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Privacy policy

This Privacy Policy (hereinafter referred to as the Privacy Policy) applies to all information posted on the website on the Internet – https://european-coaching.university/ – that the Resource (website) located on the domain name https://european-coaching.university/ (as well as its subdomains), can obtain about the User during the use of the website https://european-coaching.university/ (as well as its subdomains), programs, and products.
This Privacy Policy is drawn up in compliance with the requirements of the current legislation of Hong Kong, including the Personal Data (Privacy) Ordinance (Cap. 486). Using the services of the Site indicates the User's unconditional consent to this Privacy Policy and the conditions for processing their personal data specified therein; in case of disagreement with these conditions, the User should refrain from using the services.

DEFINITIONS
1.1. “Administration of the Resource https://european-coaching.university/” (hereinafter – Administration, Operator) – authorized employees managing the Resource on behalf of ECU Limited, registered under registration number 76667088, UNIT B, 11/F YAM TZE COMM BLDG, 23 THOMSON RD, WAN CHAI, HONG KONG, who organize and (or) carry out the processing of personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
1.2. “Personal Data” - any information relating to directly or indirectly identified or identifiable individuals (subject of personal data), including:
1.2.1. Personal information that the User provides about themselves when registering (creating an account, filling out a course application, writing a review, etc.) or in the process of using the Services, including the User’s personal data. Mandatory information required for the Services is specially marked. Other information is provided at the User’s discretion.
1.2.2. Data automatically transmitted to the Site Services during their use via software installed on the User's device, including IP address, cookie data, information about the User’s browser (or other software through which the services are accessed), technical characteristics of the equipment and software used by the User, the date and time of access to services, addresses of requested pages, and other similar information.
1.3. “Processing of Personal Data” - any action (operation) or a set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.4. “Confidentiality of personal data” - a requirement for the Operator or other persons who have gained access to personal data to prevent their dissemination without the consent of the subject of personal data or other legal basis.
1.5. “Resource https://european-coaching.university/” (hereinafter – Resource) - a set of interconnected web pages placed on the Internet at a unique address (URL): https://european-coaching.university/, as well as its subdomains.
1.6. “Subdomains of the site https://european-coaching.university/” and other temporary pages, are pages on which contact information may be indicated: ECU Limited, registration number 76667088; Address: UNIT B, 11/F YAM TZE COMM BLDG, 23 THOMSON RD, WAN CHAI, HONG KONG. Email address: european.coaching.university@gmail.com.
1.7. “User of the Resource https://european-coaching.university/” (hereinafter – User) – a person who has access to the Resource via the Internet and is using the information and materials of the Resource https://european-coaching.university/.
1.8. “Cookies” - a small piece of data sent by a web server and stored on the User's computer, which a web client or web browser sends to the web server in an HTTP request each time it tries to open a page of the relevant site.
1.9. “IP address” - a unique network address of a node in a computer network built using the IP protocol.
1.10. “Current Security Threats to Personal Data” – a set of conditions and factors creating a real danger of unauthorized, including accidental, access to personal data during their processing in the information system, resulting in the destruction, modification, blocking, copying, provision, dissemination of personal data, as well as other unlawful actions.

GENERAL PROVISIONS
2.1. The User’s use of the Resource implies their consent to this Privacy Policy and the conditions for processing personal data.
2.2. If the User disagrees with the terms of the Privacy Policy, they must stop using the Resource.
2.3. This Privacy Policy applies to the Resource https://european-coaching.university/.
2.4. The Resource does not control and is not responsible for third-party websites to which the User can go through links available on the Resource https://european-coaching.university/.
2.5. The Administration does not verify the accuracy of personal data provided by the User of the Resource https://european-coaching.university/.

SUBJECT OF THE PRIVACY POLICY
3.1. This Privacy Policy establishes the obligations of the Administration regarding nondisclosure and ensuring the protection of the confidentiality of personal data that the User provides at the request of the Administration when registering on the Resource or otherwise using the Resource, as well as when placing an order to purchase goods or services.
3.2. The personal data allowed for processing under this Privacy Policy are provided by the User by filling out the registration form or feedback form on the Resource and include the following information:
3.2.1. Surname, name, patronymic of the User;
3.2.2. Contact phone number of the User;
3.2.3. Email address (e-mail) of the User;
3.2.4. User's place of residence (at the request of the Administration).
3.3. The Resource protects Data that is automatically transmitted during viewing of advertising blocks and when visiting pages with a statistical system script installed (“pixel”):
3.3.1. IP address;
3.3.2. Information from cookies;
3.3.3. Information about the browser (or other program accessing the display of advertising);
3.3.4. Access time;
3.3.5. The address of the page where the advertisement block is located;
3.3.6. Referrer (address of the previous page).
3.4. Disabling cookies may result in the inability to access parts of the Resource requiring authorization.
3.5. The Resource collects statistics about the IP addresses of its visitors. This information is used to identify and solve technical problems, for control of the legality of financial payments.
3.6. Any other personal information not specified above (purchase history, operating systems, etc.) is subject to secure storage and non-dissemination, except as provided in clauses 5.2. and 5.3. of this Privacy Policy.

