Privacy Policy

  • The use of the Website(s) and entering into relationships for obtaining or purchasing free or paid services from the Operator signifies the User’s unconditional consent to this Policy and the conditions for processing their personal data as stated herein. If the User disagrees with these terms, they should refrain from using the Website(s) and not engage or continue any relationships with the Operator.
  • Personal Data Processing Policy
  • This Personal Data Processing Policy (hereinafter referred to as “Policy”) is developed in accordance with the California Consumer Privacy Act (CCPA). This Policy is issued and applied by Olha Novikova (hereinafter referred to as “Operator”) in accordance with the “Personal Data Protection Act” concerning all information that the Operator may receive about the user during their use of the Websites (hereinafter referred to as “Websites”). It governs any form of processing personal data and personal information (any information that allows identification and any other related information) about individuals who are consumers of the Operator’s products or services. This Policy applies to the processing of personal data collected by any means, both active and passive, both via the Internet and without its use, from individuals located anywhere in the world.
  • All issues related to the processing of personal data not regulated by this Policy are resolved in accordance with applicable California laws on personal data.
  • 1. Personal Information of Users Collected and Processed by the Websites
  • 1.1. For the purposes of this Policy, “personal data of the user” (subject of personal data) refers to:
  • 1.1.1. Personal information provided by the user to Olha Novikova independently when submitting an application, making a purchase, registering (creating an account), or through other processes of using the Websites, including: surname, first name; mobile phone number; email address.
  • 1.1.2. Data automatically transmitted by the Websites during their use through software installed on the user’s device, including IP addresses, cookie information, information about the user’s browser (or other program used to access the site), access time, requested page address, and other data about visitors from traffic statistics services, geolocation data, and other data automatically collected and processed on websites owned by the Operator.
  • This data is collected to understand the actions of visitors on the site to improve its content and functionality, thereby creating quality content and services for visitors.
  • The subject of personal data can change their browser settings at any time to block all cookies or alert them when cookies are sent. However, this may affect the functionality and services of the Websites.
  • 1.1.3. In addition to the information specified in clauses 1.1.1-1.1.2 of this Policy, the Operator also records data on purchases made by the subject of personal data on the Websites.
  • 1.2. This Policy applies only to the Websites, and the Operator (administrator of the Websites) does not control and is not responsible for third-party websites that the user may access via links available on the Websites. On such resources, other personal information may be
  • collected or requested from the user, and other actions unrelated to the Operator may be performed.
  • 1.3. The Websites generally do not verify the accuracy of personal information provided by users and do not control their legal capacity. The Operator, who administers the Websites, assumes that the user provides accurate and sufficient personal information on the matters offered in the forms on the Websites and keeps this information up to date.
  • 2. Purposes of Collecting and Processing Users’ Personal Information
  • 2.1. The Website collects and stores only the personal data necessary for providing services and/or delivering other value to visitors (subjects of personal data).
  • 2.2. The Operator has the right to use the user’s (subject of personal data) personal information for the following purposes:
  • 2.2.1. Identification of the party within agreements and contracts with the Website and the Operator.
  • 2.2.2. Providing personalized services, services, and other values to the user.
  • 2.2.3. Communication with the user, including sending notifications, requests, and information about the use of the Website, providing services, and processing requests and applications from the user.
  • 2.2.4. Improving the quality of the Website, its usability, and the development of new services and products.
  • 2.2.5. Targeting informational materials.
    2.2.6. Conducting statistical and other studies based on provided data.
  • 2.2.7. Conclusion, execution, and termination of civil law contracts with individuals, legal entities, individual entrepreneurs, and other persons as provided by current law.
  • 2.2.8. Detection, prevention, mitigation, and investigation of fraudulent or other illegal activities against the Operator.
  • 3. Conditions for Processing Users’ Personal Information and its Transfer to Third Parties
  • 3.1. The Website generally does not verify the accuracy of personal information provided by users and does not control their legal capacity. The Operator assumes that the user provides accurate and sufficient personal information in the forms of these online resources and maintains this information in an up-to-date state (clause 1.3).
