Privacy Policy

The following text of the Privacy Policy has been developed by Private Entrepreneur Furmanenko Igor Ruslanovych (hereinafter referred to as 'Legal Owner' and/or 'Company') and is addressed to an indefinite circle of individuals, Users of the Website https://justschool.me/uk and/or https://justsmart.com.ua/uk and/or the Mobile Application on the Internet, determining the procedure for obtaining, collecting, accumulating, storing, processing, using, ensuring the 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 at a network address (domain) on the Internet. The website address on the Internet is https://justschool.me/uk and/or https://justsmart.com.ua/uk.

    Mobile application a copy of a computer program in the form of a mobile application (application) for iOS, Android mobile devices called "JustSchool - English online", which is provided by the Company to the User (to the 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;

    Platform – 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, presentation of data on Orders placed on it by Users, and on Service offers placed by the Company, to provide evaluations, etc. The Platform is the result of computer programming belonging to software products;

    User - any person who visits the Website and/or the Mobile Application regardless of the purpose.

    The parties are the Company and/or Legal Owner and the User.

    Legislation of Ukraine - the system of laws and other normative acts adopted by the Verkhovna Rada of Ukraine and the highest bodies of executive power, - 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 normative legal acts, treaties, agreements, conventions , protocols, the binding consent of which was given by the Verkhovna Rada of Ukraine.

    Personal data - 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 Website and/or Mobile Application, IP address, device data (computer, browser type, mobile device operating system) used by the User, messages (information contained in correspondence between Users and the Company), other information with 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 a survey (by filling out a questionnaire or in another way), writing messages or feedback, or information received during oral communication between the User and the Company, information provided during payment and/or use by the User of any service (service) provided to the Company, and 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 internet 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 base 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 granted the right to process this data by law or with the consent of the subject of personal data, who approves the purpose of processing personal data in this database, establishes the composition of this data and the procedures for its processing, unless otherwise determined by law.

    The 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 that he is informed) regarding the granting of permission for the processing of his personal data in accordance with the formulated purpose of their processing, expressed in writing or in a form that makes it possible to conclude that consent has been given.

    Processing of personal data — any action or set of actions performed in whole or in part in the information (automated) system and/or in 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.

    Anonymization of personal data is the removal of information that makes it possible to identify 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 administrator of the personal database to carry out technical work with the personal database without access to the content of personal data is not a manager of the personal database.

    The subject of personal data is a natural person whose personal data is processed in accordance with the law.

    A 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 personal data protection, to whom the owner or manager of the personal data base transfers personal data in accordance with the law.

  2. Terms

    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 actions 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 data controller is Private Entrepreneur Furmanenko Igor Ruslanovych (RNOKPP/EDRPOU code: 3369314596).
    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 part of the Website and/or and/or Mobile application, by giving consent - activated the "continue" button ("register") and/or activated (clicked) the "place an order" button through the form of the Website and/or Mobile application ( check mark) and/or independently enters the Data, expresses his agreement with the provisions of this Policy and provides Private Entrepreneur Furmanenko Igor Ruslanovych, as well as to third parties who provide services Private Entrepreneur Furmanenko Igor Ruslanovych, including, but not limited to, processing payments, providing financial services, permission to process own personal data.
    5. Users can provide Data independently by placing such data on the Website and/or in the Mobile Application or by reporting through telephone channels and/or to the Company's email and/or postal address, by filling out questionnaires (filling in a questionnaire or in another way) , or Data may be provided from other sources (in accordance with this Policy), for example, from User feedback (ratings, comments, confirmation of information) or other information from third parties provided in the course of sending claims, complaints and/or when considering disputes, and/ or information from well-known sources on the Internet.
    6. The company does not process data related to racial, ethnic origin, nationality, political views, religious, worldview and other beliefs, membership in political parties and trade unions, public organizations, as well as data related to health or sexual life (special data categories). Information that characterizes the physiological characteristics of Users is also not processed.
    7. The User may not use the Website and/or the Mobile Application if he does not agree to the terms of this Policy.
    8. The User acknowledges that in the case of his negligent attitude to the security and protection of his Data and authorization data (password, login), third parties may gain unauthorized access to the User's account and Data. The Company shall not be liable for damages caused by such Access.
    9. Data processing and storage terms are determined based on the purposes of Data processing, as well as based on the conditions specified in the documents/agreements concluded with the Users in accordance with the requirements of the current legislation of Ukraine.
  3. List of Personal Data Databases.

    1. Legal Owner is the owner of the following personal data databases: customer personal data base.
  4. Purpose of personal data processing.

