PRIVACY POLICY AND PROTECTION OF PERSONAL DATA

CURRENT PRIVACY POLICY AND PROTECTION OF PERSONAL DATA (hereinafter referred to as the Policy) was developed in accordance with Directive 2002/58/EC of the European Parliament and of the Council of 12 July, 2002, concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications), and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the Law).

The current Policy establishes the procedure for the implementation of NEXT EDUCATION GROUP LIMITED (hereinafter referred to as the Company) processing personal data provided by clients who use the Site https://br.l-a-b-a.com/ and its individual services to receive or provide services (hereinafter - Users and the Site, respectively). The Policy determines the types of personal data collected, the purpose of using this personal data, the interaction of the Company with third parties, personal data safeguards, terms of data access as well as contact information for the User to gain access, modify, block or delete their personal data and ask any questions that may arise regarding the practice of personal data protection.

The Company highly respects the confidential (personal) information of every person who visits the Site https://br.l-a-b-a.com/, as well as those who use the services provided by the Site, without exception; therefore, the Company seeks to protect the confidentiality of personal data (information or a collection of information about an individual who has been identified or can be  specifically identified), thereby creating and ensuring the most comfortable conditions for using the Site’s services.

The Policy text is available to Users on the Internet at https://br.l-a-b-a.com/en/privacy . In case of disagreement with the Policy terms, the User must immediately stop all use of the Site.

1. Terminology and abbreviations

1. The terminology used in this Policy means the following:

1. Personal data is any information relating directly or indirectly to an identified or identifiable private entity (personal data subject).

2. Company refers to NEXT EDUCATION GROUP LIMITED, registration at: PO Box PL19 8JX, 17 Montgomery Drive, Tavistock, United Kingdom, PL19 8JX.

3. Personal data processing is any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

4. Automated processing of personal data is processing of personal data using computer technology. Despite this, the automated processing of personal data does not contain an automatic processing system, including profiling, which creates legal consequences for the User, or similarly significantly affects the User.

5. Dissemination of personal data means actions aimed at the disclosure of personal data to the public.

6. Provision of personal data means actions aimed at the disclosure of personal data to a certain person or certain group of persons.

7. Blocking of personal data is an interruption of personal data processing (except where processing is necessary to clarify personal data).

8. Use of personal data means actions (operations) with personal data performed by the Company in order to make decisions or take other actions that generate legal consequences in relation to the subject of the personal data or other persons, or otherwise affect the rights and freedoms of the subject or other persons.

9. Anonymization of personal data means actions as a result of which it becomes impossible to determine the specific owner of personal data without additional information.

10. Destruction of personal data means actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed.

11. Online program is an educational program, the training of which is carried out exclusively using remote technology on the Company’s online platform, available at: https://my.br.l-a-b-a.com/.

12. Online platform means Company software, which is a set of interconnected web-services and modules that make up a single space for providing services to consumers on the Internet.

13. Free lesson means audiovisual material (webinar), access to which, as well as to all materials, is provided by the Company free of charge for all Users who have registered to participate in such a webinar. The Company conducts free lessons for all interested Users. A free lesson is not a full or partial educational program.

14. User agreement is the agreement, posted on the Internet at https://br.l-a-b-a.com/en/terms, is the Company's offer to conclude an agreement with any third party who uses the Site on the terms stipulated in the User agreement.

15. Website is a totality of data, texts, graphic elements, designs, images, photos and video materials, and other results of intellectual activity as well as computer programs contained in the information system that ensure the availability of such information on the Internet at the network address https://my.br.l-a-b-a.com/ .

16. Personal account is a section of the Site, which the User receives access to after registration on the Site by entering a unique login and password.

17. Cookies are data that is automatically transmitted to the Company during the process of Site use by means of software installed on the User’s device. IP-address, geographical location, information about the browser and the type of operating system on the User’s device, technical specifications of the equipment and software used by the User and date and time of access to the Site is transmitted to the Company as well. Cookies can be eternal (they are called permanent cookies) and stored on the computer until the user deletes them, or temporary (these are called session cookies), that is, they are stored only until the browser is closed. In addition, cookies are divided into basic (they are set directly by the Site which was visited) and third-party (set by other sites).

18. “IP-address” is a numerical designation used by computers on the network to identify a computer each time it accesses the Internet.