  • 3.2. The confidentiality of the user’s personal information is maintained, except in cases where the user voluntarily provides information about themselves for general access to an unlimited number of people.
  • 3.3. The Website has the right to transfer the user’s personal information to third parties in the following cases:
  • 3.3.1. The user has expressed their consent to such actions by providing personal data;
  • 3.3.2. The transfer is necessary as part of the user’s use of certain Websites or for providing services, values, and/or delivering a service to the user;
  • 3.3.3. The transfer is provided for by Californian or other applicable law within the established legal procedure;
  • 3.3.4. To ensure the possibility of protecting the rights and legitimate interests of the Website or third parties in cases where the user violates the Website Use Agreement.
  • Thus, the Operator does not disclose or distribute personal data to third parties without the consent of the subject of personal data, except as expressly provided by current law and this Policy. In particular, the Operator transfers the User’s personal data to third parties to provide services (e.g., training on the Getcourse platform), adhering to the provisions of this Policy and taking measures for their preservation.
  • 3.4. When processing personal data of Website users, the Operator is guided by California law. 3.5. The processing of personal data is organized by the Operator based on the principles of:
  • 3.5.1. Legality of the purposes and methods of processing personal data, integrity, and fairness in the Operator’s activities;
  • 3.5.2. Accuracy of personal data, their sufficiency for processing purposes, and inadmissibility of collecting personal data excessive concerning the purposes stated during data collection;
  • 3.5.3. Processing only personal data that meet the purposes of their processing;
  • 3.5.4. Compliance of the content and volume of processed personal data with the declared purposes of processing. The processed personal data must not be excessive relative to the declared purposes of their processing;
  • 3.5.5. Inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
  • 3.5.6. Ensuring the accuracy of personal data, their sufficiency, and, where necessary, relevance concerning the purposes of personal data processing. The Operator takes the necessary measures or ensures their adoption to remove or clarify incomplete or inaccurate data;
  • 3.5.7. Storing personal data in a form that allows determining the subject of personal data no longer than required by the purpose of processing personal data.
  • 3.6. The processing of personal data is carried out by the Operator during the period necessary to fulfill the purposes for which they were collected by any legal means, including in personal data information systems using automation tools or without the use of such tools (mixed processing) via the Internet. In any case, the user’s personal data are stored and processed no longer than 10 (ten) years from the moment the user consents to their processing.
  • 3.7. All personal data is provided (collected) directly from the user as the subject of personal data.
  • The subject of personal data independently decides whether to provide their personal data and consents to their processing by the Operator freely, by their will, and in their interest.
  • 3.8. The consent mentioned in clause 3.7. of this Policy also implies the user’s consent to the transfer of their personal data to third parties, for the assignment of processing such data by third parties, as well as the user’s consent to the cross-border transfer of these data via the Internet (when such transfer is necessary for the effective provision of services by the Operator or necessary to achieve other purposes established by this Policy), as well as for receiving email and SMS mailings as part of the contract for service provision concluded with the Operator or to receive advertising and marketing materials.
  • In this context, cross-border data transfer means transferring data to third parties both in countries with an adequate level of data protection and in those not belonging to such countries. The necessary level of personal data protection is ensured by the Operator by complying with the conditions specified in section 5 of this Policy.
  • 3.9. The consent for processing personal data is given by the user when filling out special subscription forms on the Operator’s website, when applying for free services from the Operator (registration for a webinar, etc.), concluding the relevant service agreement (public offer), or directly when paying for services under the contract (accepting the public offer) by checking the box confirming consent to personal data processing in a special “checkbox.” This action has the legal force of written consent.
  • 3.10. In certain cases, specifically stipulated in the Operator’s local acts, the user provides personal data in another way (as opposed to those specified in clause 3.9 of this Policy). For example, when filling out application forms for specific types of services, submitting a request for a refund of services paid to the Operator, the user provides personal data to the Operator by sending an email to: [Operator’s Email]. In cases where data different from those listed in clause 1.1 of this Policy is transferred, the user separately expresses consent to process the additionally provided data.
