PRIVACY POLICY
This Privacy Policy establishes the procedure and rules for company PASS, "PASS UA" LLC (hereinafter referred to as the Company) to process personal data and information provided by Users who visit the Company's website pass.ua, order the Company's services, and fill out registration, profile and payment forms on the pass.ua website.
The Privacy Policy (hereinafter also referred to as the Policy) defines the types of personal data collected, the purpose of using such personal data, the Company's interaction with third parties, security measures to protect personal data, the conditions for access to personal data, as well as contact information for the User to access, amend, block or destroy their personal data and to deal with any questions that may arise regarding the personal data protection practices.
If the User decides to provide the Company with his/her personal data, the Company will protect it and use it only in the ways described in this Policy.In case of disagreement with the terms of this Policy, the User should not visit the pass.ua website and perform any actions on it.1. Definitions and shortcuts
Definitions and shortcuts used in this Policy means the following:1.1. User - means any individual who visits the Company's website, orders the Company's services, fills in any registration, profile or payment forms on the Company's website1.2. Personal data - any information relating directly or indirectly to a certain or defined individual (personal data subjects).1.3. Company – PASS , "PASS UA" LLC.1.4. Site/Website – website pass.ua (https://pass.ua/).1.5. Company Services - any services offered on the Company's website, such as educational courses, access to software, information services, consulting services, etc.1.6. Personal data processing is any action or set of actions performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.1.7. Automated processing of personal data means the processing of personal data by using computer technology. Nevertheless, automated processing of personal data does not include automatic processing systems, including profiling, which create legal consequences in relation to the User, or which in a similar way significantly affect the User.1.8. Dissemination of personal data - actions aimed at disclosing personal data to an indefinite number of persons.1.9. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.1.10. Blocking personal data - is a temporary stop of processing personal data (except when processing is necessary to clarify personal data).1.11. Use of personal data means actions (operations) with personal data performed by the Company in order to make decisions or perform other actions that give rise to legal consequences in relation to the personal data subject or other persons or otherwise affect the rights and freedoms of the personal data subject or other persons.1.12. Depersonalization of personal data - actions as a result of which it becomes impossible to determine the ownership of personal data to a specific personal data subject without using additional information.1.13. Destruction of personal data - actions as a result of which it becomes impossible to restore the personal data content in the personal data information system and (or) as a result of which material storage devices of personal data are destroyed.1.14. Online platform means the Company's software, which is a set of interconnected web services and modules that make up a single space for providing services to users via the Internet.1.15. TLS (Transport Layer Security) - is a cryptographic protocol that enables secure data transfer on the Internet for navigation, receiving mail, communication, file sharing, etc.
2. User's consent to the provision of personal data and their processing by the Company
2.1. The User is acquainted with and accepts the terms of this Policy and gives the Company informed and conscious consent to the processing of his/her personal data on the terms and conditions provided for by the Policy.The User shall be deemed to have consented to the processing of their personal data when they have filled in the registration form (order), profile and/or payment form, and have marked their acquaintance and consent to this Policy.By marking the acquaintance and consent to this Policy, the User agrees to transfer to the Company all personal data that was made publicly available by indicating in the personal profile and in the profile of the relevant social network or electronic service to which the User provided a link.2.2. The User's consent to the Company's processing of his/her personal data is valid from the date of granting consent to their processing (clause 2.1 of the Policy), and for the period necessary to achieve the purposes (goal) of personal data processing (section 6 of the Policy).2.3. The User has the right to withdraw consent to the processing of personal data in the form and procedure provided for in Section 8 of the Policy.2.4. The Company assumes that by providing personal data when ordering the Company's services, filling out registration/profile forms and payment forms, the User:2.4.1. Confirms that he/she has all the necessary rights that allow him/her to obtain civil rights for himself/herself and exercise them independently, and is able to create civil obligations for himself/herself, fulfill them independently and take responsibility in case of failure to do so;2.4.3. In case of uploading his/her image, the User consents to the use of this image for purposes not related to the identification of the User free of charge. The User undertakes not to provide photographs of third parties as the User's image.2.4.4. Understands that the information provided by the User about himself/herself may become available to other Users, may be copied and disclosed by such Users in the cases and under the conditions specified in Section 7 of the Policy.
