User, having registered on the Website and/or in the Mobile application, enters his personal data and/or provides this Data in another way, and/or performing any actions within the Website and/or using any - which part of the Website and/or Mobile application, by giving consent - activated the "continue" ("register") button and/or activated (clicked) the "checkout" button order" through the form of the Website and/or Mobile Application (tick) and/or independently enters the Data, expresses his agreement with the provisions of this Policy and provides JUSTSPEAK LTD, as well as third parties who provide services to JUSTSPEAK LTD, including but not limited to , processing payments, providing financial services, permission to process own personal data.
   5. Users may provide Data independently by posting such data on the Website and/or in the Mobile Application or by notifying via telephone channels and/or to the Company's email and/or postal address, by filling out questionnaires (filling out a questionnaire or in another way), or Data may be provided from other sources (in accordance with this Policy), for example, from User reviews (rating, comments, confirmation of information) or other information from third parties provided in the course of submitting claims, complaints and/or when considering disputes, and/or information from well-known sources on the Internet.
   6. The Company does not process data revealing racial, ethnic origin, national origin, political opinions, religious, philosophical and other beliefs, membership in political parties and trade unions, public organizations, as well as data concerning health or sexual life (special categories of data). Information characterizing the physiological characteristics of Users is also not processed.
   7. The User does not have the right to use the Website and/or Mobile Application if he does not agree with the terms of this Policy.
   8. The User acknowledges that in the event of his negligence in the security and protection of his Data and authorization data (password, login), third parties may gain unauthorized access to the account and User Data. The Company is not liable for any losses caused by such Access.
   9. The terms of processing and storage of Data are determined based on the purposes of processing the Data, as well as based on the conditions specified in the documents/contracts concluded with Users in accordance with the requirements of the current legislation of Ukraine.
3. List of personal data bases
   1. The copyright holder is the owner of the following personal data bases: client personal data base.
4. The purpose of processing personal data.
   1. Collection and processing of personal data is carried out in accordance with Articles 6, 7 of the Law of Ukraine "On Personal Data Protection".
   2. The purpose of processing personal data is to ensure the implementation of civil legal relations, economic and tax relations, the provision/receipt and payment for purchased services, goods in accordance with the Tax Code of Ukraine, the Law of Ukraine "On Accounting and Financial Reporting in Ukraine", maintaining accounting and management accounting and other obligations imposed by law on the personal data controller, to protect the legitimate interests of the personal data controller or a third party to whom personal data is transferred.
   3. The purpose of processing personal data is to identify the User as a client of the Website and/or Mobile Application, to communicate with the User, including for the provision of services, supply/sale of goods, payment processing, shipping, settlement transactions, reporting, in order to improve the quality of service provision, analyze User activity, manage traffic on the Website and/or Mobile Application, analyze and predict User preferences and interests; to ensure compliance by Users with the terms of the User Agreement, the Rules for posting information on the Website and/or Mobile Application, and the Rules for publishing reviews.
   4. The purpose of processing personal data is to create and implement bonus programs, loyalty programs, send messages in the form of emails, SMS messages, notifications in the Mobile Application, notifications in the web browser, including for the purpose of sending commercial offers, in order to improve the quality of service provision, generate ratings, analyze activity, perform keyword searches, send information and marketing mailings (news, promotions, advertising campaigns, information about promotions, promotional codes and discounts, personal recommendations, personal discounts and offers), which contain information about services and/or goods, advertising and commercial offers for such services and/or goods, etc.
   5. The Company may share Data with affiliates (companies operating under common ownership) who may process and use the Data for the purposes specified in this section.
5. Procedure for processing personal data. Obtaining consent, notification of rights.
   1. The processing of personal data carried out to fulfill the purpose of processing provided for in Section 4 of these Regulations is carried out on the basis of Article 11 of the Law of Ukraine "On Personal Data Protection".
   2. The processing of personal data is carried out on the basis of the consent of the personal data subject or in order to fulfill the offers accepted by the personal data subject.
   3. The consent of the personal data subject must be a voluntary expression of the will of an individual to grant permission to process his or her personal data in accordance with the formulated purpose of their processing. The consent of the personal data subject may be provided in the following forms:
      a document on paper with details that allow identifying this document and the individual;

      an electronic document that must contain mandatory details that allow identifying this document and the individual.

