• Privacy Policy

    USER AGREEMENT AND PRIVACY POLICY

    The provider of the service of using the LMS Collaborator online platform is exceptionally responsible for maintaining the confidentiality of information and personal data received, and takes all measures necessary to ensure their safe storage.

    This Privacy Policy regulates the relationship between the Service Provider and the Client regarding the mode of use of Confidential Information and personal data, the procedure for their receipt, protection, processing, transfer and deletion, and is an integral part of the Agreement for the provision of services for the use of the LMS Collaborator online platform.

    This Privacy Policy uses the following terms in the following meanings:

    Personal data – information or a set of information about an individual who is identified or can be specifically identified;

    Confidential information – information or data that is defined as confidential and received by the Service Provider and the Client from each other in the process of providing services for the use of the LMS Collaborator online platform;

    Data import – entering the data provided by the Client into the LMS Collaborator online platform;

    Cloud storage – secure cloud storage facilities, where data is stored on numerous servers distributed across the network in the European Union;

    Data transfer consent – clearly defined consent of the data owner or legal and authorized user of such data to their transfer, expressed, among others, by accepting these terms and conditions and placing an order for the use of the LMS Collaborator online platform.

    Personal data subject – an individual whose personal data is processed. For the purposes of this Privacy Policy, the Client is considered to be the Personal data subject;

    General Data Protection Regulation — (GDPR, Regulation (EU) 2016/67) is a part of the European Union legislation concerning the protection of personal data of individuals within the EU and the European Economic Area. 

    The service provider adheres to ISO 9001 and General Data Protection Regulation standards when working with personal data and confidential information.

    The relationship between the Service Provider and the Client shall be governed by the laws of Ukraine and other countries where applicable.

    The Client confirms their consent to comply with the terms of this Privacy Policy by accepting all its terms and conditions and placing an order for the use of the LMS Collaborator online platform.

    Agreeing to this Privacy Policy is mandatory to obtain the right to use the service, and is considered a voluntary consent to the transfer and processing of personal data and confidential information in accordance with these terms and conditions and the Agreement for the provision of services for the use of the LMS Collaborator online platform.

    GUARANTEES

    The Service Provider and the Client undertake to maintain the confidentiality of all data received in connection with the provision of the service of using the LMS Collaborator online platform.

    COMPLIANCE WITH THE GENERAL DATA PROTECTION REGULATION

    The Service Provider guarantees that it:

    • Does not use personal data for purposes other than those described in this Privacy Policy and the Agreement for the provision of services for access to the LMS Collaborator online platform.
    • Clearly identifies the personal data received;
    • Controls the availability of consent to receive and process personal data;
    • Provides the ability to completely delete personal data;
    • Depersonalizes data for further use by the Service Provider;
    • Guarantees compliance with GDPR requirements for all entities that have access to personal data;
    • Does not receive or process personal data on ethnicity or nationality, philosophical, religious or political views, medical and other data with a special access and storage regime;
    • Stores data on secure storage media that meets GDPR requirements;
    • Comply with other obligations imposed on them as the owner or manager of personal data 

    SOURCES OF INFORMATION OBTAINING

    The Service Provider receives information from the Client at the time of creating a personal account and in the process of using the LMS Collaborator online platform.

    The Client is responsible for the accuracy of the provided Personal Data, as well as for its timely updating. The Client guarantees that they have received and transferred Personal Data lawfully and on the basis of sufficient consent and authorization of the data controller.

    The Service Provider shall have the right to request confirmation of the accuracy of such data and the consent of the personal data owner in the form of a written confirmation.

    The Service Provider does not provide access to the LMS Collaborator online platform to persons under the age of 18.

    PURPOSE OF OBTAINING INFORMATION

    The Service Provider may use personal data for the following purposes:

    • Provision of services,
    • Provision of methodological and technical assistance.

    GROUNDS FOR PROCESSING PERSONAL DATA

    • Consent of the personal data subject;
    • Conclusion and/or execution of a contract to which the personal data subject is a party.

    DATA IMPORT

    After providing the LMS Collaborator online platform for use, the Client may transfer data entered into the platform. The Service Provider guarantees the storage of such data in accordance with this Privacy Policy and the LMS Collaborator online platform Access Service Agreement. Immediately upon receipt, the data entered by the user is transferred for storage to remote Cloud storage media and cannot be used by the Service Provider.

