The management of this website is carried out by the legal entity
LIMITED LIABILITY COMPANY “TRAINING AND SIMULATOR COMPLEX ‘ADMIRAL’”, EDRPOU code
37913949, registered and operating in accordance with the laws of Ukraine (hereinafter – the
“Company” or
“We”).
This
Privacy Policy (hereinafter – the
“Policy”) is aimed at publicly informing users (hereinafter – the
“Participants” or
“You”) about the procedure for the collection (processing), storage, and transfer of personal data and information provided by You while using this website in the course of the provision of training services in the field of maritime education.
This Privacy Policy is an integral part of the Company’s
Public Offer Agreement.
Before starting to use the Services, please review this Policy.
Our Policy is based on the generally applicable practices of the following acts:
- The Law of Ukraine “On Protection of Personal Data” dated 01.06.2010 No. 2297-VI (as amended);
- The Law of Ukraine “On Information” dated 02.10.1992 No. 2657-XII (as amended);
- Resolution of the Cabinet of Ministers of Ukraine “On the List of Information That Does Not Constitute a Commercial Secret” No. 611 dated 09.08.1993; and
- The EU General Data Protection Regulation 2016/679 (GDPR).
We control the methods of collecting Your Personal Data and determine the purposes for which the Personal Data is used by the Company. We are the
“Controller of Personal Data” within the meaning of the Law of Ukraine “On Protection of Personal Data” dated 01.06.2010 No. 2297-VI.
We process Your Personal Data only in accordance with the current legislation of Ukraine, including but not limited to cases when:
- You have given consent to the processing of Personal Data;
- Processing is necessary for entering into and/or performing a Service Agreement for training with You.
We may periodically update this Privacy Policy, including when required by the applicable legislation. Therefore, please visit
https://admiral.ua/ to ensure that you have the most up-to-date information.
Please note that You may not use the website until We receive Your explicit consent to the provisions of this Privacy Policy through the technical means provided on this website.
BASIC CONCEPTS (TERMS)
1.1. Personal Data – any information of a personal nature that enables a third party to identify a natural person (data subject).
1.2. Identified Individual (Data Subject) – a natural person who can be directly or indirectly identified, in particular by reference to a certain identifier (name, surname, document number, other identifier) or by analyzing several elements of that person’s physical, genetic, psychological, economic, cultural, or other identity.
1.3. Users – persons who use the Company’s Website(s).
1.4. Website – the internet site.
1.5. Data Controller – a natural or legal person who determines the purposes and means of processing Personal Data and bears primary responsibility for such processing. The Data Controller corresponds to the “Owner of Personal Data” under Ukrainian law.
1.6. Data Processor – a natural or legal person who, on the basis of the Controller’s instructions (directions, orders), processes Personal Data for the Controller. The Data Processor corresponds to the “Manager (Processor) of Personal Data” under Ukrainian law.
1.7. Processing of Personal Data – any operation or set of operations performed on Personal Data or sets of Personal Data, with or without automated means, such as collection, recording, systematization, structuring, storage, alteration, arrangement, retrieval, use, dissemination or any other form of making available to third parties, including employees of the Controller or Processor of Personal Data, as well as deletion of data.
1.8. Automated Processing of Personal Data – any operation or set of operations performed on Personal Data or sets of Personal Data using fully or partially automated means: storing data, performing logical and/or arithmetic operations on such data, their alteration, destruction, selection, or dissemination.
LEGISLATION GOVERNING THE PROCESSING OF PERSONAL DATA
2.1. The processing of Your Personal Data is carried out in accordance with the requirements of the current legislation of Ukraine, including the Law of Ukraine “On Protection of Personal Data.”
SCOPE OF THIS POLICY
3.1. This Policy applies to Personal Data collected by us through this Website. Personal Data includes, in particular but not exclusively, data that personally identifies You, either on its own or in combination with other information available to us. Examples of Personal Data include, among other things, Your full name, location, phone number, email address, IP address, and other information that You may provide when using our Website.
3.2. By using this site, You accept the practices described in this Policy and give Your explicit consent to the processing of Personal Data by checking the
“I agree” box in the interface of the Website, which confirms acceptance of this Policy. If You do not agree with this Policy, please do not use this Website.
