KRUPA 2022. PROJECTOR PRIVACY POLICY
І. Key information
Projector respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (hereinafter - the "Policy").

This Policy comes into force from the moment of its placement on our Site.

The purpose of this Policy is to describe how Projector, our subsidiaries, and our international branches, ("Projector," "us," "we," or "our") collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to https://prjctr.com/, https://krupaconference.com/ (collectively referred to herein as the "Site"), and what rights you have concerning this information.



Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. Be sure to return to this page periodically to ensure familiarity with the most current version of this Policy.

By continuing to use the Site after the publication of changes, you agree with the new version of the Policy. If you do not agree with the changes, you should immediately stop using the Site.



If you do not understand any aspects of this Policy and (or) have any claims, please feel free to contact us at hello@prjctr.com.ua.



If you do not agree to the usage of your personal data to contact you in the future for any purpose, please contact the support service of users of the Site and we will take into account your wishes.



If you reside or are located in the European Economic Area ("EEA") Projector is the data controller of all Personally Identifiable Information (as defined below) collected via the Site and of certain Personally Identifiable Information collected from third parties, as set out in this Policy.



Please read the Terms and conditions (Public offers) carefully before using our Site or services. By joining to mentioned documents you give to Projector the right to collect, process, and store your personal data following this Policy, and to send you some messages or send us certain information.

If you do not agree with any provision of this Policy, please do not use any of the Site's services.

This Policy applies to information collected by Projector through the Site or otherwise as described below. This Policy does not apply to the practices of any third-party websites, applications, or services that Projector does not own or maintain (collectively, "Third-Party Services"). As further detailed below, we cannot take responsibility for the content or privacy policies of any Third-Party Services.
ІІ. What information Projector collects from you
Per the Policy the following types of information are subject to collection, storage, and use:

1. Information concerning your use of our Site.

When you visit our Site, we may track, collect and summarize information, indicating, inter alia, which pages of our Site you have visited, the order in which they were visited, when they were visited, and which hyperlinks you visited.



We also collect information from the URLs from which you link to our Site. The collection of such information may include the registration of the IP address (also, the Internet service provider of the user and the geographical location of the point of connection), the operating system and browser software used by each user of the Site.

We also collect information about the device you use to access or use our Site, such as the type of device you use (for example, mobile, PC, etc.); type of network connection (for example, Bluetooth, WiFi, 3G, 4G, LTE, etc.); operating system and version (for example, iOS, Android or Windows); language settings on your mobile device mobile operator, etc.

We also use (or may use) cookies or similar tracking technologies when you visit our Site. Cookies usually do not contain any personally identifiable information. However, the personal information we hold about you may be related to information stored and received from cookies.

For more information on the use of cookies, please refer to the Projector Cookie Policy.



2. Personally Identifiable Information, provided directly by you or third parties

Some of our Site's functionality can be used without revealing any Personally Identifiable Information, though for features or Services related to the Content Offerings, Personally Identifiable Information is required.

To access certain features and benefits on our Site (collectively, "services"), you may need to submit, or we may collect, "Personally Identifiable Information" (i.e., information that can be used to identify you)(may also be referred to as "personal data" or "personal information").

Personally Identifiable Information can include information such as your name, email address, phone number, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Projector. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our Site.

We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other Projector' events, and send you email messages about Site maintenance or updates.



Personal Identifiable Information, in particular, but not exclusively, may be collected from the following sources:

· Account Registration. If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as, for example, your name, profile picture, phone number, email address, etc.

· Updates. Projector may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these Services, you may be required to provide us with Personally Identifiable Information such as your name and email address.

· Participation in Content Offerings. Projector offers users the opportunity to participate in different Content Offerings on or through the Site. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.

If you participate in a Content Offering, we may collect from you certain student-generated content, such as assignments you submit to instructors, peer-graded assignments, and peer grading student feedback. We also collect course data, such as student responses to quizzes, exams, and surveys. You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate or submit such assignments, exams, or surveys.

