General Data Protection Regulation (GDPR) Privacy Policy
Last Updated: February 26, 2025
1. Introduction
Avrulden is committed to protecting your personal data and respecting your privacy rights. This GDPR Privacy Policy explains how we collect, use, store, and protect your personal information in compliance with the General Data Protection Regulation.
This policy applies to all users of our services, including visitors to our website, registered users, and anyone who interacts with our platform.
2. Data Controller
The data controller responsible for your personal data is:
Avrulden
Derevianka St, 7, Kharkiv, Kharkiv Oblast, Ukraine, 61018
Email: support@avrulden.com
Phone: +380933141774
3. Legal Basis for Processing
We process your personal data based on the following legal grounds:
Consent: You have given clear consent for us to process your personal data for specific purposes.
Contract: Processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
Legal Obligation: Processing is necessary for compliance with a legal obligation.
Legitimate Interests: Processing is necessary for our legitimate interests or those of a third party, except where such interests are overridden by your rights and interests.
4. Personal Data We Collect
We may collect and process the following categories of personal data:
4.1 Information You Provide
Account Information: Name, email address, phone number, username, and password when you register for an account.
Profile Information: Additional information you choose to provide in your user profile.
Communication Data: Information contained in communications you send to us, including messages, feedback, and support requests.
Learning Data: Quiz responses, test results, progress tracking, scores, and completion records.
4.2 Information We Collect Automatically
Technical Data: IP address, browser type and version, device type, operating system, time zone setting, and location data.
Usage Data: Information about how you use our website and services, including pages visited, time spent, features used, and interaction patterns.
Cookies and Similar Technologies: Data collected through cookies, web beacons, and similar tracking technologies.
5. How We Use Your Personal Data
We use your personal data for the following purposes:
Service Delivery: To provide, maintain, and improve our educational platform and services.
Account Management: To create and manage your user account and authenticate your identity.
Personalization: To customize your learning experience and provide relevant content and recommendations.
Communication: To send you service-related notifications, updates, educational content, and respond to your inquiries.
Analytics: To analyze usage patterns, measure effectiveness, and improve our services.
Security: To detect, prevent, and address technical issues, fraud, and security threats.
Legal Compliance: To comply with legal obligations and enforce our terms and policies.
6. Data Sharing and Disclosure
We do not sell your personal data. We may share your information in the following circumstances:
Service Providers: With third-party vendors who perform services on our behalf, such as hosting, analytics, email delivery, and customer support.
Legal Requirements: When required by law, regulation, legal process, or governmental request.
Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets.
Protection of Rights: To protect our rights, property, safety, or that of our users or the public.
With Your Consent: When you have given explicit consent for specific sharing purposes.
7. International Data Transfers
Your personal data may be transferred to and processed in countries outside your country of residence. When we transfer data internationally, we ensure appropriate safeguards are in place, including:
Standard contractual clauses approved by the European Commission.
Adequacy decisions recognizing that certain countries provide adequate data protection.
Other legally recognized transfer mechanisms under GDPR.
8. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:
Active Accounts: Data is retained while your account remains active.
Legal Requirements: Data may be retained longer to comply with legal, accounting, or reporting obligations.
Legitimate Interests: Data may be retained to resolve disputes, enforce agreements, or for other legitimate business purposes.
When personal data is no longer needed, we will securely delete or anonymize it.
9. Your Rights Under GDPR
Under the General Data Protection Regulation, you have the following rights:
9.1 Right of Access
You have the right to request confirmation of whether we process your personal data and to obtain a copy of that data.
9.2 Right to Rectification
You have the right to request correction of inaccurate or incomplete personal data.
9.3 Right to Erasure
You have the right to request deletion of your personal data in certain circumstances, including when it is no longer necessary for the purposes for which it was collected.
9.4 Right to Restriction of Processing
You have the right to request that we restrict processing of your personal data in certain situations.
9.5 Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
9.6 Right to Object
You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes.
9.7 Right to Withdraw Consent
Where processing is based on consent, you have the right to withdraw that consent at any time.
9.8 Right to Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.
10. Exercising Your Rights
To exercise any of your rights under GDPR, please contact us at:
Email: support@avrulden.com
Phone: +380933141774
We will respond to your request within one month, though this period may be extended by two additional months for complex requests. We will inform you of any such extension.
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:
Encryption of data in transit and at rest.
Regular security assessments and audits.
Access controls and authentication mechanisms.
Employee training on data protection practices.
Incident response and breach notification procedures.
12. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to collect information about your browsing activities. You can control cookie preferences through your browser settings. For detailed information, please refer to our Cookie Policy.
13. Children's Privacy
Our services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child without parental consent, we will take steps to delete that information.
14. Automated Decision-Making
We may use automated processing to personalize your learning experience and provide recommendations. You have the right to object to automated decision-making and to request human intervention in certain circumstances.
15. Changes to This Policy
We may update this GDPR Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by posting the updated policy on our website and updating the effective date. Your continued use of our services after such changes constitutes acceptance of the updated policy.
16. Contact Information
If you have questions, concerns, or requests regarding this GDPR Privacy Policy or our data protection practices, please contact us:
Avrulden
Derevianka St, 7, Kharkiv, Kharkiv Oblast, Ukraine, 61018
Email: support@avrulden.com
Phone: +380933141774
Website: avrulden.com
17. Supervisory Authority
If you are located in the European Economic Area and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection supervisory authority.