PERSONAL DATA COLLECTED THROUGH OUR WEBSITE
4.1. The Company collects personal information about You or other Users when entering into agreements with any licensees of the Company for the use of the Website, in accordance with the powers granted to the Company.
4.2. For the purposes of the Company’s Privacy Policy, Your personal information is divided into
Personally Identifiable Information and
Non-Personally Identifiable Information.
4.3. Personally Identifiable Information (Personal Data) means information that allows us to specifically identify You. Personal information is requested when ordering services, issuing invoices, registering an account, etc. Such information may include, without limitation, Your full name, address (both legal and actual), email address, IP address, financial and personal information, and/or any other information or any combination thereof provided by You.
4.4. Non-Personally Identifiable Information means information of an exclusively statistical nature that by itself does not identify specific natural or legal persons and that depends on Your visits to the Website. For example, this information may include the time of access to the Website, the address of the website from which You followed a link directly to the Website or by which You left our Website, information regarding the devices You use and the networks You connect to when using our services: browser type and version, browser plug-ins type and kind, operating system and platform, information about Your visits including loading errors, the duration of visits to certain pages, page interactions, or any telephone number used to call our customer service number. This information is used in aggregate form to increase the usefulness and attractiveness of the Website and for Users. Non-personal information in aggregate form may be transferred to third parties with whom we have contractual relations to improve our services.
4.5. Financial Information and other types of information. We may also, from time to time, collect a subcategory of Personal Data that we call
Financial Information. Financial Information includes credit/debit card numbers, bank and other account numbers. Please note that in certain cases, as described in this Privacy Policy, the handling of Financial Information differs from the handling of other types of Personal Information.
4.6. Methods of information collection. Personal Information can generally be collected in two ways: (1) information that is knowingly and voluntarily entered into the relevant forms on the Website directly by You in response to specific prompts or required fields during use or registration on it, or otherwise knowingly and voluntarily provided by You (for example, by email); and (2) information that is collected automatically when using the Company’s Website.
USE OF PERSONAL INFORMATION AND PURPOSES OF PERSONAL DATA PROCESSING
5.1. To fulfill obligations to registered Users regarding the confidentiality of information from such databases or regarding such registered Users at any time—through the use of the Company’s web resources. We collect data for specified, explicit, and legitimate purposes and do not further process it in a manner incompatible with those purposes. We collect data according to and with regard to the purposes of processing in order to respect the principle of data minimization. We need Your Personal Data so that we and our Partners can provide You access to our services, in particular:
5.1.1. to ensure proper connection and provision of information contained in the Website’s databases by means of registration data associated with Your personal account;
5.1.2. performance of obligations under the Public Offer Agreement;
5.1.3. security and fraud prevention;
5.1.4. to verify the User’s identity and for payment for the Company’s services;
5.1.5. to verify Your identity as a User;
5.1.6. effective customer support;
5.1.7. personalization of the use of our Website;
5.1.8. providing You with notices and messages regarding Your use of our Website;
5.1.9. to contact You by mail, phone (including SMS or other messaging services) or email, or by displaying an appropriate message within the Website You are using, when necessary in connection with Your use of the Website;
5.1.10. improvement of the content, functionality, and usability of the Website;
5.1.11. improvement of our services;
5.1.12. provision of other information and services requested by You;
5.1.13. any other purposes specified in this Privacy Policy or other agreements between the Company and You.
5.2. We store data in a form that allows identification of data subjects no longer than is necessary for the purposes of its processing and for the performance of our contractual obligations with such data subject. The Company stores certain information longer than required by the purpose of processing in order to comply with the law, but not longer than the period provided by legislation. We may carry out
Automated Processing of personal data. Such processing is carried out in compliance with the principles and within the purposes defined by this Policy. We ask You to provide only those personal data that are necessary to provide the service You choose, receive a newsletter, or respond to Your specific request/claim. At the same time, if You decide to provide us with additional personal data, we may also process them with the necessary level of protection.
PERIOD OF PROCESSING (STORAGE) OF PERSONAL DATA
6.1. We will not store Your data longer than is necessary to achieve the purpose for which it is processed or to comply with statutory requirements.