    1. Collection and processing of personal data are 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 and legal relations, economic and tax relations, providing/receiving and making payments for purchased services, goods According to the Tax Code of Ukraine and the "Law of Ukraine on Accounting and Financial Reporting", keeping accounting and management records and other duties assigned by law to the owner of personal data, to protect the legitimate interests of the owner of personal data 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, for communication with the User, including for the provision of services, supply/sale of goods, payment processing, shipping, settlement operations, reporting, with the aim of improving the quality of service provision, analyzing the activity of Users, managing traffic on the Website and/or in the Mobile application, analyzing and forecasting the preferences and interests of Users; to ensure compliance by Users with the terms of the User Agreement, the Rules for posting information on the Website and/or in the Mobile application, the Rules for publishing reviews.
    4. The purpose of processing personal data is the creation and implementation of bonus programs, loyalty programs, sending 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, with the aim of improving the quality providing services, forming ratings, analyzing activity, performing keyword searches, sending informational and marketing newsletters (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 regarding such services and/or goods, etc.
    5. The Company may exchange Data with affiliates (companies operating under common ownership) who may process and use the Data for the purpose specified in this section.
  5. The procedure for processing personal data. Obtaining consent, notice of rights.

    1. The processing of personal data, carried out to achieve the purpose of processing as provided for in Section 4 of this Regulation, is based on Article 11 of the Law of Ukraine 'On Personal Data Protection'.
    2. Processing of personal data is carried out on the basis of the consent of the subject of personal data or for the fulfillment of offers accepted by the subject of personal data.
    3. The consent of the subject of personal data must be a voluntary expression of the individual's will to grant permission for the processing of his personal data in accordance with the formulated purpose of their processing. The consent of the subject of personal data can be given in the following forms:

      • a document on a paper medium with requisites, which makes it possible to identify this document and the natural person;
      • an electronic document, which must contain mandatory details that allow identification of this document and a natural person. A natural person's voluntary declaration of consent to the processing of his/her personal data is, 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 being processed within the information system based on documented software and technical solutions, including through the website and/or mobile application interface (checkmark), or through the activation (press) of the 'Accept' button..
    4. Notification of the subject of personal data about the inclusion of his personal data in the personal data base, about the rights defined by the Law of Ukraine "On the Protection of Personal Data", 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, respectively to the current legislation.
  6. 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, e-mail address, other Data necessary for providing services to Users of the Website and/or Mobile Application, communication with Users, including in the process of the User contacting the Web support service website and/or Mobile application;
      • information that Users provide to the Company when concluding contracts for the provision of services/purchase of goods and/or services by accepting a public offer posted on the Website and/or in the Mobile Application;
      • information that is necessary for communication between Users and the Company on the Website and/or in the Mobile application, including for the execution and confirmation of agreements, 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, appeals to the customer support service, complaints, claims, other appeals;
      • 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 the devices used by the 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 legal manner from partners and/or third parties;
      • Cookies files.
  7. Protection of personal data: methods of protection, responsible person, employees of the Owner of the personal data base, period of storage of personal data.

    1. The personal data base is equipped with system and software and communication tools 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 the 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 database. The duties 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 personal data of employees in accordance with their professional or official or labor duties;
      • to ensure that the employees of the Owner of the personal data base 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 data base regarding the processing and protection of personal data in personal data bases;
      • to observe and monitor compliance by other employees of the Personal Database Owner with the requirements of Ukrainian legislation in the field of personal data protection and internal documents regulating the activities of the Personal Database Owner regarding the processing and protection of personal data in personal data bases;
      • notify the Owner of the personal data base of the 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 data base regarding the processing and protection of personal data in the personal data bases immediately but no later than one working day after the discovery of such violations;
      • ensure the storage of documents confirming that the subject of personal data has consented to the processing of his personal data (regardless of the form of such consent) and notification of the specified subject about 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;
      • make copies of 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 in the organization of work related to the protection of personal data during their processing;
      • submit for consideration proposals for improving activities and improving work methods, submit comments and options for eliminating identified deficiencies in the process of personal data processing;
      • to sign and certify documents within their competence.
      • 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 database, regarding processing and protection of personal data, and in case they violate the requirements of the Law of Ukraine "On the Protection of Personal Data", they are responsible according to the legislation of Ukraine.
      • Personal data shall not be stored longer than is necessary for the purpose for which such data is stored.
      • 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 of personal data processing 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 corresponds to the provisions of the Tax Code of Ukraine on the conditions for storing documents related to the calculation and payment of taxes and fees.
      • Personal data must be deleted or destroyed from personal data bases in cases established by the legislation of Ukraine and/or international legislation.
      • Personal data is stored no longer than is necessary for their processing.
      • The company makes changes at your request to personal data if these data are unreliable, inaccurate or out of date.
    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 database, regarding processing and protection of personal data, and in case they violate the requirements of the Law of Ukraine "On the Protection of Personal Data", they are responsible according to the legislation of Ukraine.
    6. Personal data shall 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 of personal data processing 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 corresponds to the provisions of the Tax Code of Ukraine on the conditions for storing documents related to the calculation 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 legislation.
    9. Personal data is stored no longer than is necessary for their processing.
    10. The company makes changes at your request to personal data if these data are unreliable, inaccurate or out of date.
  8. Rights of the subject of personal data.