· Identity Verification. Projector may offer you the ability to verify your identity for select Services. In order to enroll for these Services, you may be required to provide us or our third-party identity verification vendor with Personally Identifiable Information such as your name, phone number, email etc.

· Communications with Projector. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.

· Third Party Sites. We may receive Personally Identifiable Information when you access or log-in to a third party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personally Identifiable Information available from the third party site.

· Surveys. We may receive Personally Identifiable Information when you provide information in response to a survey operated by us or a Content Provider.

· Partner sites. Partner sites providing Content Offering related tools and services to Projector users may collect nonfinancial individual level user data regarding the individual's use of that partner site while the partner sites provide those services to Projector. The partner sites may share that data with Projector to improve Projector's Services, the partner site's services, and the individual's educational experience. This data includes information such as the amount of time spent on the partner site and pages viewed.

· Third Party Credit Card Processing. Projector provides you with the ability to pay for Content Offerings and other Services using a credit card through a third-party payment processing service provider. Please note that our service provider – not Projector – collects and processes your credit card information.

You are responsible for ensuring the accuracy of all Personal Identifiable Information you provide to Projector.

Inaccurate information may affect your ability to use the Site and our ability to contact you. You are obliged to update your Personal Identifiable Information in the event of its change; in particular, make timely changes to the email address, because this is one of the main ways to communicate with you.

Before disclosing to us the Personal Identifiable Information of a third party, you must obtain the consent of that person to both disclose and process this information per the terms of this Policy.

ІІІ. Under what conditions Projector uses your information


ІІ. What information Projector collects from you
Per the Policy the following types of information are subject to collection, storage, and use:

1. Information concerning your use of our Site.

When you visit our Site, we may track, collect and summarize information, indicating, inter alia, which pages of our Site you have visited, the order in which they were visited, when they were visited, and which hyperlinks you visited.



We also collect information from the URLs from which you link to our Site. The collection of such information may include the registration of the IP address (also, the Internet service provider of the user and the geographical location of the point of connection), the operating system and browser software used by each user of the Site.

We also collect information about the device you use to access or use our Site, such as the type of device you use (for example, mobile, PC, etc.); type of network connection (for example, Bluetooth, WiFi, 3G, 4G, LTE, etc.); operating system and version (for example, iOS, Android or Windows); language settings on your mobile device mobile operator, etc.

We also use (or may use) cookies or similar tracking technologies when you visit our Site. Cookies usually do not contain any personally identifiable information. However, the personal information we hold about you may be related to information stored and received from cookies.

For more information on the use of cookies, please refer to the Projector Cookie Policy.



2. Personally Identifiable Information, provided directly by you or third parties

Some of our Site's functionality can be used without revealing any Personally Identifiable Information, though for features or Services related to the Content Offerings, Personally Identifiable Information is required.

To access certain features and benefits on our Site (collectively, "services"), you may need to submit, or we may collect, "Personally Identifiable Information" (i.e., information that can be used to identify you)(may also be referred to as "personal data" or "personal information").

Personally Identifiable Information can include information such as your name, email address, phone number, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Projector. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our Site.

We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other Projector' events, and send you email messages about Site maintenance or updates.



Personal Identifiable Information, in particular, but not exclusively, may be collected from the following sources:

· Account Registration. If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as, for example, your name, profile picture, phone number, email address, etc.

· Updates. Projector may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these Services, you may be required to provide us with Personally Identifiable Information such as your name and email address.

· Participation in Content Offerings. Projector offers users the opportunity to participate in different Content Offerings on or through the Site. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.

If you participate in a Content Offering, we may collect from you certain student-generated content, such as assignments you submit to instructors, peer-graded assignments, and peer grading student feedback. We also collect course data, such as student responses to quizzes, exams, and surveys. You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate or submit such assignments, exams, or surveys.

· Identity Verification. Projector may offer you the ability to verify your identity for select Services. In order to enroll for these Services, you may be required to provide us or our third-party identity verification vendor with Personally Identifiable Information such as your name, phone number, email etc.

· Communications with Projector. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.

· Third Party Sites. We may receive Personally Identifiable Information when you access or log-in to a third party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personally Identifiable Information available from the third party site.