      Voluntary expression of will of an individual to grant permission for the processing of his personal data, if possible, certified by the electronic signature of the subject of personal data.

      a mark on the electronic page of a document or in an electronic file processed in an information system based on documented software and technical solutions, including through the form of the Website and/or Mobile Application (checkmark), or by activating (clicking) the "Accept" button.
   4. Notification of the subject of personal data about the inclusion of his personal data in the personal data database, about the rights defined by the Law of Ukraine "On Personal Data Protection", about the purpose of data collection and the persons to whom his personal data is transferred is carried out during the registration of civil legal relations in accordance with current legislation.
6. The data that may also be collected.
   1. The Company may also collect the following Data:
      information about the User's account, login and password, phone number, email address, other Data necessary to provide services to Users of the Website and/or Mobile Application, communication with Users, including in the process of the User contacting the support service of the Website and/or Mobile Application;

      information that Users provide to the Company when concluding contracts for the provision of services/purchase and sale of goods and/or services by accepting a public offer posted on the Website and/or Mobile Application;

      information necessary for communication between Users and the Company on the Website and/or in the Mobile Application, including for making and confirming transactions, receiving and sending messages, posting reviews, comments, making payments, for fulfilling requests from Users and receiving feedback from Users if necessary, information posted by Users based on the results of their service, reviews, comments, contacting customer support, complaints, claims, other requests;

      data about devices used by Users, information about Users' Websites and/or their mobile data (in case the User uses Mobile Applications) such as: IP address; date and time when the User uses the Website and/or Mobile Application, information about the software, as well as the Internet browser used by the User, information about the operating system of the mobile device, information about the operation of the User's devices, individual identifiers of devices used by Users;

      information about the User's actions on the Website and/or Mobile Application (consumer behavior regarding purchased services, goods on the Website and/or Mobile Application);

      information posted or provided by the User during their participation in bonus programs, promotions, special offers organized by the Company;

      information received from Users by filling out questionnaires or otherwise communicated to the Company;

      information received by the Company in a lawful manner from partners and/or third parties;

      Cookies.
7. Personal data protection: methods of protection, responsible person, employees of the Owner of the personal data base, storage period of personal data.
   1. The personal data base is equipped with system and software and hardware and communication means that prevent loss, theft, unauthorized destruction, distortion, forgery, copying of information and meet the requirements of national and international standards.
   2. The responsible person organizes work related to the protection of personal data during their processing, in accordance with the law. The responsible person is determined by the order of the Owner of the personal data base. The responsibilities of the responsible person regarding the organization of work related to the protection of personal data during their processing are specified in this policy and in the order.
   3. The responsible person is obliged to:
      know the legislation of Ukraine in the field of personal data protection;

      develop procedures for access to employees' personal data in accordance with their professional or official or labor duties;

      ensure that employees of the Owner of the personal database comply with the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regulating the activities of the Owner of the personal database regarding the processing and protection of personal data in personal databases;

      comply with and monitor compliance by other employees of the Owner of the personal database with the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regulating the activities of the Owner of the personal database regarding the processing and protection of personal data in personal databases;

      notify the Owner of the personal database of facts of violations of the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regulating the activities of the Owner of the personal database regarding the processing and protection of personal data in personal databases immediately but no later than one business day from the moment such violations are detected;

      ensure the storage of documents confirming the personal data subject's consent to the processing of their personal data (regardless of the form of such consent) and notification of the specified subject of his rights.
   4. In order to fulfill his duties, the responsible person has the right:
      to receive the necessary documents, including orders and other administrative documents issued by the Owner of the personal data base, related to the processing of personal data;