6.2. To determine the appropriate retention period, we define the nature and category of Personal Data, the purposes for which we process it, and whether we can achieve those purposes by other means.
6.3. The retention period for Personal Data is determined in accordance with the retention periods for the relevant documents in paper form set by the legislation of Ukraine, after which the Personal Data shall be destroyed in the prescribed manner. Upon completion of the retention period, confidential information shall be destroyed or transformed into a state in which it loses the characteristics of personal information in order to achieve anonymity.
COOKIES AND SIMILAR TECHNOLOGIES
7.1. We use cookies and other web technologies to collect information and support certain functions of our Website. For example, we use these technologies to:
7.1.1. collect information about how our Website is used by visitors, which pages are visited, which links are used, and how long each page is viewed;
7.1.2. collect information about how our Website is used by visitors, which pages are visited, which links are used, and how long each page is viewed;
(duplicated in source text – preserved)
7.1.3. support the functions of our sites, for example, to eliminate the need to re-enter login details already stored in our database, or to re-apply settings already set during previous visits to personalize Your experience on our Website.
7.2. Usually, the information collected using these web technologies does not allow us to identify You personally. However, if You have created a user profile, for example, by registering in a password-protected section of our Website, we may link the information collected by web technologies with other information that personally identifies You.
7.3. If You do not want to receive cookies, You can set Your browser to restrict or completely prohibit the use of such files. In addition, You can delete our cookies after leaving the Website. Although You are not required to download our cookies when visiting our Website, if You restrict or completely prohibit cookies in Your browser, You may not be able to use all features of our Website.
DISCLOSURE OF YOUR PERSONAL INFORMATION BY THE COMPANY
8.1. Within the Company. We provide shared access to Personal Information collected through our Website to the Company’s employees (natural persons).
8.2. Transfer of control. Your Personal Information may be transferred to companies that acquire the Company’s corporate rights or assets, for example, as a result of a sale, merger, reorganization, or liquidation. In the event of such transfer of control, the Company shall use Your Personal Information in accordance with this Policy and the privacy preferences You have communicated to us.
8.3. Regulatory compliance, protection of our rights and the rights of others. We have the right to disclose Personal Data when we believe such disclosure is required by law, court order, or is necessary to prevent negative phenomena in the state and society. We are also entitled to disclose Personal Information to prevent or investigate possible crimes, including fraud or theft of Personal Data, to enforce or apply our terms of use of online resources or other agreements, and to protect our own rights or property, or the rights, property, or safety of our Users or others.
8.4. Aggregate information. We have the right to provide limited access to demographic or survey information to third parties; however, such information will be anonymous and will not contain any personal data. Aggregate information to which we grant limited access may include anonymous information collected through the use of cookies and other similar tracking technologies.
8.5. Except as provided in this section, we shall not share Personal or Financial Information or unique identifiers with third parties, except for our licensees, without Your explicit prior consent or a mandatory legal requirement. The Company does not sell names, email addresses, or any other personal and contact information to third parties, and we have no intention of doing so in the future.
8.6. The transfer of information to our partners is carried out on the basis of agreements that define the purposes and methods of data processing and establish the partners’ obligations to ensure an appropriate level of protection of Personal Data and to process it in accordance with the applicable legislation.
PROCEDURE FOR HANDLING REQUESTS OF THE PERSONAL DATA SUBJECT
9.1. As a Personal Data subject, You have the right to obtain any information about Yourself during our processing of Your Personal Data.
9.2. Access by a Personal Data subject to their data is free of charge.
9.3. To obtain access to Your data, You may submit a request to us. The request shall state:
9.3.1. surname, name and patronymic, place of residence (place of stay), and details of the identity document of the Personal Data subject;
9.3.2. information about the Personal Data database to which the request relates;
9.4. The period for reviewing a request for satisfaction and providing a response may not exceed thirty calendar days from the date of its receipt.
9.5. Within this period, We shall provide a response to Your request or, in cases where We act as a Data Processor, We shall forward Your request to the Owner of the Personal Data database and inform You accordingly. In cases where the request cannot be satisfied based on the law, We shall inform You, indicating the grounds specified in the relevant regulatory act.