  • 4. User’s Modification of Personal Information
  • 4.1. The user can change (update, supplement) their provided personal information or part of it at any time, as well as adjust its confidentiality settings by sending a request to the Operator- owner of the Websites at bt.mosendz@gmail.com.
  • 4.2. The user can withdraw their consent to personal data processing at any time by sending a request to the administration at bt.mosendz@gmail.com.
  • 5. Measures to Protect Users’ Personal Information
  • 5.1. In processing personal data, the Operator applies legal, organizational, and technical measures to ensure the security of personal data in accordance with California law.
  • Security of personal data is achieved, in particular, through:
  • 5.1.1. Assessing the effectiveness of personal data security measures before their implementation;
  • 5.1.2. Detecting unauthorized access to personal data and taking measures to prevent recurrence;
  • 5.1.3. Restoring personal data modified or destroyed due to unauthorized access;
  • 5.1.4. Establishing access rules to personal data processed in the personal data information system and ensuring the registration and accounting of all actions performed with personal data in the information system;
  • 5.1.5. Checking the inclusion of confidentiality provisions in contracts concluded by the Operator with third parties and including them when necessary;
  • 5.1.6. Controlling personal data security measures and the level of protection of personal data information systems.
  • 5.2. Third parties who have gained access to personal data on behalf of the Operator are obligated to take necessary organizational and technical measures to ensure the confidentiality of such information on their personal devices from which personal data is processed.
  • 5.3. Interaction with regional executive bodies on issues of processing and protecting personal data subjects, whose personal data is processed by the Operator, is carried out within the framework of California law.
  • 5.4. The Operator is obliged to immediately cease processing personal data upon the request of the data subject as specified in the “Personal Data Protection Act.”
  • 6. Responsible Person for Personal Data Processing
    6.1. The person responsible for personal data processing is the Operator personally. 6.2. In their activities, the responsible person:
  • 6.2.1. Conducts internal control over the compliance of the Operator, its employees, and contractors with California laws, to which they have access from the Operator, including personal data protection requirements.
  • 6.2.2. Controls the receipt and processing of inquiries and requests from personal data subjects.
  • 6.2.3. Takes measures to identify unauthorized access to personal data and immediately implements personal data protection measures.
  • 6.2.4. Maintains continuous control over the level of personal data protection.
  • 6.2.5. Familiarizes employees of the Operator who have access to personal data with California and EU personal data legislation, including personal data protection requirements, and with local acts of the Operator defining the procedure for personal data processing.
  • 6.2.6. Conducts internal control and/or audit for compliance with personal data processing in accordance with the “Personal Data Protection Act” and related legal acts, personal data protection requirements, this Policy, and other local acts of the Operator.
  • 7. User Responsibility
  • 7.1. Personal data subjects are obligated to provide only accurate personal data to the Operator and promptly notify of any changes. The Operator does not verify the accuracy of personal data and does not control the legal capacity of personal data subjects, assuming that the subject provides accurate and sufficient personal information for the questions offered in the registration form (subscription, payment) and maintains this information up to date.
  • The risk of providing inaccurate personal data lies with the personal data subject.
  • 7.2. The Operator does not knowingly process personal data of minors. The Operator recommends using the website by individuals over the age of 18. Responsibility for the actions of minors, including their purchase of services on the Websites, rests with their legal representatives. If the Operator becomes aware of having received personal information about a minor without the consent of legal representatives, such information will be deleted promptly.
  • 7.3. The Operator is not responsible for processing personal data of third parties, which the recipient of the Operator’s services reported as their own. The risk of liability in this case lies with the recipient of the services who provided inaccurate data.
  • 7.4. If the personal data subject disagrees with all or any part of this Policy, they must immediately cease using the Website and its services.
  • 8. Personal Data Storage
  • 8.1. Personal data is stored in electronic form in personal data information systems located in databases on the territory of the United States.