3. Personal data protection
3.1. The Company takes the necessary and appropriate legal, organizational and technical measures to protect the information provided by Users from unauthorized or accidental access, destruction, changing, blocking, copying, and disclosure, as well as from other illegal actions of third parties. However, despite its best efforts, the Company cannot guarantee absolute protection against any threats arising outside the Company's regulation.3.2. The Company uses standard operating procedures to ensure the confidentiality of personal data and performs all personal data processing operations in accordance with the EU General Data Protection Regulation ("GDPR").3.3. The Company does not sell, transfer or disclose personal data received from Users on the website to third parties without the prior consent of the User, except as provided for in this Policy.3.4. The Company provides access to information and personal data only to authorized employees, partners, contractors and suppliers of the Company who have agreed to ensure the confidentiality of such information and data in accordance with the Company's requirements.
4. Encryption TLS (Transport Layer Security):
4.1. The Company encrypts all connections and information transfers between the Company's website and the User's device using the TLS (Transport Layer Security) protocol (better known as the previous version of SSL). This prevents the interception of data entered by the User during transmission.4.2. If the website is accessed using compatible browsers, TLS (Transport Layer Security) technology protects personal information through server authentication and data encryption, ensuring the safety and security of such information during transmission. The following versions of the most common browsers are compatible with this technology: Internet Explorer (from version 11), Mozilla Firefox (from version 27), Google Chrome (from version 32) and Apple Safari (from version 7).4.3. If the User has any questions or complaints related to the security of the TLS level protection implemented on the Company's website, the Company undertakes to resolve these issues as soon as possible.
5. Personal data and information processed by the Company
5.1. The personal data of the User that may be processed by the Company include (depending on the type of services ordered, registration and/or profile forms, payment forms, etc:)
- surname, first name, patronymic;
- date of birth, gender, marital status;
- mobile phone number;
- email address;
- data of accounts in social networks and electronic services (links to the User's profiles in Facebook, Instagram, Linkedin, Google, Twitter, etc;)
- images (including photos);
- information about the place of residence;
- information about education, specialty, profession;
- information on language skills;
- information about work experience, place of work and position;
- information about current employment, hobbies and interests;
- information about the User's PC, including IP address, geographical location, browser type and version, and operating system;
- information about the User's visits and use of the Company's website, including referral sources, length of visits, pages viewed and navigation paths on the website;
- information entered when using the services of the Company's website;
- information generated by the use of the Company's website, including information about the time, frequency and conditions of its use;
- information regarding any purchases, services (forms of payment) or transactions made by the User through the Company's website, including: name, address, telephone number, e-mail address and bank/credit card information;
- information posted by the User on the Company's website for the purpose of publishing it on the Internet, including the username, profile picture and content of the publication;
- information contained in any messages sent by the User to the Company by e-mail or through the website, including the content of the message and metadata;
- other personal information provided by the User to the Company when ordering the Company's services, filling in registration and profile forms, as well as payment forms.
6. Purpose (goal) of personal data processing
The Company processes personal data of Users solely for the following purposes:
- providing services to the User, including those purchased through the Company's website;
- providing the User with the opportunity to use the services available on the Company's website;
- creating a User profile in the Company's database (including online platforms) to provide services to the User;
- establishing and maintaining connection, and communication between the User and the Company;
- providing information on ordering, paying for and receiving the Company's services, filling out registration, profile and payment forms, providing support in case of problems related to the Company's services. oviding information on ordering, paying for and receiving the Company's services, filling out registration, profile and payment forms, providing support in case of problems related to the Company's services;
- fulfilment of the Company's obligations to the User who ordered the Company's services;
- sending by the Company to the User's email address and other means of communication (telephone, private messages in social networks, apps, etc.) messages, information, files, etc. related to the provision of services by the Company, including invoices, payment reminders, and receiving payments from the Company, etc;
- sending by the Company to the User's e-mail of advertising messages;
- statistical and other research based on depersonalised information provided by the User;
- posting on social networks and the Internet in general, other advertising and information sources, for the purpose of advertising with depersonalisation of personal data.
- administration of the website and the Company's business;
- personalisation of the website for the User;
- sending non-marketing commercial messages to the User;
- sending the User an electronic newsletter, if it has been ordered (the User can notify the Company at any time that he/she no longer wishes to receive electronic newsletters);
- sending the User marketing messages regarding the Company's business activities or the business activities of carefully selected third-party companies that the Company believes may be of interest to the User, through publications or, if the User has specifically consented to this, by sending e-mail or through the use of similar technologies (the User may notify the Company at any time that he/she no longer wishes to receive marketing messages);
- providing third-party companies with statistical information about Users (however, these third-party companies will not be able to identify any individual User from this data);
- processing requests and complaints regarding the Company's website;
- to ensure the security of the Company's website and prevent fraud;
- to verify compliance with the terms and conditions governing the use of the Company's website (including monitoring of private messages sent through the private message service of the Company's website);
- and for other purposes.
