Policy of Privacy
and Protection of Personal Data

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

This Policy establishes the procedure for NEXT EDUCATION GROUP LIMITED (hereinafter referred to as the Company) for processing personal data provided by customers who use the Site https://l-a-b-a.com/ and its individual services for receiving or provision of services (hereinafter referred to as the Users and the Site, respectively). The Policy defines the types of personal data collected, the purposes of using such personal data, the interaction of the Company with third parties, safety measures for protecting personal data, conditions for access to personal data, as well as contact information for the User regarding access, modification, blocking or deletion of their personal data and dealing with any questions that may arise regarding the practice of protection of personal data.

The Company treats with great respect the confidential (personal) information of all, without exception, Users who have visited the Site https://l-a-b-a.com/, as well as those who use the services provided by the Site. Wherefore, the Company strives to protect the confidentiality of personal data (information or a set of information about a natural person who is identified or can be specifically identified), thereby creating and ensuring the most comfortable conditions for using the services of the Site for each User.

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

• 1. Terminology and Abbreviations

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

  1.1. Personal data – any information, which relates directly or indirectly to a specific or determinate natural person (owner of personal data).

  1.2. Company – NEXT EDUCATION GROUP LIMITED, registered at the following address: PO Box PL19 8JX, 17 Montgomery Drive, Tavistock, United Kingdom, PL19 8JX.

  1.3. Processing of personal data – any action or set of actions performed with personal data with or without the use of automation devices, including collecting, recording, classification, accumulation, storage, validation (updating, change), extraction, use, transferring (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

  1.4. Automated personal data processing – processing of personal data using computer machines. Despite this, the automated personal data processing does not contain a system of automatic processing, including profiling, which creates legal consequences for the User, or which in a similar way significantly affects the User.

  1.5. Distribution of personal data – actions aimed at disclosing personal data to to general public.

  1.6. Providing personal data – actions aimed at disclosing personal data to a a certain person or to a defined public.

  1.7. Blocking of personal data – interruption of personal data processing (except when processing is necessary for rectification of personal data).

  1.8. Use of personal data – actions (operations) with personal data performed by the Company with the purpose of making decisions or performing other actions that give rise to legal consequences in relation to the owner of personal data or other persons or otherwise affecting the rights and freedoms of the owner of personal data or other persons.

  1.9. Depersonalization of personal data – actions, as a result of which it becomes impossible to determine the ownership of personal data by a specific owner of personal data without the use of additional information;

  1.10. Destruction of personal data – actions, as a result of which it becomes impossible to restore restore the content of personal data in the information system of personal data and (or) as a result of which material media bearing the personal data are destroyed.

  1.11. Online program – an educational program, which lessons are given exclusively using distance learning technologies on the Company's Online Platform, available at: https://l-a-b-a.com.

  1.12. Online platform – the Company's software, which represents a set of interrelated web services and modules that make up a single space for providing services to consumers on the Internet.

  1.13. Free lesson – multimedia content (webinar), access to which, as well as to all materials of which, is provided by the Company free of charge for all Users who have registered to participate in such a webinar. The Company provides free lessons for all interested Users. Such free lesson is not fully or partly an educational program.

  1.14. User agreement – agreement posted on the Internet at https://l-a-b-a.com/offerta, which is an offer by the Company to enter into an agreement with any third party using the Site on the terms provided for in the User agreement.

  1.15. Site – a set of information, texts, graphic elements, design, images, photos and video materials, and other copyright products, as well as computer programs contained in an information system, which ensures the availability of such information on the Internet at a network address https://l-a-b-a.com.

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

  1.17. Cookies – data, which is automatically transmitted to the Company in the process of using the Site by the means of the software installed on the User's device, including the IP address, geographic location, information about the browser and type of operating system of the User's device, specifications of the equipment and software used by the User, date and time of access to the Site. Cookies can be everlasting (they are called persistent cookies) and be stored in the computer until the User deletes them, or temporary (such cookies are called session cookies), that is they are stored only until the browser is closed. Cookies can be additionally divided into basic (they are installed directly by the visited Site) and third-party (installed by other sites).

  1.18. "IP address" – a numerical designation used by computers online to identify the computer each time of its access the Internet.

