Privacy Policy

1. INTRODUCTION

This privacy policy is provided by Liubov BORISOVA, an individual entrepreneur under Czech law, place of business V Sáreckém údoli 2802, 16400 Praha 6 – Dejvice, Czech Republic (the “Provider”), treats any and all personal data she processes as strictly confidential, and uses them in compliance with applicable data protection laws.

This Privacy Policy applies to personal data processing related to:
  • use of the websites https://academio-writing.eu/, https://academio.online/ and related sites (the “Websites”);
  • communication with the Provider via e-mail or phone;
  • performance of a contract concluded with the participants of the Provider’s courses and/or with other contractors;
  • fulfilment of the Provider’s legal obligations;
  • necessary protection of the legitimate interests of the Provider.


2. DATA CONTROLLER & CONTACT DETAILS

Liubov BORISOVA, an individual entrepreneur under Czech laws, place of business V Sáreckém údoli 2802, 16400 Praha 6 – Dejvice, Czech Republic, is within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679), a controller of your personal data.

Address: V Sáreckém údoli 2802, 16400 Praha 6 – Dejvice, Czech Republic
Email: l.borisova@academio-writing.eu


3. PURPOSES OF PERSONAL DATA PROCESSING

The Provider may process your personal data for the following purposes:

  • Performance of a contract including related negotiations (contracts concluded with the participants of the Course/Programme including the Terms of Use (the “Contract”), contracts concluded with suppliers of goods and providers of services;
  • Compliance with legal obligations (in particular obligations under accounting and tax laws, i.e. transfers of personal data to tax and revenue authorities and, where appropriate, to other public authorities in compliance with applicable laws);
  • Sending marketing communications, offers of products and services, and targeted advertising (the Provider may send commercial communications and/or newsletters, related in particular to academic writing, and may offer services via e-mail); for targeted advertising, it is possible to use information obtained from the Website);
  • Provider’s legitimate interest (protection of the rights and legitimate interests of the Provider, keeping records of coaching calls for 3 years after termination of the Contract for analytics and improvement of the Provider’s services; protection of the Website against misuse);
  • Processing requests sent by means of electronic forms (in particular if you ask for information related to the Course via e-mail or via electronic forms available at the Website, or if you enrol for educational or social events organized by the Provider).


4. WHAT KIND OF PERSONAL DATA ARE PROCESSED?

The Provider may process the following personal data for the following purposes:

Name
  • Performance of a contract; Fulfilment of legal obligations; Sending marketing communications, offer of services and products and targeted advertising; Protection of the Provider’s legitimate interest; Processing requests sent by means of electronic forms
Contact address
  • Performance of a contract; Fulfilment of legal obligations; Sending marketing communications and offer of services and products; Protection of the Provider’s legitimate interest; Processing requests sent by means of electronic forms
E-mail
  • Performance of a contract; Fulfilment of legal obligations; Sending marketing communications, offer of services and products and targeted advertising; Protection of the Provider’s legitimate interest; Processing requests sent by means of electronic forms
Phone number
  • Performance of a contract; Fulfilment of legal obligations; Sending marketing communications, offer of services and products and targeted advertising; Protection of the Provider’s legitimate interest; Processing requests sent by means of electronic forms
Bank account number and other transaction-related data
  • Performance of a contract; Fulfilment of legal obligations; Protection of the Provider’s legitimate interest
Date of birth
  • Performance of a contract; Fulfilment of legal obligations
Text, audio and video data
  • Performance of a contract; Protection of the Provider’s legitimate interest

The Provider processes personal data both manually and by automated means.

The Provider may collect, store and use certain information by automated means, such as statistical information whenever you visit the Websites.


5. PROCESSING OF PERSONAL DATA BASED ON CONSENT

If you grant to the Provider your consent with the processing of your personal data for the purpose of sending personalised marketing communications (in those cases, profiling may also take place) or for the purpose of sending offers of the services and products of business partners of the Provider, whether via e-mail or by phone, you acknowledge that the grant of such consent is voluntary and that the consent can be revoked at any time by a written notice to the Provider’s address or via a link contained in the e-mail message with the marketing communication. The consent is granted until revoked. Failure to grant the consent does not affect the performance of the contract.


6. RECIPIENTS OF PERSONAL DATA

The Provider will disclose your personal data only to its authorised employees, tax/legal advisors or to individual data processors engaged by the Provider under relevant contracts such as IT and marketing providers (Thinkific platform, Active Campaign tools, Zoom, scheduling software etc.), or to other controllers if applicable, but in any case within the scope necessary to achieve the purposes of the processing and on the basis of the relevant legal title for the processing of the personal data.

In some case defined by legislation, the Provider is authorised, or even obligated, to transfer certain personal data under applicable laws to criminal prosecution authorities or other public authorities.


7. DATA TRANSFER TO THIRD COUNTRIES

Personal data is not transferred to third countries, ie. to countries outside the European Union, and in the case of their storage on cloud servers/other places outside the European Union, their adequate protection is ensured in accordance with applicable legislation.