PURPOSES OF PROCESSING USER PERSONAL INFORMATION
4.1. The Resource (Site) collects and stores only those personal data necessary for providing services or executing agreements and contracts with the User, except where the law requires the obligatory storage of personal information for a specified period.
4.2. The User's personal data may be used by the Resource Administration in the following cases:
4.2.1. To identify the User registered on the Resource to place an order and (or) conclude, for example, an Offer Agreement on providing information and consulting services by remote means.
4.2.2. To provide the User with access to personalized data of the Resource.
4.2.3. To establish feedback with the User, including sending notifications and requests concerning the use of the Resource, rendering services, processing requests, and applications from the User.
4.2.4. To determine the location of the User to ensure security and prevent fraud.
4.2.5. To confirm the accuracy and completeness of the personal data provided by the User.
4.2.6. To create an account if the User has consented to create an account.
4.2.7. To send notifications to the User regarding the Resource (if necessary).
4.2.8. To process and receive payments, confirm tax or tax benefits, dispute a payment, determine the right to a User's credit line.
4.2.9. To provide effective customer and technical support to the User in case of problems related to the use of the Resource.
4.2.10. To provide the User, with their consent, updates of the product, special offers, information on prices, newsletters, and other information on behalf of the Resource or Resource partners.
4.2.11. To conduct advertising activities with the User's consent.
4.2.12. To provide access to the User to websites or services of Resource partners to receive products, updates, and services.

METHODS AND TERMS OF PROCESSING PERSONAL INFORMATION
5.1. The processing of the User’s personal data is carried out without a time limit, by any legal means, including in personal data information systems using automation tools or without using such means.
5.2. The User agrees that the Administration has the right to transfer personal data to third parties, in particular, courier services, postal organizations, telecommunication operators, solely to fulfill the Offer Agreement, to which the User has acceded on the Resource.
5.3. The User's personal data can be transferred to authorized state authorities of Hong Kong only on the grounds and in the manner established by Hong Kong legislation.
5.4. In case of loss or disclosure of personal data, the Administration informs the User about the loss or disclosure of personal data.
5.5. The Administration takes the necessary organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, modification, blocking, copying, dissemination, as well as other illegal actions by third parties.
To ensure the security of personal data when processing it in the information system in accordance with Hong Kong legislation, the Resource Administration may contract a legal entity or individual entrepreneur, which, if necessary, holds a license for activities related to the technical protection of confidential information. The measures to ensure the security of personal data, implemented within the framework of the personal data protection system, take into account current threats to personal data security and the applied information technologies, including but not limited to the following measures:
Identification and authentication of subjects and objects of access;
Access management of subjects to objects of access;
Limiting the software environment;
Protecting machine-readable media storing and (or) processing personal data;
Registration of security events;
Antivirus protection;
Detection (prevention) of intrusions;
Control (analysis) of the security of personal data;
Ensuring the integrity of the information system and personal data;
Ensuring the availability of personal data;
Protecting the virtualization environment;
Protecting technical means;
Protecting the information system, its devices, communication systems, and data transmission systems;
Detecting incidents (one event or a group of events) that could lead to disruptions or failures in the functioning of the information system and (or) the emergence of personal data security threats, and responding to them;
Configuring the information system and personal data protection system;
Checking system and (or) application software, including the source code, for undeclared features using automated tools and (or) without using such tools;
Penetration testing of the information system;
Using system and (or) application software developed using secure programming methods.
5.6. The Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.