• 2. User Consent to Processing of His Personal Data by the Company

  2.1. The User shall accept the terms of the Policy and give the Company his informed consent to the processing of his personal data on the terms provided for by the Policy and the Law:

  2.1.1. When registering on the Site – regarding personal data that the User provides to the Company:

  • by filling out the registration form, which can be found online, the User is considered to have given consent to the processing of his personal data when the checkbox in the field "I accept the terms of the Offer Agreement and agree with the personal data processing policy" is ticked at the time of clicking the "Register" button;
  • by authorization using personal data specified by the User on social media or E-services. The User is considered to have given consent to the processing of his personal data at the time of clicking the button representing the social media or E-service.

  By clicking this button, the User gives consent to the transfer of all his personal data that was made public by him by indicating it in the account of the relevant social media or E-service to the Company.

  2.1.2. When entering or editing personal data in the "Personal Data", "My Interests" section in the personal account - for personal data that the User provides when editing information in the "Personal Data", "My Interests" section in the personal account. The User is considered to have given consent to the processing of his newly entered or changed personal data at the time of clicking the "Save" button.

  2.1.3. When filling out the feedback form – for personal data that the User provides to the Company when filling out the feedback form online on the Site and E-services (Google, etc.). The User is considered to have given consent to the processing of his personal data entered in the fields of the feedback form at the time of clicking the button confirming the sending of the application (these buttons may be named "Send", "Submit a request" and in other similar way).

  2.1.4. When subscribing for receiving information and news materials from the Company – by filling out a form for subscribing to a newsletter, which can be found online. The subscription form becomes available after completing the registration procedure. The User is considered to have given consent to the processing of his personal data by ticking the "I hereby give consent to the processing of my personal data" box at the time of clicking the "Subscribe" button.

  2.1.5. Registration for training under the Online Program – by filling in the application fields for registering for training, which can be found online. The User is considered to have given consent to the processing of his personal data by ticking the box in the "Register for training" form at the time of clicking the "Sign up" button.

  2.1.6. When sending a scanned copy of the completed consent form for the processing of personal data by e-mail – for personal data that the User provides to the Company in order to receive educational services on the Site under the program of further professional education. The User is considered to have given consent to the processing of his personal data at the time of sending a scanned copy of the consent to the e-mail address with the domain name @l-a-b-a.com.

  2.1.7. Registration for a Free lesson – by filling in the fields of the application for registration, which can be found online. The User is considered to have given consent to the processing of his personal data by ticking the box in the "Register for training" form at the time of clicking the "Sign up" button.

  2.1.8. For any use of the Site – regarding personal data that is automatically transferred to the Company in the process of using the Site by the means of the software installed on the User's device. The User is considered to have given consent to the processing of his personal data at the time of the start of using the Site.

  2.2. The User's consent to the processing of his personal data by the Company is valid since the date of giving consent to its processing (clause 2.1 of the Policy), and for the period necessary for achieving the goals of personal data processing (section 5 of the Policy).

  2.3. The User has the right to withdraw consent to the processing of his personal data in the form and procedure, provided for in section 9 of the Policy.

• 3. Conditions for the Provision of Personal Data by the User

  The Company proceeds from the premise that when providing personal data on the Site, the User:

  3.1. Confirms that he has all the necessary rights that allow him to obtain civil rights for himself and exercise them independently, as well as the ability to create civil obligations for himself by his actions, independently fulfill them and bear responsibility in case of failure to fulfill them.

  3.2. Shows reliable information about himself to the extent necessary to use the Site, and maintains the provided personal data up to date.

  3.3. In case of uploading his image via his personal account of the Site, he agrees to the use of this image for purposes that are not related to the identification of the User. The User undertakes not to provide photos of third parties as an image of the User.

  3.4. Realizes that information on the Site posted by the User about himself may become available to other Users of the Site, may be copied and distributed by such Users in the cases and under the conditions specified in clause 6.7 of the Policy.

  3.5. Realizes that any phone conversations conducted by him with an employee of the Company are automatically recorded in order to control the quality of service for Users, as well as to resolve disputes and conflict situations that may arise during such phone calls. At the same time, the User gives his consent to such automatic recording of phone conversations and storage of such records in accordance with the terms of this Policy.