YOUR RIGHTS AS PERSONAL DATA SUBJECTS
10.1. Rights of Personal Data subjects under the laws of Ukraine:
10.1.1. to know about the sources of collection, location of their Personal Data, the purposes of their processing, the location or place of residence (stay) of the Owner or Processor of Personal Data, or to give an appropriate instruction to authorized persons to obtain this information, except in cases established by law;
10.1.2. to receive information about the conditions for granting access to Personal Data, including information about third parties to whom their Personal Data is provided;
10.1.3. to access their Personal Data;
10.1.4. to receive, no later than thirty calendar days from the date of the request (except as provided by law), a response as to whether their Personal Data is being processed, and to receive the content of such Personal Data;
10.1.5. to make a reasoned request to the Owner of Personal Data objecting to the processing of their Personal Data;
10.1.6. to make a reasoned request for the modification or destruction of their Personal Data by any Owner and Processor of Personal Data if such data is processed unlawfully or is inaccurate;
10.1.7. to protect their Personal Data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of such data, as well as to protect against the provision of information that is inaccurate or damages the honor, dignity, and business reputation of a natural person;
10.1.8. to lodge complaints regarding the processing of their Personal Data with the Ukrainian Parliament Commissioner for Human Rights or with a court;
10.1.9. to exercise legal remedies in case of violation of the legislation on the protection of Personal Data;
10.1.10. to include a reservation regarding the restriction of the right to process their Personal Data when giving consent;
10.1.11. to withdraw consent to the processing of Personal Data;
10.1.12. to know the mechanism of automated processing of Personal Data;
10.1.13. to protection against an automated decision that has legal consequences for them.
10.2. Other rights of Personal Data subjects under the GDPR:
10.2.1. Right to information;
10.2.2. Right to rectification of data about You.
PROTECTION OF PERSONAL INFORMATION BY THE COMPANY
11.1. We use a comprehensive data security program that includes commercially reasonable administrative, physical, and technological security measures to protect Your Personal Data from unauthorized access, use, unauthorized or accidental destruction, alteration, or disclosure. Although we take commercially reasonable precautions to ensure an appropriate level of security, we cannot guarantee absolute security of information provided over the internet or stored in our databases from criminal interference by third parties (hacker attacks).
11.2. As a data Controller, we take appropriate technical and organizational measures to ensure that, by default, only those Personal Data that are necessary for each specific purpose of processing are processed.
11.3. The data Controller is not responsible for all actions of its Users; the data Controller makes commercially reasonable efforts to prevent unauthorized access to or use of the Website and promptly notifies Users of any such unauthorized access or use; and complies with all applicable legal standards.
POWERS AND LIABILITY OF THE DATA PROCESSOR
12.1. Based on contractual or statutory requirements, We may act as a
Data Processor of Personal Data.
12.2. If Personal Data is received from a service provider using this Website, concerning third parties (end consumers of services, clients, employees of the service provider), We presume that such information has been obtained by the service provider lawfully with the appropriate consent of the data subject, and We are not responsible for how such information was obtained.
CHILDREN
13.1. Our Website is intended for use by persons aged
16 and older.
13.2. Persons who have reached the age of 16 may use our Website provided they give consent to the processing of Personal Data.
13.3. In fulfilling our contractual obligations to our Users and clients, We may process Personal Data of persons under 16 years of age, provided that such data is provided by the lawful representatives of such persons to meet the needs and interests of those persons as data subjects. We consider that You are the lawful representative of a person under 16 if You act in the interests of such person and have agreed to the terms of this Policy when using the Website. If we become aware that You are not a lawful representative, We will make reasonable efforts to delete the Personal Information of the person under 16 from our databases.
CONTACT DETAILS REGARDING THE PRIVACY POLICY
14.1. If you have any questions regarding this Policy or our privacy practices, please send an email or a written message (see Contact details on this page).
LLC “Training and Simulator Complex ‘ADMIRAL’”
Legal address:
68094, Odesa region, Odesa district, Burlacha Balka village, 31 Prymorska Street
Director:
Olha Chuprova
Email:
[email protected]
