General Data Protection Regulation (GDPR) Privacy Notice
Last updated: October 21, 2024
This notice explains how Ulnisrak collects, uses, stores, and protects personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR). It applies to all individuals whose personal data we process in connection with our services, website, and communications.
1. Data Controller
Ulnisrak acts as the data controller for personal data collected through this website and related services. As data controller, we determine the purposes and means of processing your personal data.
You may contact us regarding any data protection matter at:
- Email: contact@ulnisrak.com
- Phone: +380689494867
- Address: Svitlohirska St, 74, Kryvyi Rih, Dnipropetrovsk Oblast, Ukraine, 50000
2. Personal Data We Collect
We collect personal data that you provide directly, data generated through your use of our services, and data received from third parties where applicable.
2.1 Data You Provide Directly
- Full name and contact details (email address, phone number)
- Account registration information
- Billing and payment information
- Communications you send to us, including support requests and feedback
- Survey responses and preferences
2.2 Data Collected Automatically
- IP address and approximate geographic location
- Browser type, version, and operating system
- Pages visited, session duration, and navigation paths
- Device identifiers and connection data
- Cookie and tracking technology data
2.3 Data From Third Parties
- Authentication data from third-party login providers where applicable
- Payment verification data from payment processors
- Analytics data from integrated third-party tools
3. Legal Bases for Processing
We process your personal data only where a lawful basis under Article 6 of the GDPR applies. The following bases govern our processing activities:
| Processing Purpose | Legal Basis |
|---|---|
| Providing and managing your account and access to services | Performance of a contract (Art. 6(1)(b)) |
| Processing payments and issuing invoices | Performance of a contract (Art. 6(1)(b)) |
| Sending transactional and service communications | Performance of a contract (Art. 6(1)(b)) |
| Complying with legal and regulatory obligations | Legal obligation (Art. 6(1)(c)) |
| Fraud prevention and platform security | Legitimate interests (Art. 6(1)(f)) |
| Improving and optimizing our services | Legitimate interests (Art. 6(1)(f)) |
| Sending marketing and promotional communications | Consent (Art. 6(1)(a)) |
| Storing cookie preferences and analytics data | Consent (Art. 6(1)(a)) |
4. How We Use Your Personal Data
We use collected personal data for the following purposes:
- Creating and maintaining your user account
- Delivering purchased courses, masterclasses, and educational content
- Processing transactions and managing billing
- Responding to inquiries, support requests, and feedback
- Sending service-related notifications and updates
- Monitoring and improving platform performance and user experience
- Detecting, investigating, and preventing fraudulent or unauthorized activity
- Meeting applicable legal, tax, and regulatory requirements
- Sending marketing communications where consent has been given
5. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law.
5.1 Retention Periods
- Account data: Retained for the duration of your account and for up to 3 years following account closure, unless a longer period is required by law.
- Transaction and billing records: Retained for a minimum of 7 years to comply with financial and tax obligations.
- Support and communication records: Retained for up to 2 years from the date of last contact.
- Marketing consent records: Retained until consent is withdrawn, plus a reasonable period thereafter for compliance documentation.
- Analytics and usage data: Retained in aggregated or anonymized form indefinitely; identifiable data retained for up to 13 months.
When personal data is no longer required, it is securely deleted or anonymized.
6. Data Sharing and Disclosure
We do not sell, rent, or trade your personal data. We may share your data with third parties only in the following circumstances:
6.1 Service Providers
We engage trusted third-party service providers who process data on our behalf under binding data processing agreements. These include:
- Cloud hosting and infrastructure providers
- Payment processing services
- Email delivery and communication platforms
- Analytics and performance monitoring tools
- Customer support software providers
6.2 Legal Requirements
We may disclose personal data when required to do so by law, court order, regulatory authority, or to protect the rights, property, or safety of our users or the public.
6.3 Business Transfers
In the event of a merger, acquisition, or transfer of business assets, personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.
7. International Data Transfers
As an internationally operating platform, your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). Where such transfers occur, we ensure appropriate safeguards are in place, including:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Adequacy decisions issued by the European Commission
- Binding Corporate Rules where applicable
You may request information about the specific safeguards applied to your data by contacting us at contact@ulnisrak.com.
8. Cookies and Tracking Technologies
We use cookies and similar technologies to operate our platform, analyze usage, and deliver relevant content. Cookies are small text files stored on your device.
8.1 Types of Cookies We Use
| Cookie Type | Purpose | Legal Basis |
|---|---|---|
| Essential | Required for core platform functionality and security | Legitimate interests |
| Functional | Remembering your preferences and settings | Consent |
| Analytics | Understanding how users interact with our platform | Consent |
| Marketing | Delivering relevant communications and measuring campaign effectiveness | Consent |
You may manage your cookie preferences at any time through your browser settings or our cookie consent tool. Withdrawing consent for non-essential cookies will not affect your ability to use core platform features.
9. Your Rights Under GDPR
As a data subject under the GDPR, you have the following rights with respect to your personal data:
9.1 Right of Access
You have the right to request a copy of the personal data we hold about you and information about how it is processed.
9.2 Right to Rectification
You have the right to request correction of inaccurate or incomplete personal data without undue delay.
9.3 Right to Erasure
You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where consent is withdrawn, or where processing is unlawful, subject to applicable legal retention requirements.
9.4 Right to Restriction of Processing
You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to its processing.
9.5 Right to Data Portability
Where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
9.6 Right to Object
You have the right to object to processing based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will cease processing your data for that purpose immediately.
9.7 Rights Related to Automated Decision-Making
You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects, unless such processing is necessary for a contract, authorized by law, or based on your explicit consent.
9.8 Right to Withdraw Consent
Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
To exercise any of these rights, please contact us at contact@ulnisrak.com. We will respond to your request within 30 days. In complex cases, this period may be extended by a further two months, and we will notify you accordingly.
10. Data Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:
- Encryption of data in transit using TLS protocols
- Encryption of sensitive data at rest
- Access controls and role-based permission systems
- Regular security assessments and vulnerability testing
- Staff training on data protection responsibilities
- Incident response and breach notification procedures
In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and affected individuals without undue delay, as required by Article 33 and 34 of the GDPR.
11. Children's Data
Our services are not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately at contact@ulnisrak.com and we will take prompt steps to delete such data.
12. Third-Party Links
Our platform may contain links to third-party websites or services. This notice applies solely to data processed by Ulnisrak. We are not responsible for the privacy practices of third-party sites and encourage you to review their respective privacy policies before providing any personal data.
13. Right to Lodge a Complaint
If you believe your personal data has been processed in a manner inconsistent with the GDPR, you have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or the location of the alleged infringement. We encourage you to contact us first so we may address your concern directly.
14. Changes to This Notice
We may update this GDPR Privacy Notice from time to time to reflect changes in our practices, legal requirements, or service offerings. The date at the top of this page indicates when the notice was last revised. Where changes are material, we will notify registered users by email or through a prominent notice on our platform prior to the changes taking effect.
Continued use of our services following notification of changes constitutes acceptance of the updated notice.
15. Contact Us
For any questions, requests, or concerns relating to this notice or the processing of your personal data, please contact us:
- Company: Ulnisrak
- Email: contact@ulnisrak.com
- Phone: +380689494867
- Address: Svitlohirska St, 74, Kryvyi Rih, Dnipropetrovsk Oblast, Ukraine, 50000
- Website: ulnisrak.com