7. Personal data processing
7.1. The processing of the User's personal data includes the following actions by the Company: collection, recording, systematisation, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, destruction.7.2. The User's personal data is collected in the case specified in clause 2.1 of the Policy.7.3. Personal data is stored (depending on which comes first):
- until the moment of their destruction by the Company - in case of receipt from the User of a withdrawal of consent to the processing of personal data or a request for the destruction of personal data;
- until the expiration of the consent (clause 2.2 of the Policy) or the achievement of the purposes of personal data processing.
- in cases where it is required by law;
- in connection with any current or future legal proceedings;
- in order to establish, exercise or defend the Company's legal rights (including providing information to other parties for the purpose of fraud prevention or credit risk mitigation);
- to a buyer (or potential buyer) of any business or assets that the Company sells (or intends to sell);
- to any person who, in the Company's reasonable opinion, may request a court or other authorised body to disclose such personal data and, in the Company's reasonable opinion, such court or authorised body orders the disclosure of such personal data.
- receipt of the User's withdrawal of consent to the processing of personal data, in case the User stops receiving the Company's services and using the Company's services;
- receipt of a request from the User to destroy personal data;
- expiration of the consent (clause 2.2 of the Policy).
8. User rights
The User has the right to:8.1. At its own decision, provide the Company with personal data for processing under the conditions specified in this Policy. At the same time, some of the personal data provided are necessary for the provision of services by the Company, and in case of failure to provide them, the User is not allowed to receive such services.8.2. Independently make changes and updates to their personal data, providing the relevant information to the Company, if such changes and updates contain relevant and true information.8.3. To demand from the Company to clarify his/her personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the purpose of processing, as well as to take measures provided for by law to protect his/her rights.8.4. Apply legal remedies in case of violation of personal data protection legislation.8.5. To send the Company his/her requests and demands, including regarding the use of his/her personal data, as well as withdrawal of consent to the processing of personal data. The Company shall consider the Users' Requests, respond to them and/or take the necessary actions within 30 calendar days from the date of receipt of the Request.8.6. In addition to the rights specified in this Policy, the User has the opportunity to exercise any right provided for by law
9. Cookie files
9.1. The Company's website uses cookies.9.2. Cookie — is a file containing an identification (a string of letters and numbers) that is sent by the web server to the web browser and stored by the browser. The identification is then sent back to the server each time the browser requests a web page from the server. Cookies can be either "permanent" or ""session"": permanent cookies will be stored by the browser and will be valid until the expiration date, unless deleted by the User in advance; "session" cookies, on the contrary, will be deleted after the end of the session with the site or after closing the browser.9.3. Cookies usually do not contain any information that identifies the User. However, the personal information of the User held by the Company may be linked to the information stored and received from cookies.9.4. When Comany use cookies on the Website, they may classify into any one of the following categories:
- "Strictly Necessary" cookies are necessary for the Website to function and cannot be switched off in Company's systems. They are usually only set in response to actions made by User which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
- "Analytics and Performance" cookies allow the Company to track analytics by counting visits and traffic sources so Company can measure and improve the performance of the Website. They may be set by Company or by third party providers to help Company to know which pages or videos are the most and least popular and see how visitors move around the Website.
- "Functional" cookies enable the website to provide enhanced functionality and personalization based on User's interaction with the Website. They may be set by the Company or by third party providers, such as Adobe, whose services Company have added to her pages.
- "Advertising and Targeting" cookies may be set through our Website by the Company advertising partners, such as Adobe. They may be used by those companies to build a profile of User's interests and show you relevant advertisements on other websites.
- "Social Media" cookies are set by social media services (e.g., Twitter, LinkedIn, Facebook, Instagram) that Company have added to the Website to enable User to share Company content with User's friends and networks. These cookies are capable of tracking User's browser across other websites and building up a profile of User's interests.
10. Changes to the Privacy Policy
The Company has the right to make changes and additions to this Policy from time to time and without prior notice to the User, including in the case of changes in legal requirements.