  3.6. Understands this Policy and shows his informed consent to it.

• 4. Personal Data Processed by the Company

  4.1. The personal data of the User processed by the Company includes the following:

  • full name;
  • cell phone number;
  • e-mail address;
  • data of accounts on social media and E-services (links to User profiles in VKontakte, Facebook, Linkedin, Skype, Google, Twitter, etc.);
  • image;
  • place of work;
  • country, city;
  • birth date;
  • profession;
  • data on work experience and position;
  • IP address;
  • cookies;
  • parameters and settings of web browsers (User-agent);

  4.2. The Company protects Data, which is automatically transmitted while viewing ad units and when visiting pages on which the system’s statistical script ("pixel") is installed:

  • IP address;
  • data from cookies;
  • data on the web browser (or other program, which gains access to the display of advertising);
  • access time;
  • the address of the web page on which the ad unit is located;
  • referrer (url of the previous web page);

  4.3. All Site sessions are registered. Other user traffic information is not processed or stored.

  4.4. The Company does not collect any information, certain requirements regarding the processing of which are established by law, such as information about racial or ethnic origin, political, religious or worldview beliefs, membership in political parties and professional unions, conviction to criminal punishment for committing a crime, as well as data relating to health, sexual life, biometric or genetic data.

  4.5. The Company collects data regarding the statistics of Site sessions. The data may contain information about connections, traffic, the user's web browser, as well as the date, time, duration of work online and surfing the Site.

  4.6. Any other personal information not specified above (browsing history, web browsers and operating systems used, etc.) is subject to safe storage and non-distribution.

• 5. Use of Cookies

  5.1. The Company cares about its Users and tries to make the use of the Site as comfortable as possible. For this the Company uses cookies to analyze the behavior, preferences and interests of the User. Such an analysis will provide the Company with the ability to improve the experience of interacting with the Site, 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 – needed for the user for browsing the web page and while using certain services, for example, to access guard pages, register, log in, and implement on-site search. They also store the previous actions of the user while transferring 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. Following metrics can be examples of such data: time spent surfing the Site, the most frequently visited web pages, understanding which sections and services of the Site were most interesting to the User, how effective this or that advertising and/or marketing campaign, etc. is.

  All information collected by performance cookies can be used for statistical and analytical purposes. Some cookie data may be provided to third parties, who have permission from the web resource, and solely for the aforementioned purposes.

  Functionality cookies – used to save settings or configurations that are stored on the user's device between web browser sessions. Following metrics can be examples of such data: username, account photo, information on comments, site language, location, information about whether the user was previously provided with any information or selected benefits, as well as other Site settings.

  These cookies also allow users to watch videos, take part in interactive activities (quizzes, polls) and interact with social networks.

  To improve the impressions after visiting the resource, these cookies store the information provided by the User, which helps increasing the efficiency of interaction with the Site.

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

  Targeting cookies - used for providing content that may be of interest to the user. This data is stored on the User's device between web browser sessions. Following metrics can be examples of such data: tracking recommended text, graphics, audio and video materials in order to avoid rerun, manage targeted advertising, evaluate the effectiveness of advertising campaigns, information about the User's visits to other resources during transitions, as well as other Site settings.

  The Site may share this information with other parties, including media clients, advertisers, agencies and related business partners, in order for them to be able to provide quality targeted advertising.

  Third party and analytics service cookies:

  For the sake of prompt delivery, better display and detailed analysis of the content on the Site, the Company uses services that are the property of other third-party companies, such as Facebook, Twitter, Instagram, Alphabet Inc., Gemius and others.

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

  It’s worth noting that the Site cannot affect the work of the cookies used by these services. All the necessary information on their use can be found by visiting the appropriate resource.

  Google Analytics Terms of Use - http://www.google.com/analytics/terms/ru.html

  Cookie management:

  The main web browsers (listed below) are set to automatically accept cookies. In order to disable them, use the help function in your web browser. Help can be activated via the menu or using the F1 button.

  Microsoft Edge — https://privacy.microsoft.com/ru-ru/privacystatement

  Mozilla Firefox — https://www.mozilla.org/ru/privacy/Sites/#cookies

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

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

  Safari for macOS — https://support.apple.com/kb/PH21411?locale=en_US

  Important:

  • cookie settings configuration for mobile web browsers may be different;
  • it should be reminded that full-fledged work with the Site is available only in case of using cookies;
  • disabling cookies may lead to restriction of access to content and to the defective functioning of the Site services.

