Policy on Processing and Protection of Personal Data
The purpose of this Policy on Processing and Protection of Personal Data is to inform you how LLC “TRADE HOUSE “BUSTHUB”, a legal entity registered under the laws of Ukraine, EDRPOU code 45596755, located at Ukraine, 04071, Kyiv, Yaroslavsky Lane, building 1/3 (hereinafter referred to as “Busthub”), processes the data that you provide to Busthub, and your rights in this regard, including personal data contained in cookies on our website https://platma.academy (hereinafter the “Website”).
By registering on our website, you give Busthub consent to collect and process your data under the conditions defined by the provisions of this Policy. By providing consent on the cookie banner when visiting our website, you agree to the collection and processing of personal data that may be contained in cookies.
1. Personal Data We Collect/Process, Purpose, and Grounds:
During registration (creating a user account) and online purchase of services on the website, we collect the following data:
- Name and Surname, email address, phone number, country/region of the user, order number, order history of services, payment information, user code, and IP address.
Processing the above-mentioned personal data is necessary for us to ensure proper registration of the user account, its administration, and providing the user with access for its use, processing purchases on the website, fulfilling our agreement with the user regarding Busthub service orders, and user support and maintenance. We carry out the specified collection/processing based on your consent under paragraph 1 part 1 article 11 of the Law of Ukraine “On Personal Data Protection” and based on the provisions of paragraph 3 part 1 article 11 and paragraph 6 part 1 article 11 of the Law of Ukraine “On Personal Data Protection”.
For analyzing user activity on the website (cookies), we collect/process the following data:
- IP address, user actions, country/region of the user, timestamps, browsing information, including information about previous user visits and preferences on the website.
If you consent to the use of cookies, we process personal data based on our legitimate interest to improve our services and your consent under paragraph 1 part 1 article 11 of the Law of Ukraine “On Personal Data Protection” and based on the provisions of paragraph 6 part 1 article 11 of the Law of Ukraine “On Personal Data Protection”. Please refer to the cookie policy in section 2 of this Policy for more detailed information.
To send informational and promotional messages, we collect/process the following data:
- IP address, user actions, timestamps, browsing information, including information about your previous visits and preferences on the website, Name and Surname, email address, phone number, user country, browsing information, including user activity (registration data/source, email activity — receiving, opening, clicking), actions on the website (cookie identifier).
Our legitimate interest in collecting/processing the above-mentioned data lies in ensuring relevant, up-to-date, and informative personalized informational materials and their administration based on your consent under paragraph 1 part 1 article 11 of the Law of Ukraine “On Personal Data Protection” and based on the provisions of paragraph 3 part 1 article 11 and paragraph 6 part 1 article 11 of the Law of Ukraine “On Personal Data Protection”.
2. Details on Cookies
We, along with our partners, use cookies on our website. A cookie is a small piece of data that a website stores on a visitor’s computer or mobile device.
As stated on our cookie banner, we use the following types of cookies:
- Necessary – cookies that provide the basic functionality of our website. You can disable them yourself by changing your browser settings, but this may affect the website’s functionality.
- Statistical – cookies that we use to collect aggregated statistics about your visit. They allow us to count visits and traffic sources, find out which pages are the least popular, and see how visitors navigate the website. The information collected by these cookies is often aggregated, thus anonymous. We use third-party online analytics services such as Google Analytics and Facebook Pixel. Service providers administering these analytics services use automated technologies to collect data (such as email addresses, IP addresses, cookies, and other device identifiers) to evaluate, for example, website usage and diagnose technical issues.
- Advertising – cookies that may be used by us to create a profile of your interests and show advertising materials. They do not directly store personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, the advertising provided/displayed to you will be less relevant.
You have control over cookies and can enable/disable them at any time. You can always withdraw your consent or change your cookie consent settings on this page.
You can also use your browser or device settings to manage cookies. The links below contain information on cookie settings in the following most common browsers:
To learn more about Google Analytics and/or opt out of using cookies, click here.
To learn more about Facebook Pixel and/or opt-out of using cookies, click here.