· Surveys. We may receive Personally Identifiable Information when you provide information in response to a survey operated by us or a Content Provider.

· Partner sites. Partner sites providing Content Offering related tools and services to Projector users may collect nonfinancial individual level user data regarding the individual's use of that partner site while the partner sites provide those services to Projector. The partner sites may share that data with Projector to improve Projector's Services, the partner site's services, and the individual's educational experience. This data includes information such as the amount of time spent on the partner site and pages viewed.

· Third Party Credit Card Processing. Projector provides you with the ability to pay for Content Offerings and other Services using a credit card through a third-party payment processing service provider. Please note that our service provider – not Projector – collects and processes your credit card information.

You are responsible for ensuring the accuracy of all Personal Identifiable Information you provide to Projector.

Inaccurate information may affect your ability to use the Site and our ability to contact you. You are obliged to update your Personal Identifiable Information in the event of its change; in particular, make timely changes to the email address, because this is one of the main ways to communicate with you.

Before disclosing to us the Personal Identifiable Information of a third party, you must obtain the consent of that person to both disclose and process this information per the terms of this Policy.

ІІІ. Under what conditions Projector uses your information
The Personal Identifiable Information you provide to us through the Site will be used for the purposes specified in this Policy or on the relevant pages of the Site.



We may use your Personal Identifiable Information under the following conditions:

a) to fulfill our obligations to you, such as:

• compliance with the Terms and conditions (Public offers) that you accept by browsing the relevant pages of the Site;

• providing you with the Services purchased through the Site and complying with the terms of such Services providing;

• providing you with the opportunity to use the services available on the Site;

• sending you messages, invoices, and payment reminders, and receiving payments from you;

• sending you non-marketing commercial messages;

• sending you e-mails that you have specifically requested;

• sending you an e-mail, if you ordered it (you can at any time refuse to receive the relevant mailings from us);

• send you marketing communications about our business or the business of carefully selected third parties that we believe may have interest for you, through publications or, if you have specifically agreed to do so, by emailing or using similar technologies. (You may opt-out of receiving marketing communications at any time);

b) to comply with our legal obligations to third parties; or

c) to secure our legitimate interests or the legitimate interests of others. In this case, our legitimate interests are:

• manage, develop and expand the scope of Projector's activities;

• manage the Site and provide the Services;

• select appropriately qualified suppliers;

• build relationships with partners and research institutions;

• conduct research and statistical analysis;

• conduct marketing activities;

• ensure internal administrative and audit objectives;

• ensure the security of our Site and prevent fraud;

• check the compliance of any activity carried out on the Site with the conditions and rules governing the use of our Site (including monitoring of private messages sent through the private messaging service of our Site).

d) for other purposes.



Which legal basis applies to a specific processing activity will depend on the type of personal information processed and the context in which it is processed.



If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.



We may process your personal information in some cases for marketing purposes based on your consent (which you may withdraw at any time as described below).



If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent or delete your account and we will stop doing so. However, if you withdraw your consent, this may impact the ability of us to be able to provide our Services to you.

If you provided personal information for publication on our Site, we would publish it. Otherwise, we will use this information under the license you gave us.

IV. How Projector uses your information
1. Information relating to your use of our Site.

We use information relating to your use of the Site to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our Services and the Site.

2. Personally Identifiable Information provided directly by you or via third parties.

Except as outlined in this Policy or as specifically agreed to by you, Projector will not disclose any of your Personally Identifiable Information.

In addition to the other uses set forth in this Policy, we may disclose and otherwise use Personally Identifiable Information as described below.

· Providing the Site and our Services. We use Personally Identifiable Information which you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or Services that you request from us.

· Technical support and security. We may use Personally Identifiable Information to provide technical support to you, where required, and to ensure the security of our Services and the Site.

· Participation in Content Offerings. We use the Personally Identifiable Information that we collect from you when you participate in a Content Offering through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of an Online Course. We may also share your Personally Identifiable Information and your performance in a given Content Offering with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.