2. User consent to process personal data by the Company
2.1. The User accepts the Policy terms and gives the Company informed consent to process their personal data under the terms stipulated by the Policy and the Law:
2.1.1. Upon registering on the Site,  the User provides the Company with personal data:
• by filling out the registration form located on the Internet, the User is considered to have consented to the processing of their personal data by putting a checkmark in the field “
I accept the terms of the Public Offer Agreement and agree with the personal data processing policy” at the time of clicking the “Register” button;
• by authorising the use of personal data specified by the User in social networks or electronic services. The User is considered to have consented to the processing of their personal data at the time of pressing the button that displays the social network or electronic service selected for authorization.
By pressing the specified button, the User agrees to transfer to the Company all personal data that they made publicly available by indicating so in the profile of the corresponding social network or electronic service.
2.1.2. Upon entering or changing the personal data in the section “Personal data”, “My interests” in the personal account - for personal data that the User provides, when editing information in the sections of “Personal data”, “My interests” in the personal account. It is considered that the User consents to the processing of their newly entered or changed personal data at the moment of pressing the “Save” button.
2.1.3. Upon filling out the feedback form - for personal data that the User provides to the Company when filling out the feedback form on the Internet on the Site and electronic services (Google, etc.). It is considered that the User consents to the processing of their  personal data, entered in the fields of the feedback form, at the moment of pressing the button that confirms the sending of the application (the buttons may be called "Send", "Leave an application" or similar).
2.1.4. When subscribing to receive information and news items from the Company - by filling out the subscription form  for the mailing list, located on the Internet. The subscription form becomes available after the registration process is completed. It is considered that the User consents to the processing of their personal data by putting a tick in the field “I hereby give consent to the processing of my personal data” and pressing the “Subscribe” button.
2.1.5. Registering for training through the Online program this is done by filling out the application fields located on the Internet. It is considered that the User consents to the processing of their personal data by putting a tick in the form “Register for  training” and clicking the “Register” button.
2.1.6. Upon sending a scanned copy of the completed consent form for processing of personal data by email-for personal data that the User provides to the Company to receive educational services on the Site under the program of additional professional training. It is considered that the User consents to the processing of their personal data at the moment of sending a scanned copy of the agreement to the email address with the domain name @br.l-a-b-a.com.


2.1.7. Signing up for a free lesson - by filling out the application fields for registration, located on the Internet. It is considered that the User consents to the processing of their personal data when putting a tick in the form “Register for training” and pressing the “Register” button.
2.1.8. For any use of the Site -  for personal data that is automatically transmitted to the Company in the process of using the Site by means of software installed on the User’s device. It is considered that the User consents to the processing of their personal data the moment they start using the Site.
2.2. The User’s consent to have their personal data processed by the Company is considered valid from the day consent is received (clause 2.1. of the Policy), and for the period necessary to achieve the goals of processing personal data (section 5 of the Policy).
2.3. The User has the right to withdraw consent to the processing of personal data in the form and manner provided for in section 9 of the Policy.

3. Conditions for User provision of personal data

The Company proceeds from the premise that when providing personal data on the Site, the User:
3.1. confirms that they possess all the necessary rights to acquire civil rights for themselves and exercise them independently, as well as the ability to create civil duties for themselves, to fulfill them independently and bear responsibility if they are not fulfilled.
3.2. indicates accurate information about themselves in the volume necessary for Site use and and keeps the personal information provided up to date.
3.3. if the User uploads their image through the personal account of the Site, they consent to the use of the image, without compensation and for non-identification purposes. The User agrees not to provide photographs of third parties as an image of the User.
3.4. recognizes that the personal information they post on the Site may become available to other Users of the Site, may be copied and distributed by such Users in cases and on the conditions specified in clause 6.7 of the Policy.
3.5. is familiar with the Policy and expresses their informed and conscious consent with regard to it.