  To contact the Company regarding the use of cookies, send an email to [email protected]. If the User does not enable the use of cookies or deliberately deletes all cookies from his web browser, then the next time he visits the Site, the User will be prompted to enable the use of cookies again.

  Information about Users, which is obtained using cookies, is not sold or distributed in the public domain. It is also the property of the company that owns the resource.

• 6. Purposes of Personal Data Processing

  The Company processes Users' personal data solely for the following purposes:

  6.1. Registration of the User by the Company on the Site, providing the User with the opportunity to fully use the Site services.

  6.2. Displaying the User profile on the Site in his personal account.

  6.3. 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.

  6.4. Fulfillment of Company obligations to the User who signed up for learning under the Online Program, for a Free lesson, under agreements with the Company.

  6.5. Sending e-mails containing commercials by the Company to the e-mail address of the User; targeting advertising materials.

  6.6. Improving the quality of service for Users and modernizing the Company's Site by processing User’s requests and applications.

  6.7. Statistical and other studies based on depersonalized information provided by the User.

  6.8. Posting the following information on the Company's Online Platform, which is available at: https://l-a-b-a.com/, in official social media groups and other communities of the Company online, other advertising and information sources, for purposes that are not related to the identification of the User:

  • video materials obtained while providing services;
  • User’s comments regarding the services provided by the Company.

  The User retains the right to unsubscribe from e-mail marketing. Then his name and e-mail address will be automatically deleted from the database. To do this, just simply click on the corresponding item, which can be found in each received e-mail.

• 7. Personal Data Processing

  7.1. The processing and storage of the provided personal data is carried out in data centers where the equipment, which ensures the functioning of the Site's services, is located. The personal data provided is processed and may be stored in the Personal Data Database 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 in a country other than the country where he lives. The level of information protection and legislation in this area may differ in different countries. Regardless of where exactly 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 Shield Framework and the US-Switzerland Privacy Shield Framework.

  7.2. Personal data is processed using automated systems, except, when non-automated processing of personal data is necessary taking into account the fulfillment of legal requirements.

  7.3. The processing of the User's personal data includes the following actions performed by the Company: collection, recording, systematization, accumulation, storage, validation (updating, changing), extraction, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, and destroying.

  7.4. The collection of the User's personal data shall be carried out in the cases specified in clause 2.1 of the Policy.

  7.5. The storage of personal data shall be carried out (whichever occurs first):

  • until they are deleted by the User in the "My profile and programs" and "Settings" sections of the personal account;
  • until the moment of their destruction by the Company – in case of receipt from the User of withdrawal of consent to the processing of personal data or a request for the deletion of personal data;
  • until the consent expires (clause 2.2 of the Policy) or the goals of personal data processing are achieved.

  7.6. Validation of personal data can be carried out by the User independently in the "Personal data" and "My interests" sections of the Personal Account or by the Company at the request of the User.

  7.7. Distribution of personal data might be carried out by the Company only in the following cases:

  7.7.1. To maintain communication, including while providing services remotely when processing personal data in order to display the User's profile for other Site Users. In this case the User's personal data may be available to Users, who are registered on the Site in accordance with clauses 2.1.4, 2.1.8.

  7.7.2. In order to post User’s comments about the services provided by the Company in various sources of information.

  7.7.3. For the purpose of posting video materials obtained in the process of providing services in various sources of information.

  7.8. The Company has the right to transfer personal data to third parties (Company’s Processors) subject to the following conditions:

  • a third party ensures the confidentiality of personal data during their processing and use; undertakes not to disclose to other persons, and also not to distribute personal data of Users without their consent;
  • the third party guarantees compliance with the following measures to ensure the security of personal data during its processing: the use of information security tools; detection and recording the facts of unauthorized access to personal data and taking measures to restore personal data; restriction of access to personal data; registration and accounting of actions with personal data; control and evaluation of the efficiency of the measures taken for ensuring the security of personal data;

  7.9. The Company shall provide the deletion of personal data in the following cases:

  • deletion of personal data by the User in the "My Profile and Programs" and "Settings" sections of the personal account;
  • receiving the withdrawal of consent for personal data processing from the User;
  • receiving a request for the deletion of personal data from the User;
  • expiration of consent (clause 2.2 of the Policy).

