Effective date: 15.12.2025Website: pogorelova.orgData Controller: Svitlana PogorielovaContact email: moc.liamg%40analtivs.p
1. Overview
This Privacy Policy explains how we collect, use, and protect personal data when you visit our website, contact us, or purchase and access our online services and digital content (the “Course”).
2. Personal data we collect
We may collect: • Contact data you provide: name, email address, message content • Purchase and access data: order details, access status, course progress (if applicable) • Technical data: IP address, device and browser information, basic logs • Cookie data: depending on your cookie choices (see Section 9)
3. Purposes and legal bases (GDPR)
We process personal data based on the following legal grounds: • Contract necessity: to provide the Course, grant access, and deliver requested services • Legitimate interests: to secure the website, prevent fraud, and improve performance • Consent: for optional marketing emails and non-essential cookies where required • Legal obligation: for accounting, tax, and compliance where applicable
This structure follows GDPR transparency requirements for data collected from the data subject. 
4. How we use your data
We use personal data to: • respond to inquiries and provide support • process orders and provide access to digital content/services • send service-related communications • maintain security and troubleshoot issues • send marketing communications only if you consent (you can unsubscribe anytime)
5. Sharing your data
We may share data with service providers acting as processors, such as: • hosting and infrastructure providers • email delivery providers • payment providers (to process transactions)
We do not sell your personal data.
6. International transfers
Some service providers may process data outside the EEA. Where this occurs, we rely on appropriate safeguards (for example, contractual protections) as required by GDPR.
7. Data retention
We keep personal data only as long as necessary: • inquiries and support: typically up to [12-24] months • purchase and access records: for the duration of access and as needed for support, plus legal retention where applicable • technical logs: typically a short period for security and troubleshooting
8. Your rights (EEA/UK)
You have the right to: • access, rectify, or erase your data • restrict or object to processing • data portability (where applicable) • withdraw consent at any time (for consent-based processing)
To exercise rights, email .moc.liamg%40analtivs.p
You also have the right to lodge a complaint with the French supervisory authority (CNIL) or your local authority. 
9. Cookies
We may use cookies for: • essential functionality • analytics and performance (if enabled) • preference storage
Where required, we will request consent for non-essential cookies. You can control cookies through your browser settings.
10. Security
We use reasonable technical and organizational measures to protect personal data.
11. Children
This website and Course are intended for adults. We do not knowingly collect personal data from children under 16.
12. Changes
We may update this policy and will post the updated version with a new effective date.