4. Personal data processed by the Company
4.1. The User’s personal data processed by the Company includes:
1. First name, last name;
2. Mobile phone number;
3. Email address;
4. Account data in social networks and electronic services (links to the User’s profiles on Facebook, LinkedIn, Skype, Google, Twitter, etc.);
5. Image;
6. Place of work;
7. Country, city;
8. Date of birth;
9. Occupation;
10. Data on work experience and current position;
11.IP-address;
12. Cookies;
13. Parameters and settings of Internet browsers (User-agent).
4.2. The company protects Data that is automatically transmitted when viewing ad units and when visiting pages on which the system's statistical script is installed (“pixel”):
1. IP-address;
2. information from cookies;
3. information about the browser (or other program that provides access to the display of advertising);
4. access time;
5. the address of the page on which the ad unit is located;
6. referrer (address of the previous page).
When you visit the Site, all logins are recorded. Other User traffic information is not processed or stored.
4.4. The Company does not collect any information that is processed under requirements specified by legislation, such as information about racial or ethnic origin, political, religious or ideological beliefs, membership of political parties and trade unions, conviction of a criminal offense or conviction of a criminal punishment, as well as data on health, sexuality, biometric or genetic details.
4.5. The Company collects data on the statistics of Site visits. The information may contain details about connections, traffic, the User's browser, date, time, duration of work on the Internet and stay on the Site.
4.3. Any other personal information which has not been mentioned above (browsing history, browsers and operating systems used, etc.) is subject to reliable storage and non-distribution.

5. Use of cookies

5.1. The Company takes care of its Users and tries to make the Site visit as comfortable as possible. For this, the Company needs to analyze the User’s behavior, preferences and interests by means of cookies. Such analysis will help the Company to improve the experience of interacting with the Site and to determine the most convenient interface and navigation of the Service.

5.2 According to the classification of the International Chamber of Commerce, the Company uses the following categories of cookies:

Strictly necessary cookies are necessary for the User to move around the web page and when using certain services, for example, to access protected pages, register and authorize and search the Site. They also memorize previous user actions when switching to the previous page in the same session.

Performance cookies aggregate information about how the Site is used. This data is stored on the User's device between web browser sessions. Examples of such data may include the following metrics: time spent on the Site, most frequently visited pages, understanding which site sections and services were most interesting to the User, the effectiveness of one or another advertising and / or marketing campaign, etc.

All information collected by means of performance cookies is intended for statistical and analytical purposes. Some cookie data may be provided to third parties that have permission from the web resource, and solely for the above mentioned purposes.

Functionality cookies are used to save settings or configurations stored on the User's device between the web browser sessions. Examples of such data may include the following metrics: User name, profile photo, information left in the comments, site language, location, data on  whether the user was provided with any information or selected advantages earlier, as well as other site settings.

These cookies also allow Users to watch videos, participate in online interactions (polls, voting) and interact with social networks.

To make the experience more pleasant after visiting the resource, these cookies remember the information provided by the User, increasing the efficiency of interaction with the Site.

Some cookie data may be provided to third parties that have permission from the web resource, and solely for the above mentioned purposes.

Targeting cookies are used to provide content that may interest the User. This data is stored on the User's device between web browser sessions. Examples of such data may include the following metrics: tracking the recommended text, graphic, audio and video material in order to avoid re-display, managing targeted advertising, evaluating the effectiveness of advertising campaigns, information about the User’s visits to other resources during transitions, and other Site settings.

The Site may share this information with other parties, including media clients, advertisers, agencies and joint business partners to provide good quality targeted advertising.

Cookies of third-party services and analytics services:

The Company uses services which are owned by the third-party companies such as Facebook, Twitter, Instagram, Alphabet Inc., Gemius and others, for prompt delivery, better display and detailed analysis of content on the Site.

The companies cited as an example may use cookies on the User's device while working on the Site.

It should be noted that the Site cannot affect the operation of cookies used by these services. All necessary information about their use can be found by visiting the appropriate resource.

Google Analytics Terms of Use - https://marketingplatform.google.com/about/analytics/terms/us/

Cookie management:

Major web browsers (listed below) are set up to accept cookies automatically. To disable them, use the help function in your browser. The help function can be accessed through the menu or the F1 button.

Microsoft Edge:  https://privacy.microsoft.com/en-us/privacystatement 

Mozilla Firefox: https://www.mozilla.org/en/privacy/websites/#cookies

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Opera: http://help.opera.com/Windows/11.50/en/cookies.html

Safari for macOS: https://www.apple.com/legal/privacy/en-ww/cookies/

Important:

To contact the Company about the use of cookies, send an email to info@br.l-a-b-a.com. 

