PRIVACY POLICY AND DATA PROTECTION NOTICE

Effective Date: September 3, 2006
Last Updated: November 6, 2026

This Privacy Policy and Data Protection Notice ("Policy") applies to the collection, use, storage, and processing of personal data by Lisov Andrey Nikolaevich, acting as a self-employed individual / sole proprietor applying the special tax regime "Tax on Professional Income" / Simplified Taxation System (INN 7710140679) (hereinafter referred to as the "Contractor", "We", "Us", or "Our"), operating via the website and associated digital platforms (hereinafter referred to as the "Website").
This Policy is designed to comply with international data protection frameworks, including the General Data Protection Regulation (GDPR) for the European Union (EU) and European Economic Area (EEA), U.S. state privacy laws (such as the California Consumer Privacy Act / CCPA), and the data protection and personal data legislation of the Commonwealth of Independent States (CIS) (including Federal Law No. 152-FZ "On Personal Data" of the Russian Federation).
By accessing our Website, purchasing our Digital Products, or participating in our Mentorship Services, you ("User", "Customer") consent to the practices described in this Policy.
1. INFORMATION WE COLLECT
We collect personal data necessary to provide you with access to our educational materials, SaaS platforms, AI roles, and mentorship sessions, as well as to fulfill our contractual obligations.
1.1. Categories of Personal Data Collected:
  • Identification and Contact Data: Full name, email address, phone number, messenger handles (e.g., Telegram username), and tax identification numbers (if applicable for business entities).
  • Payment and Financial Data: Billing address, transaction history, and partial payment details processed securely through third-party payment gateways (e.g., Prodamus, bank partners). Note: We do not store full credit card numbers or sensitive banking credentials on our servers.
  • Technical and Usage Data: IP addresses, browser types, device information, operating system, time zone settings, log data, and interaction history with our Website, GetCourse platform, and closed chats.
  • User-Generated Content: Feedback, questions submitted during mentorship sessions or Zoom calls, and homework or project files shared for review.
2. LEGAL BASES FOR PROCESSING (GDPR COMPLIANCE)
If you are located in the European Union or European Economic Area, we process your personal data under the following legal bases:
  1. Performance of a Contract: Processing is necessary to fulfill the Agreement / Public Offer (e.g., delivering digital products, managing subscriptions, or conducting mentorship calls).
  2. Legal Obligation: Processing is required to comply with financial, tax, and regulatory laws.
  3. Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, analyzing website traffic, and improving our services, provided these interests are not overridden by your data protection rights.
  4. Consent: Where required by law, we rely on your explicit consent (e.g., for marketing communications or optional cookies).
3. CIS DATA PROTECTION COMPLIANCE
For users located in the CIS region (including the Russian Federation):
  • Personal data processing is conducted in strict compliance with local data protection mandates (such as Federal Law No. 152-FZ).
  • We ensure that the collection of personal data is limited to specific, pre-defined, and legitimate purposes connected to the execution of the Public Offer agreement.
  • Databases containing personal data of citizens of the Russian Federation are localized in accordance with applicable statutory data residency requirements where mandated.
4. U.S. PRIVACY RIGHTS (CCPA / VCDPA / STATE LAWS)
If you are a resident of the United States (including California, Virginia, and other states with comprehensive privacy legislation):
  • No Sale of Personal Data: We do not sell or rent your personal information to third parties for monetary or valuable consideration.
  • Categories of Personal Information Disclosed for Business Purposes: We share identifiers, commercial information, and internet activity data with service providers (such as hosting, CRM, and payment processors) strictly to operate our business and deliver services.
  • Consumer Rights: Depending on your state of residence, you may have the right to request access to, correction of, or deletion of your personal data, as well as the right to opt-out of certain data processing activities.
5. SHARING AND DISCLOSURE OF INFORMATION
We do not trade or lease your personal information. We may share your data only with trusted third parties who assist us in operating our business, under strict confidentiality agreements:
  • Platform and Infrastructure Providers: GetCourse, Telegram, SaaS-hosting platforms, and cloud storage providers.
  • Payment Gateways and Financial Brokers: Prodamus and partner banks processing transactions or installment plans.
  • Legal and Regulatory Authorities: When required by law, court order, or governmental regulation to protect our rights, safety, or property.
6. DATA SECURITY AND RETENTION
  • Security Measures: We implement industry-standard technical, administrative, and physical security measures (including encryption, access controls, and secure server environments) to protect your personal data from unauthorized access, alteration, disclosure, or destruction.
  • Retention Period: We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations (such as statutory tax and accounting retention periods, which may range up to 5-10 years), resolve disputes, and enforce our agreements.
7. YOUR DATA PROTECTION RIGHTS
Depending on your jurisdiction (EU, US, CIS), you may exercise the following rights regarding your personal data:
  • Right to Access: Request a copy of the personal data we hold about you.
  • Right to Correction: Request correction of inaccurate or incomplete data.
  • Right to Erasure ("Right to Be Forgotten"): Request the deletion of your data, subject to legal retention obligations (e.g., completed financial transactions or active digital licenses where refunds are restricted).
  • Right to Restrict or Object: Object to or limit the processing of your data under specific conditions.
  • Right to Data Portability: Request the transfer of your data to another service provider in a structured, commonly used format.
To exercise any of these rights, please contact us using the details provided below.
8. INTERNATIONAL TRANSFERS
As an international service provider, your personal data may be transferred to, stored, and processed in servers located outside your country of residence, including within the Russian Federation, the EU, or the US. We take appropriate safeguards to ensure that your data receives an adequate level of protection wherever it is processed.
9. CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify or update this Privacy Policy at any time. Any changes will be posted directly on the Website with an updated effective date. Your continued use of the Website or services after changes are posted constitutes your acceptance of the revised Policy.
10. CONTACT INFORMATION
For any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact the Contractor:
  • Data Controller: Lisov Andrey Nikolaevich (Self-employed)
  • Tax ID (INN): 7710140679
  • Email Support: advertooq@gmail.com
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