    THIRD PARTIES

    The Service Provider may provide confidential information and personal data to third parties on the direct instructions of the Client (for example, to integrate the platform with other services). In this case, the Service Provider is not responsible for the safety of such data and cannot guarantee compliance with the special treatment of such information.

    The Service Provider may disclose confidential information and personal data to third parties solely for the purpose of providing services to the Client, which may include cases of involving third-party specialists, connecting third-party software. In this case, the Service Provider shall be liable for the actions of such third parties as if they were its own. The use of personal data is carried out only in accordance with the professional, official or labor duties of such persons. These third parties are obliged to prevent the disclosure of personal data entrusted to them or which became known in connection with the performance of professional, official or labor duties in any way. By accepting the terms of the Privacy Policy, the Client agrees to such transfer of information to third parties.

    Information may also be disclosed to law enforcement and other governmental authorities if such disclosure is mandatory and upon a proper request, which the Service Provider shall immediately notify the Client.

    WITHDRAWAL OF CONSENT TO THE TRANSFER AND PROCESSING OF INFORMATION

    The Client has the right to withdraw their Consent to the transfer and processing of personal data at any time. In this case, the Service Provider is obliged to take all actions dependent on it to delete/transfer personal data to the Client and take all actions necessary for the uninterrupted provision of the service to the Client. At the same time, in this case, the Service Provider shall not be responsible for the quality and continuity of the service.

    RIGHTS OF THE PERSONAL DATA SUBJECT:

    The subject of personal data has the following rights:

    • to be informed about the sources of collection, location of their personal data, the purpose of their processing, location or place of residence (stay) of the owner or manager of personal data or give an appropriate order to obtain this information to their authorized persons;
    • to receive information on the conditions for granting access to personal data, including information about third parties to whom his/her personal data is transferred;
    • to receive, no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, a response on whether his or her personal data is processed, as well as to receive the content of such personal data;
    • to submit a reasoned request to the personal data controller with an objection to the processing of their personal data;
    • submit a reasoned request to change or eliminate their personal data by any owner and administrator of personal data, if this data is processed illegally or is unreliable;
    • other rights provided for by applicable law.

    DATA PROTECTION

    The Service Provider guarantees the protection of personal data and confidential information from accidental loss or destruction, from unlawful processing, including unlawful destruction or access to personal data not provided for by the terms of this policy.

    The Service Provider uses exclusively safe and secure resources for storing confidential information and personal data, including Cloud storage devices.

    USE OF COOKIES

    Cookies are small amounts of data that are sent to the Client’s browser from the website’s computers and stored on the Client’s computer’s hard disk. Cookies are used to provide the Client with an individualized experience of using the website and to facilitate the use of the website during the next visit.

    Cookies on the Provider’s public information websites

    Our cookies are used for the following purposes:

    Strictly required/technical.

    These cookies are required to enable the Client to use the public information sites of the Service Provider. They include cookies that allow the Service Provider to remember the Client’s previous actions during the same browsing session.

    Analytical.

    These cookies are used by the Service Provider to analyze how the website is used. For example, they track the most visited pages and where visitors come from. They include, for example, Google Analytics cookies.

    Functional.

    These cookies are used to customize the Client’s experience. For example, cookies allow us to remember the data that the Client provided when filling out forms so that they do not have to enter the same information several times.

    Cookies in LMS Collaborator

    The LMS Collaborator platform does not collect any cookies unless required by the Client.

    The Client has the right to integrate additional software modules into LMS Collaborator to collect cookies. In this case, the Client is responsible for obtaining consent to work with cookies from personal data subjects and all legal aspects of this work.

    Terminating the use of cookies

    Most web browsers automatically accept cookies. However, the Client does not have to accept cookies, they can reject or block the use of cookies and delete all cookies currently stored on their device. To find out how to do this for a particular browser, click “help” in your browser menu.

    THE PROCEDURE FOR AMENDING THIS POLICY

    The Service Provider has the right to change the terms of this Privacy Policy, which shall be notified to the Client no later than one calendar month prior to the effective date of such changes

    CONSIDERATION OF COMPLAINTS FROM PERSONAL DATA SUBJECTS

    If the Client (personal data subject) has any questions, please contact us:

    Davintoo Ukraina LLC
    [email protected]

     +38(067)217-0440