If the User does not enable the use of cookies or intentionally deletes them from their web browser, then upon further visits to the Site the User will again be offered to enable and use cookies

User information obtained through cookies is not sold or distributed in the public domain, and is the property of the company that owns the resource.

6. Purposes of processing personal data
6.1. The Company processes Users’ personal data solely for the following purposes:
6.2.1. Registration of the User by the Company on the Site, providing the User with the opportunity to fully use the Site services.
6.2.2. Displaying the User’s profile in their personal account on the Site.
6.2.3. Establishing and maintaining communication between the User and the Company, advising on the provision of services, providing customer and technical support in case of problems associated with the use of the Site.
6.2.4. Fulfillment of the Company’s obligations to the User who has signed up for training via the Online program and/or for the free lesson, under agreements with the Company.
6.2.5. For the Company to send advertising messages to the User’s e-mail; targeted promotional materials.
6.2.6. Improving the quality of User services and upgrading  the Company Site by processing the User’s requests and applications.
6.2.7. Statistical and other studies based on anonymized information provided by the User.
6.2.8. Distribution on the Company’s Online platform, available at:
https://br.l-a-b-a.com/, in the official groups of social networks and other communities of the Company on the Internet, other advertising and information sources, for purposes not related to identifying the User:
• video materials obtained in the process of providing services
• feedback from the User about the services provided by the Company.
The User reserves the right to unsubscribe. Their name and email address will then be automatically deleted from the database. To do this, just click on the corresponding clause, which is included in every email.

7. Processing of personal data
7.1. Processing and storage of the provided personal data is carried out in data centers, where the equipment that ensures proper functioning of Site services is located. The provided personal data is processed and can be stored in the Personal Data Base or in a separate table of the Site Database. Due to the fact that the Company’s servers are located in different regions around the world, the information of a particular User may be processed not in the country of residence. The level of information protection and legal regulation in this area may vary in different countries. Regardless of where the User’s data is processed, the Company uses the same security measures described in this Policy. The company also adheres to a number of data transfer laws, including the US-EU privacy agreement EU-US Privacy Shield Framework and the similar Swiss-US Privacy Shield Framework, between the US and Switzerland.
7.2. Personal data is processed using automated systems, except when manual processing of personal data is necessary in connection with the implementation of legal requirements.
7.3. Processing of the User’s personal data includes the following Company’s actions: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
7.4. The collection of the User’s personal data is carried out in the cases specified in clause 2.1 of the Policy.
7.5. Storage of personal data is carried out (depending on which event occurs first):
• until the User deletes the data in the sections “My profile and programs” and “Settings” of their personal account;
• until the Company destroys the data - in the event the User withdraws consent for personal data processing or there is a requirement that the personal data be destroyed;
• until consent expires (clause 2.2 of the Policy) or the purposes of processing personal data is achieved.
7.6. Personal data can be updated by the User independently in the sections “Personal data”, “My interests” of the Personal account or by the Company at the User’s request.
7.7. The Company may distribute personal data only in the following cases:
7.7.1. When processing personal data in order to display the User profile for other Site Users to maintain communication including when providing services remotely. In this case, the User’s personal data may be available to Users registered on the Site in accordance with clause 2.1.4, 2.1.8.
7.7.2. In order to distribute reviews about the services provided by the Company, which have been left by users in various sources of information.
7.7.3. In order to post video materials obtained in the process of providing services in various sources of information.
7.8. The Company is entitled to transfer personal data to third parties (Processors of the Company) subject to the following conditions:
• The third party ensure confidentiality of personal data during its processing and use; undertakes not to disclose and distribute the Users’ personal data to other persons without their consent.
• The third party guarantees compliance with the following measures to ensure the safety of personal data during its processing: use of data security facilities; detection and fixing of facts of unauthorized access to personal data and taking measures to restore it; restriction of access to personal data; registration and accountability of actions with personal data; monitoring and evaluating the effectiveness of personal data safeguards.
7.9. Destruction of personal data is carried out by the Company in the following cases:
• the User deletes the personal data in the “My Profile and Programs” and “Settings” sections of the personal account;
• the User withdraws the consent to the processing of personal data;
• the Company receives a request from User to destroy personal data;
• expiration of the consent (clause 2.2 of the Policy).
The Company does not transfer personal data to third parties, except where such a transfer is required by the Law, at the request of the data subject in other cases specified by this Policy. The Company understands that personal information is a value and inalienable content, including the personal non-property rights of any individual, and therefore takes all possible measures to protect the personal information of Users, voluntarily and knowingly transmitted by them to the Company.