8. PERSONAL DATA RETENTION

The Provider will process and retain your personal data for a period of time necessary to safeguard all the rights and obligations resulting from the relevant contract, and thereafter for a period for which the Provider, as data controller, is required to retain personal data under applicable laws, or for which you have granted to the Provider your consent with such processing. In other events, the data retention period is based on, and must be proportionate to, the purpose of the processing, or is stipulated by applicable laws.

The Provider processes personal data for the retention periods specified below:

PROCESSING PURPOSE AND RETENTION PERIOD

Performance of a contract
  • For the duration of the contract and for 10 years from termination of the contract.
  • Video and audio records of coaching calls are retained for 12 months from the commencement of data processing (under legal basis “performance of a contract”).
Compliance with legal obligations
  • For the period stipulated by applicable legal regulation.
Sending marketing communications and offers of services, products and targeted advertising
  • For the duration of the consent to the processing of personal data, or until revocation of the consent.
Protection of the legitimate interests of the Provider
  • For a maximum of 3 years from the commencement of data processing, unless separate laws require otherwise (such as the laws on legal profession and tax advisory services), or unless it is necessary in justified cases to retain data for a longer period in connection with a particular case. The records of coaching calls (text, video, audio) are kept for 3 years after termination of the Contract for analytics and improvement of the Provider’s services.
Processing requests sent by means of electronic forms
  • For the period necessary to process the relevant request.


9. COOKIES

When you visit and use Websites, cookies or other technologies such as pixels will be activated on your device. Cookies are small files designed to store and receive identifiers and other information about computers, telephones and other devices you use to access the Website, that help provide, protect and improve the services the Provider offers.

Cookies enable the Provider to offer you the content and services most suitable to your needs and interests. Cookies enable the Provider to record information regarding your visit to the Website and will thus make your next visit easier and quicker.

Following cookies are used on the Website:

A) FUNCTIONAL COOKIES
When you visit and use the Website for information purposes only, we collect personal data received by our server from your Internet browser. We need these cookies to display the Website and ensure it can be used in a stable and secure way.

B) BASIC ANALYTICS COOKIES
These cookies are used to enhance the functioning of the Website. They enable us to recognise and to count the number of visitors and see how visitors are using the Website. They help us improve the way the Website is functioning, e.g. by enabling users to easily find what they are looking for. These cookies do not collect information that could identify you but they help us to enhance the functionality of the Website.

C) MARKETING COOKIES
These are used to track Website user preferences to target advertising, i.e. to display relevant marketing and advertising information (also on third party websites) matching these preferences.
Marketing cookies use external company tools. These marketing cookies will only be used with your consent.
We use the following marketing tools on our Website:
Google Analytics advertising features beyond the basic analytical features (https://support.google.com/analytics/answer/6004245?hl=en)
Cookies may be disabled in your Internet browser settings, or you can only enable certain types of cookies (depending on your Internet browser type). However, if you disable basic (functional) cookies, certain functions of the Website may not work the way they should.


10. YOUR RIGHTS

As a data subject, you have certain rights in connection with the processing of personal data, which result from applicable laws and which you may exercise at any time:

Right of access to personal data: If you wish to know whether the Provider processes personal data, you have the right to obtain information as to whether or not your personal data are being processed and, where that is the case, you also have the right to obtain access to your personal data.

Right to rectification of inaccurate personal data and to completion of incomplete personal data: If you think that the Provider is processing personal data about you which are inaccurate or incomplete, you have the right to request their rectification and/or completion. The Provider will rectify or complete the date without undue delay, always taking technological capacities into account.

Right to erasure: If you request erasure, the Provider will erase your personal data if (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, (ii) the personal data have been unlawfully processed, (iii) you object to the processing and there are no overriding legitimate grounds for the processing of your personal data, or (iv) the legal obligation in EU or national law to process personal data no longer applies.

Right to restriction of processing: If you request restriction of processing, the Provider will make your personal data unavailable, or will temporarily remove or store them, or will perform any other processing activities as may be necessary for the proper exercise of that right;

Right to data portability: If you wish the Provider to transfer to a third party your personal data processed by the Provider electronically on the basis of a contract or your consent, you may exercise your right to data portability. In the event the exercise of this right adversely affected the rights and freedoms of others, the Provider will not be able to act on your request.

Right to object: The right to object to the processing of personal data for the performance of a task carried out in the public interest or in the exercise of official authority, or for protection of the Provider’ legitimate interests. Unless the Provider demonstrate that compelling legitimate grounds for the processing exist which override the interests, rights and freedoms of the data subject, the processing will be discontinued without undue delay.

Where requests to exercise the above rights are repetitive or manifestly without legal basis, the Provider may either charge a reasonable fee for the exercise of the relevant right, or refuse to act on the request. In that event you will be informed accordingly.


11. DATA PROTECTION OFFICER

The Provider is not obliged to appoint a data protection officer.


12. COMPLAINTS

You can file a data protection complaint to the Provider via l.borisova@academio-writing.eu and you have a right to contact/file a complaint to the Czech Personal Data Protection Office (www.uoou.cz):

Address: Pplk. Sochora 27, 170 00 Praha 7, Czech Republic
Email: posta@uoou.cz


13. FINAL PROVISIONS

This Privacy Policy came into effect as of 20 June 2023 and it will be updated on a regular basis. The up-to-date version is available at https://academio-writing.eu/ and https://academio.online/