      to make copies of the received documents, including copies of files, any records stored in local computer networks and autonomous computer systems;

      to participate in the discussion of the duties performed by him to organize work related to the protection of personal data during their processing;

      to submit for consideration proposals for improving activities and improving work methods, to submit comments and options for eliminating identified shortcomings in the process of processing personal data;

      to sign and endorse documents within the scope of his competence.
   5. Employees who directly process and/or have access to personal data in connection with the performance of their official (labor) duties are obliged to comply with the requirements of the legislation of Ukraine in the field of personal data protection and internal documents of the Owner of the personal data base, regarding the processing and protection of personal data, and in case of violation by them of the requirements of the Law of Ukraine "On Personal Data Protection" they are liable in accordance with the legislation of Ukraine.
   6. Personal data should not be stored longer than is necessary for the purpose for which such data is stored.
   7. To determine the appropriate storage period, the Company determines the nature and category of personal data, the purposes for which it processes them, and whether it can achieve these purposes by other means. As a rule, the term for processing personal data is no more than 2555 days from the date of submission of tax reports for the period during which the relevant transaction took place. The specified processing time complies with the provisions of the Tax Code of Ukraine on the conditions for storing documents related to the accrual and payment of taxes and fees.
   8. Personal data must be deleted or destroyed from personal data bases in cases established by the legislation of Ukraine and/or international law.
   9. Personal data are stored no longer than is necessary for their processing.
   10. The Company makes changes to personal data at your request if these data are unreliable, inaccurate or outdated.
8. Rights of the personal data subject.
   1. The personal data subject has the right:
      to know about the location of the personal data base containing his personal data, its purpose and name, location and/or place of residence of the owner or administrator of this base or to give a corresponding instruction to obtain this information to persons authorized by him, except for cases established by law;

      to receive information about the conditions for providing access to personal data, in particular information about third parties to whom his personal data contained in the relevant personal data base are transferred;

      to access his personal data contained in the relevant personal data base;

      to receive no later than 30 (thirty) calendar days from the date of receipt of the request, except for cases provided for by law, a response on whether his personal data are stored in the relevant personal data base, as well as to receive the content of his personal data that is stored;

      to submit a reasoned request to change or destroy their personal data to any owner and administrator of this database, if these data are processed illegally or are inaccurate;

      to submit a reasoned request to object to the processing of their personal data by state authorities, local self-government bodies in the exercise of their powers provided for by law;

      to protect their personal data from illegal processing and accidental loss, destruction or damage;

      to address issues of protecting their rights regarding personal data to state authorities, local self-government bodies, whose powers include the protection of personal data. To apply all possible legal remedies in case of violation of the legislation on personal data protection.
9. Procedure for processing requests of the subject of personal data.
   1. The subject of personal data has the right to receive any information about himself from any subject of relations related to personal data, without specifying the purpose of the request, except for cases established by law.
   2. The subject of personal data has access to data about himself free of charge.
   3. To obtain any personal data about himself, the subject of personal data submits a request for access (hereinafter referred to as the request) to the owner of the personal data base.
   4. The request shall indicate:
      surname, first name and patronymic, place of residence/stay and details of the document certifying the identity of the subject of personal data;

      other information that allows identifying the person of the subject of personal data;

      list of personal data requested;

      information about the personal data base in respect of which the request is submitted, or information about the owner or manager of this base.
   5. The term for examining the request for its satisfaction may not exceed 10 (ten) working days from the date of its receipt. Within this period, the owner of the personal data base shall inform the subject of personal data whether the request will be satisfied or the relevant personal data shall not be provided, indicating the grounds provided for in the relevant regulatory legal act.
   6. The request shall be satisfied within 30 (thirty) calendar days from the date of its receipt, unless another term is provided for by law.
10. Disclosure of personal data to third parties.
    1. The procedure for accessing personal data of third parties is determined by the terms of this policy and the terms of the consent of the personal data subject provided to the personal data database owner to process this data, in order to fulfill the obligations assumed to the personal data subject or in accordance with the requirements of the law.
    2. Access to personal data is not provided to a third party if the specified person refuses to assume obligations to ensure compliance with the requirements of the Law of Ukraine "On Personal Data Protection" or is unable to provide them.
    3. The subject of relations related to personal data who wishes to receive any personal data submits a request for access (hereinafter referred to as the request) to personal data to the personal data database owner.
    4. The request shall indicate:
       surname, first name and patronymic, place of residence (place of stay) and details of the document certifying the individual submitting the request (for an individual - the applicant);