If you do not choose our cookie banner, cookies will not be deployed, but the banner will appear again each time you visit our website.
3. To Whom We Transfer Personal Data
We may transfer your personal data to our contractors, partners, and authorities who need it to achieve the purposes (objectives) of processing listed in section 2 of this Policy or to whom we are obliged to disclose your data under applicable law, both in Ukraine and abroad.
In some cases, we may use the services of contractors and third-party processors to process your data on our behalf, such as backup solution providers, cloud solutions, or other IT systems we use.
For the transfer of personal data within Ukraine and abroad, we use data processing agreements. If personal data is transferred from Ukraine to the EU/EEA or countries outside the EU/EEA, Busthub ensures an adequate level of protection by using standard contractual clauses aimed at protecting personal data in agreements with data recipients or ensuring that recipients are at least subject to special certification mechanisms or that they are “safe” third countries as required by applicable law and/or the list of countries ensuring an adequate level of personal data protection defined by the Cabinet of Ministers of Ukraine. According to the current legislation of Ukraine (part 3 article 29 of the Law of Ukraine “On Personal Data Protection”), states – participants of the European Economic Area, as well as states that have signed the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, are recognized as providing an adequate level of personal data protection.
By providing us with your data, you consent to the transfer of your data as defined in this section and do not require notification of such transfer. Otherwise, you must stop using the website and not provide us with your personal data.
4. Where Personal Data is Stored and How We Protect It
We maintain full control over personal data collected on the website, including through cookies, by storing the data on secure servers that are fully owned and controlled by Busthub.
We protect personal data through organizational and technical means, including the following:
- We do not have direct access to most personal data collected through cookies.
- We do not take actions to combine your data to which we have access with personal data from other sources that may affect the ease of identifying your person.
- Our employees are trained in the basics of cybersecurity and privacy.
- We use enhanced password requirements.
5. Data Retention Period
Visitor logs of the website automatically delete visit information every 12 months.
We retain other personal data for an indefinite period – as long as it is necessary to fulfill the purposes described in section 1 of this Policy, or until you withdraw your consent.
The legal basis for our processing of your data is your given consent.
6. Rights
You may at any time request access, correction, and deletion of your data. Additionally, you may restrict the processing of your data, object to processing, and exercise your right to disclose and transfer your data.
If you have given consent to the processing of your data, you may withdraw it at any time by contacting us. However, such withdrawal will not affect any processing of personal data that occurred before the withdrawal.
You can find a detailed list of your rights in Article 8 of the Law of Ukraine “On Personal Data Protection”.
7. About Electronic Mailing (Informational Messages)
We guarantee that users’ email addresses will not be transferred or sold to other companies. Our electronic mailing list includes only those users who have consented (subscribed) to receive informational messages from Busthub. Such electronic mailing of informational messages may include information about Busthub’s services and products, current offers, news, promotions, events, and other promotional materials regarding Busthub’s services and products. Additionally, by subscribing to the mailing list, you consent to receive informational messages about unfinished orders on the website (items in the cart), and information about Busthub’s services and products that interest you.
You can always unsubscribe using the link at the bottom of each email or by contacting Busthub customer support. If you have shown no interest in our mailing for at least 3 months, we reserve the right to stop sending you our mailing. Of course, you can subscribe again at any time.
8. Contacts
Specific questions regarding the storage and processing of your data or submitting complaints or requests for additional information about this Policy can be sent to us at the following address:
LLC “TRADE HOUSE “BUSTHUB”
Ukraine, 04071, Kyiv, Yaroslavsky Lane, building 1/3
Email: support.academy@platma.com
9. Changes to This Policy
This Policy on the processing and protection of personal data may be updated and changed, for example, due to changes in current legislation and practices in the field of data protection without notice and your consent. We recommend that you stay informed of any changes to the Policy on the processing and protection of personal data by personally familiarizing yourself with it on the website. You will be notified directly by email of some changes, and in certain situations, you may be asked to accept significant changes.
The date of the last change of the Policy on the processing and protection of personal data: 05/29/2024.
