This Policy was last updated July 16, 2020.
Tuitoria respects the privacy of our stakeholders. We aim to protect the personal data that are provided to us. “Personal Data” refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access. This is as per defined in the Personal Data Protection Act 2005 (PDPA) in Ukraine.
When you consent to provide your personal data to us, you warrant and represent to us the personal data which you disclose to us is accurate and complete; and where you volunteer personal data of another person to us, that you are authorized by such other person to disclose such personal data to us, and that such personal data is accurate and complete.
This policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your personal data.
This set of Policy and your use of this website shall be governed in all respects by the laws of Ukraine.
Collection & Consent of Personal Data
We will collect your personal data in one or more of the following ways:
1. When you register for any courses, events, membership programs or services with us;
2. When you post a feedback, or interact with our customer service officers, e. via emails, telephone calls or at our centres;
When we are required to validate as our student;
1. When you use some of our services including establishing any online accounts with us;
2. When you request that we contact you, be included in an email or other mailing list;
3. When you respond to our promotions, campaigns or other initiatives or attend our events;
When you visit our websites, we may automatically collect standard information tracked by most other websites (Eg. Your IP address) for cybersecurity record purposes;
1. When you take part in any contest, survey or promotion conducted by us and/or our business partners (including submission of photographs);
2. When you visit our centres which has live CCTV recording for security purposes or photo taking or video recording at events;
3. When we receive information about you from third party social networking services when you choose to connect with those services; and
When you submit your Personal Data to us for any other reasons; and/or when we collect your Personal Data by other lawful means.
1. Purpose for Collection, Use & Disclosure of your personal data
Your Personal Data may be collected, used and/or disclosed for the following purposes:
1. To verify accuracy of your personal data;
2. To provide courses, events, membership programs & services that you have registered for
To respond and deal with enquiries, complaints and other customer-care matters or otherwise communicate with you;
1. To monitor customer-facing interactions for quality assurance, employee training and performance evaluation;
2. To manage payment, billing, account, credit checks and debt-recovery matters;
3. To send you information, promotions, updates, marketing and advertising materials in relation to our coursesand programs and that of our subsidiaries.
To manage, develop and improve our business and operations to serve you better;
To personalize your experience at our customer touch points;
1. To carry out market research and customer surveys;
2. To conduct investigations or audits or carry out crime and fraud prevention and risk management activities;
3. To comply with legal and regulatory requirements;
To enforce our legal rights and obligations;
For other purposes for which we have obtained your consent
Your Personal Data may be disclosed for the purposes indicated above to our officers and employees, third parties, affiliates, service providers, advisors which include without limitation, the following persons or entities:
1. Banks, credit card companies, and payment vendors;
2. Debt collection agencies;
Credit information companies;
1. Logistics and courier services companies;
2. Call centre service providers;
3. Our business partners and authorised program partners
Relevant government regulators or authorities or law enforcement agencies, e.g. OSCE, MOIA etc.,
Our insurers and advisors, including consultants, trainers, assessors, auditors and lawyers;
1. Data intermediaries; and
2. Any other party to whom you authorise us to disclose your Personal Data to.
Except for relevant government regulators and authorities or law enforcement agencies, we will ensure that the parties listed above receiving your personal data are
1. Under duty of confidentiality to us with respect to the use, holding, processing, retention and/or transfer of your Personal Data; and
2. Have the need to know or handle such personal data
Security of Personal Data
We have put in placed appropriate physical & IT security measures which continually strives to meet industry standards to protect our possession & control of all personal data against unauthorised access, collection, use, disclosure, copying & disposal.
However, even though we endeavour to ensure our internal systems are secured, we would like to remind you that that all communications sent via Internet (E.g. Email & Website) cannot be guaranteed to be completely secure and thus you are providing your personal data via Internet at your own risk. Tuitoria will not hold any responsibility or liability for the confidentiality and security of any information you send via Internet.
Withdrawal of Consent
You have the right at any time to indicate your choice to us to withdraw your consent for the continued use & disclosure of your personal data (to a reasonable extent and as permitted by PDPA) via one or more of the following means:-
1. By writing to our Data Protection Officer.
2. Unsubscribe options as stated on our email or other marketing messages.
In withdrawing your consent, you acknowledge that, depending on the purpose(s) that you have indicated your withdrawal of consent for, we may not be able to provide or continue providing certain programs, courses & services to you. We may also have to cease such provisions accordingly without any liability to Tuitoria.
Please note that it may take up to 30 working days for any request for withdrawal of consent to be processed and updated in our systems.
Data Protection Officer
We have appointed a Data Protection Officer to oversee the protection & security management of all personal data. Should you have any query, request or feedback relating to your Personal Data, please contact us at the following:
Data Protection Officer
For more information about the Ukraine Personal Data Protection Act, please visit http://cedem.org.ua