       name, EDRPOU code, location of the legal entity submitting the request, position, last name, first name and patronymic of the person signing the request (for a legal entity - the applicant);

       confirmation that the content of the request corresponds to the powers of the legal entity (for a legal entity - the applicant);

       last name, first name and patronymic, as well as other information that allows identifying the individual in respect of whom the request is made;

       identifying the individual in respect of whom the request is made;

       list of personal data requested;

       information about the personal data database in respect of which the request is submitted, or information about the owner or administrator of this database;

       purpose of the request.
    5. The term for examining a request for its satisfaction may not exceed 10 (ten) business days from the date of its receipt. During this term, the owner of the personal data base shall inform the person submitting the request whether the request will be satisfied or the relevant personal data shall not be provided, indicating the grounds provided for in the relevant regulatory legal act.
    6. The request shall be satisfied within 30 (thirty) calendar days from the date of its receipt, unless otherwise provided by law.
    7. Postponement of access to personal data of third parties is allowed if the necessary data cannot be provided within 30 (thirty) calendar days from the date of receipt of the request. In this case, the total term for resolving the issues raised in the request may not exceed 45 (forty-five) calendar days.
    8. The notice of postponement shall be notified to the third party who submitted the request in writing, with an explanation of the procedure for appealing such a decision.
    9. The notice of postponement shall indicate:
       the last name, first name and patronymic of the official;

       the date of sending the notice;

       the reason for the postponement;

       the period within which the request will be satisfied.
    10. Refusal of access to personal data is allowed if access to them is prohibited by law.
    11. The notice of refusal shall indicate:
        the last name, first name and patronymic of the official who refuses access;

        the reason for the refusal.
    12. The decision to postpone or refuse access to personal data may be appealed to the authorized state body for personal data protection, other state authorities and local self-government bodies whose powers include the protection of personal data, or to the court.
    13. The Company reserves the right, in accordance with the requirements of the current legislation of Ukraine, to exchange Data with state authorities for the purpose of: preventing fraud; resolving disputes and clarifying circumstances that are/may cause a violation of current legislation, as well as in the event that the Company detects unlawful actions of Users of the Website and/or Mobile Application and/or receives claims, complaints, and appeals from third parties.
11. Changing/deleting of data or withdrawal of consent
    1. Users may at any time change/delete personal information or refuse to receive messages, or withdraw consent to the processing of personal data through their Account or by sending a request to the email address support@justschool.me.
    2. Upon receipt of such a notification, the processing of the User's personal data will be terminated, and his personal data will be deleted, except in cases where such processing may be necessary in accordance with the current legislation of Ukraine.
    3. The functioning of some features of the Website and/or Mobile Application, for which information about the User is required, may be terminated from the moment of change/deletion of the Data.
12. Other conditions
    1. The Company reserves the right to change the terms of this Policy at any time. In such case, the updated version will be posted on the relevant page of the Website. If the User does not agree with the changes, he undertakes to immediately cease any use of the Website and/or Mobile Application.
    2. The Company is not liable for any harm or losses suffered by the User or third parties as a result of a misunderstanding or misunderstanding of the terms of this Policy.
    3. If the provisions of this Policy, items or parts thereof are recognized as contrary to the current legislation of Ukraine, or as invalid, this fact will not in any way affect the other provisions of this Policy, they remain fully valid and continue to operate in full and are valid, and any invalid provision or provision that cannot be enforced shall be amended by the Copyright Holder to the extent necessary to ensure its validity and enforceability.