    1. The subject of personal data has the right to:
      • to know the location of the personal database that contains his personal data, its purpose and name, the location and/or place of stay of the owner or administrator of this database or to give the appropriate instructions for obtaining 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 your 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 in cases provided by law, an answer on whether his personal data is stored in the relevant personal data base, as well as to receive the content of his personal data that is stored;
      • make a reasoned demand for the change or destruction of your personal data by any owner and administrator of this database, if these data are processed illegally or are unreliable;
      • submit a reasoned demand with an objection to the processing of your personal data by state authorities, local self-government bodies in the exercise of their powers provided for by law;
      • to protect your personal data from illegal processing and accidental loss, destruction or damage;
      • to apply for the protection of one's rights regarding personal data to state authorities, local self-government bodies, whose powers include the protection of personal data. Apply all possible means of legal protection in case of violation of the legislation on the protection of personal data.
  9. Procedure for processing personal data subject requests.

    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 access of the subject of personal data to data about himself is free of charge.
    3. The subject of personal data in order to obtain any personal data about himself submits a request for access (hereinafter - a request) to the owner of the personal data base.
    4. The request states:
      • last name, first name and patronymic, place of residence/residence and details of the document certifying the identity of the subject of personal data;
      • other information that makes it possible to identify the person of the subject of personal data;
      • list of requested personal data
      • 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 of examining the request for its satisfaction cannot exceed 10 (ten) working days from the date of its receipt. Currently, the owner of the personal data base notifies the subject of personal data whether the request will be granted or whether the relevant personal data are not subject to provision, indicating the basis provided for in the relevant regulatory legal act.
    6. The request is satisfied within 30 (thirty) calendar days from the date of its receipt, unless another term is provided by law.
  10. Disclosure of information about personal data to third parties.

    1. The procedure for access to the personal data of third parties is determined by the terms of this policy and the terms of the consent of the subject of personal data, given by the owner of the personal data base to the processing of this data, in order to fulfill the obligations to the subject of personal data or in accordance with the requirements of the law.
    2. Access to personal data is not granted to a third party if the specified person refuses to undertake obligations to ensure the fulfillment of the requirements of the Law of Ukraine "On the Protection of Personal Data" or is unable to ensure them.
    3. The subject of relations related to personal data, who wishes to receive any personal data, submits a request for access (hereinafter - a request) to personal data to the owner of the personal data base.
    4. The request states:
      • surname, first name and patronymic, place of residence (place of stay) and details of the document certifying the natural person submitting the request (for a natural person, the applicant);
      • name, EDRPOU code, location of the legal entity submitting the request, position, surname, 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 authority of the legal entity (for a legal entity, the applicant);
      • surname, first name and patronymic, as well as other information that makes it possible to identify the natural person in respect of whom the request is made;
      • list of requested personal data;
      • information about the database of personal data, in relation to which the request is submitted, or information about the owner or manager of this database;
      • the purpose of the request.
    5. The term of examining the request for its satisfaction cannot exceed 10 (ten) working days from the date of its receipt. During this period, the owner of the personal data base informs the person who submits the request whether the request will be satisfied or whether the relevant personal data are not subject to provision, indicating the basis provided for in the relevant regulatory legal act.
    6. The request is satisfied within 30 (thirty) calendar days from the date of its receipt, unless otherwise provided by law.
    7. Delay 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. At the same time, the total term for solving the issues raised in the request cannot exceed 45 (forty-five) calendar days.
    8. The notice of postponement is brought to the attention of 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 states:
      • surname, first name and patronymic of the official;
      • the date of sending the message;
      • the reason for the postponement;
      • the period during which the request will be granted.
    10. Refusal of access to personal data is allowed if access to it is prohibited by law.
    11. The notification of refusal shall state:
      • last name, first name, patronymic of the official who refuses access;
      • reason for refusal.
    12. The decision to delay or deny 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 a 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: fraud prevention; settlement of disputed situations and clarification of circumstances that are/may be the cause of violation of the current legislation, as well as in case of detection by the Company of illegal actions of Users of the Website and/or Mobile Application and/or receipt of claims, complaints, appeals of third parties.
  11. Change/removal of data or withdrawal of consent

    1. Users can 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 e-mail address support@justschool.me / support@justsmart.com.ua .
    2. After receiving such notification, the processing of the User's personal data will be stopped, and his personal data will be deleted, except when 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 the Data is changed/deleted.
  12. Other conditions

    1. The Company reserves the right to change the terms of this Policy at any time. In this case, the updated version will be posted on the corresponding page of the website. In the event that the User does not agree with the changes, he undertakes to immediately stop any use of the Website and/or the Mobile Application.
    2. The Company is not responsible for damage or losses suffered by the User or third parties as a result of misunderstanding or misunderstanding of the terms of this Policy.
    3. In the event that the provisions of this Policy, clauses or their parts, 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 are fully valid, and any invalid or unenforceable provision shall be modified by Legal Owner to the extent necessary to ensure its validity and enforceability.

Version from "25" January 2024.