  • 8.2. Personal data is stored in a form that allows identification of the personal data subject for periods ensuring compliance with and achievement of the purposes of personal data processing established by this Policy.
  • 8.3. Personal data storage is carried out with restricted access, including by creating appropriate access levels.
  • 8.4. Personal data contained in different electronic databases and processed for different purposes are stored separately.
  • 9. Termination of Processing and Destruction of Personal Data
  • 9.1. In case of detection of inaccurate personal data during the appeal of the personal data subject, the Operator is obliged to block personal data related to this personal data subject from the moment of such appeal for the period of verification, provided that blocking personal data does not violate the rights and legitimate interests of the personal data subject or third parties.
  • 9.2. If the fact of inaccuracy of personal data is confirmed, the Operator, based on the information provided by the personal data subject, must clarify the personal data within 7 (seven) working days from the date of submission of such information and remove the blocking of personal data.
  • 9.3. If illegal processing of personal data is detected, the Operator, within a period not exceeding 3 (three) working days from the date of detection, must cease the illegal processing of personal data.
  • If it is impossible to ensure the legality of personal data processing, the Operator, within a period not exceeding 10 (ten) working days from the date of detection of illegal personal data processing, must destroy such personal data. The Operator is obliged to inform the personal data subject about the elimination of violations or the destruction of personal data.
  • 9.4. In the case of withdrawal by the personal data subject of consent to their processing, the Operator is obliged to cease processing and, if the storage of personal data is no longer required for the purposes of personal data processing, to destroy the personal data within a period not exceeding thirty working days from the date of receipt of the mentioned withdrawal.
  • 9.5. The Operator has the right to continue using personal data about the subject after considering the withdrawal of consent to their processing, ensuring the anonymization of such information.
  • 9.6. The Operator sends notifications about the results of consideration of requests from personal data subjects specified in this section through the support service bt.mosendz@gmail.com by sending messages to the personal data subject’s email specified in the request.
  • 10. Dispute Resolution
  • 10.1. Before filing a lawsuit regarding disputes arising from relationships between the personal data subject and the Operator, it is mandatory to file a claim (a written proposal for voluntary dispute resolution).
  • 10.2. The recipient of the claim shall notify the claimant in writing about the results of the claim review within 30 (thirty) calendar days from the date of receipt of the claim.
  • 10.3. In case of failure to reach an agreement, the dispute will be submitted to a court at the location of the Operator in accordance with applicable California law.
  • 10.4. This Policy on personal data processing and relationships between the personal data subject and the Operator are governed by applicable California law.
  • 11. Additional Conditions
  • 11.1. The Operator reserves the right to make changes to this Personal Data Processing Policy without the consent of personal data subjects.
  • 11.2. A new edition of the Personal Data Processing Policy comes into force from the moment it is posted on the Website unless otherwise provided by the new edition of the Policy.
  • 11.3. Suggestions and comments for amendments to the Personal Data Processing Policy should be sent to: bt.mosendz@gmail.com.
  • 11.4. The invalidity of individual provisions of this Policy, if recognized by a court decision or other authorized state body, does not entail the invalidity of the entire Policy.
  • 11.5. When processing personal data, the Operator does not specifically check for the presence of a special personal data processing regime established by the laws of the countries to which individual recipients of the Operator’s services or individuals who provided their data via the subscription form on the Website are subject. If the personal data subject is a resident of a state with a special personal data protection regime, such as the European Economic Area (EEA), and accesses the Website from European countries, the Operator takes all reasonable measures to ensure compliance with such data protection laws established by the respective state or group of countries (GDPR). To do this, the personal data subject must inform the Operator about the presence of a special personal data protection regime by contacting support at bt.mosendz@gmail.com.
  • 12. Operator’s Details
  • Individual Entrepreneur: Olha Novikova
  • Tax Identification Number: The Tax Identification Number (TIN) will be provided privately upon request if necessary.
    Email: Bt.mosendz@gmail.com
на головну