RIGHTS AND OBLIGATIONS OF THE PARTIES
6.1. The User has the right to demand the Administration of the Resource to clarify their personal data, block, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights.
6.2. If the User believes that the Administration of the Resource is processing their personal data in violation of the requirements of Hong Kong’s Personal Data (Privacy) Ordinance or otherwise violates their rights and freedoms, the User has the right to appeal the actions or inaction of the operator to the authorized body for the protection of the rights of personal data subjects or in court, including compensation for damages and (or) compensation for moral harm in court.
6.3. The User has the right to withdraw consent to the processing of personal data by sending a notification to the Administration of the Resource at the email address: european.coaching.university@gmail.com. The Administration of the Resource stops processing personal data within the time frame established by the current legislation of Hong Kong.
6.4. The User must:
6.4.1. Provide information about personal data necessary for using the Resource.
6.4.2. Update and supplement the provided information about personal data in case of changes.
6.5. The Administration of the Resource must:
6.5.1. Use the obtained information solely for the purposes specified in section 4 of this Privacy Policy.
6.5.2. Ensure the confidentiality of confidential information, not disclose it without the prior written permission of the User, as well as not sell, exchange, publish, or disclose in any other possible ways the User’s transmitted personal data, except for p.p. 5.2. and 5.3. of this Privacy Policy.
6.5.3. Take precautions to protect the confidentiality of the User's personal data according to the procedure usually used to protect such information and provided by the Personal Data (Privacy) Ordinance.
6.5.4. Block personal data related to the respective User from the moment of the User's request or request from their legal representative or authorized body for the protection of the rights of personal data subjects for the verification period, in case of inaccurate personal data or unlawful actions.

RESPONSIBILITIES OF THE PARTIES
7.1. The Administration of the Resource, which has failed to fulfill its obligations, is liable for losses incurred by the User due to the unlawful use of personal data, in accordance with Hong Kong legislation, except for the cases provided for in p.p. 5.2., 5.3., and 7.2. of this Privacy Policy.
7.2. In the event of loss or disclosure of Confidential Information, the Administration is not responsible if this confidential information:
7.2.1. Became public before its loss or disclosure.
7.2.2. Was received from a third party before it was received by the Administration of the Resource.
7.2.3. Was disclosed with the User's consent.
7.3. The User bears full responsibility for compliance with the requirements of Hong Kong legislation, including laws on advertising, copyright and related rights, protection of trademarks, but not limited to the above, including full responsibility for the content and form of materials.
7.4. The User acknowledges that responsibility for any information (including but not limited to: data files, texts, etc.) that they may access as part of the Resource, rests with the person who provided such information.
7.5. The User agrees that the information provided to them as part of the Resource may be an intellectual property object, the rights to which are protected and belong to other Users, partners, or advertisers who post such information on the Resource https://coachingup.university/. The User is not entitled to make changes, lease, loan, sell, distribute, or create derivative works based on such Content (in whole or in part), except when such actions were directly permitted in writing by the owners of such Content based on the terms of a separate agreement.
7.6. Regarding text materials (articles, publications available in the public domain on the Resource), their distribution is allowed, provided that a link to the site (any other resource) and the author's full name (pseudonym, nickname), who wrote this text material, is given.
7.7. The Administration is not responsible to the User for any loss or damage suffered by the User as a result of deleting, failing, or inability to save any Content and other communication data contained on the Resource or transmitted through such Resource.
7.8. The Administration is not responsible for any direct or indirect losses caused due to: use or inability to use the site or specific services; unauthorized access to the User's communications; actions or statements of any third party on the site.
7.9. The Administration is not responsible for any information posted by the User on the Resource, including but not limited to, information protected by copyright without the express consent of the copyright holder.

DISPUTE RESOLUTION
8.1. Before filing a lawsuit on disputes arising from the relations between the User of the Resource https://european-coaching.university/ and the Administration, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute).
8.2. The recipient of the claim within 30 calendar days from the date of receipt of the claim, in writing, notifies the claimant of the claim about the results of the consideration of the claim.
8.3. If an agreement is not reached, the dispute will be referred to the court at the place of registration of the Administration.
8.4. This Privacy Policy and the relations between the User and the Administration of the Resource are governed by the current legislation of Hong Kong.

ADDITIONAL PROVISIONS
9.1. The Administration of the Resource has the right to make changes to this Privacy Policy without the consent of the User.
9.2. The new Privacy Policy comes into force from the moment it is posted on the Resource unless otherwise provided by the new version of the Privacy Policy.
9.3. All suggestions or questions regarding this Privacy Policy should be reported to: european.coaching.university@gmail.com.
9.4. The current Privacy Policy is posted on the page at https://european-coaching.university/.
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