7.10. Cross-border transfer of personal data.

The company must make sure that the foreign state into whose territory it is supposed to carry out the transfer of personal data, provides adequate protection of the rights of the subjects of personal data, before such a transfer begins.

Cross-border transfer of personal data to the foreign territories, where there are no adequate protections of the rights of subjects’ personal data, may be carried out in the following cases:

• with written consent from the personal data subject to the cross-border transfer of their personal data;

• execution of a contract to which the subject of personal data is a party.

8. Protection of personal data

The Company takes the necessary and sufficient legal, organizational and technical measures to protect User information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution and other illegal actions of third parties. However, despite all efforts, the Company cannot guarantee absolute protection from any threats that can arise outside of the Company control.

The Company uses standard working methods such as encrypted communications, secure facilities, firewalls and password protection systems to ensure the confidentiality of personal data.

The Company provides access to information and personal data only to authorized employees who have agreed to ensure the confidentiality of such information and data in accordance with the requirements of the Company.

The Site may contain links to other websites (for informational purposes only). If you follow the link to other websites, this Policy will not apply to these websites. As a result, the Company recommends you become familiar with the privacy and personal data policy of each website before transferring personal data by which you can be identified.

9. User rights

The User is entitled to:

9.1. At their own discretion, provide the Company with personal data for processing under the terms specified by the Policy. At the same time, some of the personal data provided is necessary for the conclusion of the User Agreement, and, if it is not provided, the conclusion of such an Agreement is impossible;

9.2. Independently make changes and corrections to their own personal data in the "Personal Data", "My Interests" sections of their personal account, if such changes and corrections contain up-to-date and true information;

9.3. Delete personal data by editing the “Personal data”, “My interests” sections in their personal account;

9.4. Request the Company clarify their personal data, block or destroy it, if the personal data is incomplete, outdated, inaccurate, received illegally or is not necessary for the stated purpose of processing as well as take legal measures to protect their rights;

9.5. Receive no later than thirty calendar days after the receipt of a request, except in cases provided for by the law, an answer to whether the personal data is processed, as well as receive the content of such personal data;

9.6. Make a reasoned demand to the owner of personal data with an objection to the processing of their personal data;

9.7. Apply legal remedies in case of violation of legislation on the protection of personal data, including file a complaint with a supervisory authority;

9.8. In order to update, gain access, make changes, block or delete your own personal data, withdraw consent to the processing of personal data that has been provided to the Company in accordance with this Policy, or if there are any comments, wishes or claims regarding your personal data that has been processed by the Company, please contact the Company by email info@br.l-a-b-a.com.

9.9. Send the Company their requests and requirements for the use of personal data and withdrawal of consent to the processing of personal data. An appeal may be sent in writing to the address of the Company (section 11 of the Policy); or by email to the email address of the Company info@br.l-a-b-a.com (the Document should be sent from the User’s email address indicated as an authorized email address by them during registration on the Site or in the agreement). The Company considers the Users' Appeals, responds to them and/or performs the necessary actions within 30 calendar days from the receipt of the Appeal.

9.10. In addition to the rights listed in this Policy, the User has the opportunity to exercise any right provided by the Law.

10. Policy modification

10.1. The Company reserves the right to periodically, and without prior notice to the User, make changes and additions, including if legal requirements change.

The User is obligated to familiarize themselves with the text of the Policy every time they use the Site.

10.2. The new version of the Policy comes into force from the moment it is posted in the appropriate section of the Company website. Continuing to use the Site or its services after the publication of a new Policy version means the User accepts the Policy and its terms. In case of disagreement with the Policy terms, the User must immediately stop using the Site and its services.

10.3. We ask you to revise the Policy from time to time in order to be aware of any changes or additions.

11. Company Information

NEXT EDUCATION GROUP LIMITED

Company number 12073324

Correspondence address: PO Box PL19 8JX, 17 Montgomery Drive, Tavistock, United Kingdom, PL19 8JX

Email Address: info@br.l-a-b-a.com