· Identity Verification. For Services that require identity verification, we may use the Personally Identifiable Information that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you.

· Communications with or from Projector. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.

· Communications with Projector Business Partners. We may share your Personally Identifiable Information with Content Providers and other business partners of Projector so that Content Providers and other business partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.

· Research. We may use the data for research related to online education.

· Disclosure to Projector Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, "Contractors") to assist us in providing our Services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Content Offerings. Access to your Personally Identifiable Information by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.

· Government Authorities; Legal Rights and Actions. Projector may share your Personally Identifiable Information with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law.

· Disclosure to Acquirers. Projector may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of Projector to which your Personally Identifiable Information relates.

· Disclosure to employees, managers, partners of Projector, in the scope and objectives defined in the Policy.

Projector will not disclose your Personal Identifiable Information to third parties, except as provided in this Policy.

International privacy practices

Projector's Sites are primarily operated and managed on servers located and operated within the Ukraine. In order to provide our products and Services to you, we may send and store your Personally Identifiable Information (also commonly referred to as personal data) outside of the country where you reside or are located.

Your Personally Identifiable Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personally Identifiable Information. We are committed to protect the privacy and confidentiality of Personally Identifiable Information when it is transferred. If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law.

However, we may not prevent the use of your Personal Identifiable Information published by you on the Internet through our Site, or its unauthorized use for criminal purposes by third parties.


V. Retention of Personally Identifiable Information
We keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is collected and processed.

Your Personally Identifiable Information will be deleted as soon as you submit a notice requesting the deletion of your account (your personal data).
VІ. Confidentiality & Security of Your Personally Identifiable Information
We consider the confidentiality and security of your information to be of the utmost importance. We will use industry-standard physical, technical, and administrative security measures to keep your Personally Identifiable Information confidential and secure, and will not share it with third parties, except as otherwise provided in this Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law.

Because the Internet is not a 100% secure environment, Projector cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails communications are typically not encrypted and should not be considered secure.

All electronic financial transactions made through our Site will be protected by data encryption technology.
VІІ. Your rights concerning to Personal Identifiable Information
You can ask Projector for any Personal Identifiable Information we have about you and receive a copy free of charge (unless the law allows charging a fee). Projector reserves the right to refuse to provide information at your request, within the applicable law.

You have the right to instruct us not to process your Personal Identifiable Information for marketing purposes, by marking the appropriate form of consent. In the absence of your special waiver, it is considered that you agree that your personal information may be used for marketing purposes (if you agreed for that earlier).

You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us, and request that we delete or provide you with a copy of your personal data by logging into the Site and visiting your user account page.

If you would like further information about your rights or would like to exercise any of them, you may also contact us via hello@prjctr.com.ua.



If you reside or are located in the EEA, you have the right to request that we:

· provide access to any Personally Identifiable Information we hold about you;

· prevent the processing of your Personally Identifiable Information for direct-marketing purposes;

· update any Personally Identifiable Information which is out of date or incorrect;

· delete any Personally Identifiable Information which we are holding about you;

· restrict the way that we process your Personally Identifiable Information;

· provide your Personally Identifiable Information to a third-party provider of services; or

· provide you with a copy of any Personally Identifiable Information that we hold about you.

We try to answer every email promptly where possible and provide our response within the time stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personally Identifiable Information. Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation. When you email us with a request, we may ask that you provide us with the information necessary to confirm your identity.
VІІІ. No information from children under 14.
Projector strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 14 is prohibited, and certain regions and Content Offerings may have additional requirements and/or restrictions. In line with this belief, we do not knowingly collect or maintain Personally Identifiable Information on our Site from persons under 14 years of age, and no part of our Site is directed to persons under 14 years of age. If you are under 14 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 14 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such Personally Identifiable Information.

ІХ. Question, Suggestion and Complaints



If you have any privacy-related questions, suggestions, unresolved problems, or complaints, you may contact us via hello@prjctr.com.ua.

To contact Projector, please use the following contact info:

041021, Kyiv, Olhynska str., bldg. ½, ap.16

Tel.: +38 097 015 92 72

hello@prjctr.com.ua