Privacy Policy

This privacy policy (“Privacy Policy”) describes how we, Kultprosvet Inc. and our affiliates, subsidiaries (“Kultprosvet”, “we” or “us”) process, use, collect and store Personal Data (defined below) that we receive from or about you (“you”). If you do not agree with the terms, please refrain from accessing or using the Services or any other aspect of Kultprosvet’s business.

Please read this Privacy Policy carefully so you can fully understand our practices concerning your Personal Data. By "Personal Data" we mean any information that can be used alone or in combination with other data to identify any living person, as well as any information that is considered to be information that identifies or can identify a person under the applicable privacy laws.

1. How we collect your Personal Data

1.1 Kultprosvet handles your Personal Data responsibly and with your privacy in mind and follows current data protection legislation (including GDPR and other relevant regulations such as national laws and regulations).

1.2 We may disclose your personal data to our affiliates, meaning an entity that controls, is controlled by, or is under common control with the Kultprosvet. Our affiliates may use the personal data we share in a manner totally consistent with this Privacy Policy.

1.3 This Privacy Policy explains what information is collected by Kultprosvet when you visit the kultprosvet.net website (hereinafter “the website”), visit any related websites (hereinafter “subdomains”), use any other services provided by Kultprosvet, or communicate with us by any means including by calls, email, phone, messenger, or any other medium (collectively referred to herein as the "Services"). This document also describes how we protect your Personal Data.

Additionally, in this Privacy Policy, we explain how the Personal Data we collect will be used and how you can control this information. You will always find the most recently updated version of this information on the website.

1.4 If you have any questions, comments, or requests about Personal Data collection or this Privacy Policy, please contact us at [email protected].

2. What Personal Data Kultprosvet collects and how we use it

2.1 We obtain your Personal Data from:

2.2 The Privacy Policy extends to:

We only collect and process the Personal Data that is necessary with respect to the specific purposes set up in advance.

2.3 The Personal Data we obtain:

2.4 Browser information we obtain automatically

2.5 Cookies

We may use cookies to personalize our service and to improve the experience on our website and subdomains. Here is a list of cookies that we may use:

3. Third parties

3.1 To ensure the security of your Personal Data, we carefully select third-party services that we use. We use exceptional services that claim they are compliant with GDPR and other data protection regulations.

3.2 Third-party services

3.3 Subcontractors

Your data may also be transferred to subcontractors. During this process, data may be transferred to parties located in countries outside the EU that are not bound by EU data protection regulations. However, to protect your Personal Data, we always sign contracts with our subcontractors that contain provisions for the protection of user data.

4. How to withdraw your consent for collecting, processing, and using your Personal Data

You can withdraw consent to collect, process, and use your Personal Data anytime by emailing [email protected]. If you receive our emails, you can unsubscribe by clicking the Unsubscribe button in any email or just replying with a request to unsubscribe.

5. How we protect and store your Personal Data

5.1. Security

We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised including as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

5.2. Retention of your Personal Data

We may store your Personal Data for as long as necessary to fulfill the purpose for which we collected it, and as long as necessary to fulfill your requests or inquiries or provide services or until we proactively delete it or you send a valid deletion request. In addition, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

6. Your rights as a data subject

6.1 Right to access

You have the right to find out what Personal Data is being collected and processed, how it is being used, for how long it is being stored, if your Personal Data has been transferred to any third parties, and how you can withdraw your consent for Personal Data collection, processing, and use.

6.2 Right to rectification

You have the right to ask that we rectify inaccurate Personal Data. Taking into account the purposes of data processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

6.3 Right to erasure

You have the right to obtain from us the erasure of your Personal Data when this Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed when you withdraw your consent on which the processing was based, or when your Personal Data is processed illegally.

6.4 Right to restrict processing

You have the right to restrict us from processing your Personal Data if:

• you contest the accuracy of your Personal Data; in this case, we shall not process your Personal Data for a period sufficient for us to verify the accuracy of the Personal Data;
• the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of its use instead;
• your Personal Data is no longer needed for processing but is still required by you for the establishment, exercise, or defense of legal claims;
• you object to processing your Personal Data on grounds related to your particular situation; in this case, we only have the right to process your Personal Data if we provide legitimate grounds for processing it that are more compelling than your grounds for not processing.

6.5 Right to data portability

This means that you may have the right to receive your Personal Data in a structured, commonly used, and machine-readable format.

6.6 Right to object to profiling, if applicable.

6.7 Right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area or the United Kingdom, as applicable, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality.

6.8 You have a right to complain with your local data protection supervisory authority (i.e., your place of habitual residence, place of work, or place of alleged infringement) at any time or before the relevant institutions in your place of residence. However, we kindly ask that you try to resolve any issues with us before reaching out to your local supervisory authority or relevant institution.

6.9 To the extent privacy laws applicable to you afford you the rights referenced above, we will respect your rights and comply with such laws. You can exercise your rights by contacting us at [email protected]. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly under applicable law or inform you if we require further information to fulfil your request.

7. Use by children

We do not offer our services for use by children and, therefore, we do not knowingly collect personal information from, and/or about children under the age of eighteen (18). If you are under 18, you should not use the website, or provide any information to the Website without the involvement of a parent or a guardian. If we become aware that you provide Personal Information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].

8. Do not track notice

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not currently respond to or honor DNT signals. However, we do honor legally required browser-based opt-out preference signals such as the Global Privacy Control.

9. Privacy information for California residents

9.1. If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer's personal information obtained from the consumer's activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. Please see the sections above in our Privacy Policy for detailed information about our data collection and use practices, as well as for more information about our advertising practices.

9.1.1. Category of Personal Data which We may sell/share: Device identifiers and Service usage information, Email address.

9.1.2. Categories of third parties to which We may sell/share of Personal Data: Ad networks and advertising analytics partners.

9.1.3. Your Choices Regarding “Sharing” and “Selling”. You have the right to opt out of the sale or sharing of your personal information for online advertising purposes by contacting us at [email protected]. Please note that there may be circumstances in which we are entitled by law to continue to sell or share your data. Also, note that your withdrawal of consent shall not affect our right to request your consent to sell or share again after twelve (12) months.

9.2. Other CCPA Rights

If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives. The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.

9.3. California “Shine the Light” disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of Personal Data (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure.

10. How you can raise a complaint

You can raise a complaint by sending an email to [email protected].

11. Privacy Policy updates

We will update this Privacy Policy from time to time. Updates may be in response to changes to existing law or any changes to security standards and best practices for third-party services or tools that we use. We will update this Privacy Policy as we deem necessary.