  The Company never transfers personal data to third parties, except when such transfer is required by the Law, at the request of the owner of personal data or in other cases set forth in this Policy. The Company realizes that personal information is a valuable and integral content, including the personal non-property rights of any individual. Therefore, the Company takes all possible measures to protect the personal information of Users, voluntarily and knowingly transferred by the latter to the Company.

  7.10. Trans-border transfer of personal data

  The Company shall make sure that the foreign country, to the territory of which it is supposed to transfer personal data, provides adequate protection of the rights of personal data owners, before such a transfer begins.

  Trans-border transfer of personal data on the territory of foreign countries that do not provide adequate protection of the rights of personal data owners may be carried out in the following cases:

  • availability of personal data owner’s written consent to the trans-border transfer of his personal data;
  • execution of an agreement to which the personal data owner is a party.

• 8. Protection of Personal Data

  The Company takes all the necessary and sufficient legal, organizational and technical measures to protect the information provided by Users from unauthorized or accidental access, deletion, modification, blocking, copying, distribution, as well as from other illegal actions performed by third parties with it. However, despite all efforts, the Company cannot guarantee complete protection against any threats arising outside the Company's control.

  The Company uses standard operating practices such as encrypted communication, secured premises, firewall systems and password protection systems for the purpose of the confidentiality of personal data.

  The Company provides access to information and personal data only to its 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 a link to other websites, this Policy will not apply to such sites. Wherefore, the Company recommends you to read the privacy and personal data policies of each site before transferring your personal data according to which you can be identified. Read more here

• 9. User Rights

  User has the right to:

  9.1. At his sole discretion, provide the Company with personal data for its processing on the terms specified in the Policy. At the same time, some of the personal data provided are necessary for the conclusion of the User Agreement. In case if they are not provided, the conclusion of such User Agreement is impossible;

  9.2. Independently make changes and corrections to your personal data in the "Personal Data" and "My Interests" sections in your personal account, provided that such changes and corrections contain up-to-date and reliable information;

  9.3. Delete personal data by editing the "Personal Data" and "My Interests" sections in your personal account;

  9.4. Require the Company to clarify his personal data, block or delete them in case if the personal data is incomplete, outdated, imperfect, illegally obtained or not necessary for the stated purpose of processing, as well as take legal measures to protect his rights;

  9.5. Receive no later than thirty calendar days since the date of receipt of the request, except as otherwise provided by law, an answer on whether personal data is being processed, as well as receive the content of such personal data;

  9.6. Assert a justified claim to the owner of personal data with an objection to the processing of his personal data;

  9.7. Use legal protection means in case of violation of the legislation on the protection of personal data, including filing a complaint to a supervisory authority;

  9.8. To update, access, edit, block or delete your personal data, withdraw your consent to the processing of personal data that you provided to the Company in accordance with this Policy, or in case of any comments, wishes or claims regarding your personal Data, which is being processed by the Company, please contact the Company by e-mail [email protected].

  9.9. Send the Company his requests and requirements, including those regarding the use of his personal data, as well as the withdrawal of consent to the processing of personal data. The appeal can be sent in writing to the Company address (section 11 of the Policy); or by e-mail (the Document shall be sent from the e-mail address of the User specified by him during registration on the Site or as an authorized e-mail address in the agreement), to the e-mail address [email protected]. The Company considers the Users’ Appeals, provides a response to them and/or takes the necessary actions within 30 calendar days since the date of receipt of such Appeal.

  9.10. In addition to the rights indicated in this Policy, the User has the opportunity to exercise any right provided for 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 when changing legal requirements.

  The User is obliged to reread the text of the Policy every time he uses the Site.

  10.2. The new edition of the Policy comes into force since the moment it is posted in the relevant section of the Company's website. Continuation of the use of the Site or its services after posting of a new edition of the Policy means acceptance of the Policy and its terms by the User. In case of any disagreement with the terms of the Policy, the User shall immediately stop using the Site and its services.

  10.3. Please review the Policy from time to time in order to be aware of any changes or additions.

• 11. Company Profile

  NEXT EDUCATION GROUP LIMITED

  Company number 12073324

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

  E-mail address: [email protected]