Privacy Policy "ABITLY"

1.1. This Privacy Policy defines the privacy conditions when using the Website — abitly.org, hereinafter referred to as the "Website", general rules for collection, processing, distribution, use and storage of personal data of Website Users by the Website owner.

1.2. We comply with all requirements of applicable law to protect your privacy. This Privacy Policy is a legal document that explains what information about you we will collect when you use the Website, how this information will be used and how we will transfer and protect such information.

1.3. EVERY USER MUST CAREFULLY READ AND COMPLY WITH THE TERMS OF THIS PRIVACY POLICY.

1.4. BY USING THE WEBSITE, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. YOU ALSO AGREE THAT YOUR PERSONAL DATA THAT WE COLLECT IS PROVIDED TO US WITH YOUR VOLUNTARY CONSENT.

1.5. You provide and guarantee us the right to process your personal data, including the right to perform the following actions to process your personal data (fully or partially in an automated system): storage, registration, modification, restoration and deletion. You also agree to the inclusion of your personal data in our personal data database and that such inclusion does not require any additional notifications.

2.1. In this Privacy Policy, the following terms have the following meanings:

2.2. Other terms and definitions used in this Privacy Policy should be understood in accordance with the provisions of the TERMS AND CONDITIONS OF USE "ABITLY", unless otherwise expressly stated in this Privacy Policy.

3.1. Users agree to provide us, immediately upon request notification, with any information (including Personal Data) that we deem necessary to comply with the requirements of any law and/or subordinate regulatory act.

3.2. Technical (software) means of the Website may collect such Personal Data of Users as: name and/or surname, place of residence, mobile phone number, email address, links to social networks (instagram, facebook, tiktok, telegram, etc.), gender, date of birth, specialization, educational institution where the User is studying or has graduated from, course of study, faculty, User's photo, other information that may be specified by the User. Information provided by Users during registration may be displayed on the Website in whole or in part.

3.3. To implement the functions of the Website information system, we also collect such Personal Data as: history of active sessions of Users in the Website information system. When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some cookies that are installed on your device. In addition, when you browse the Website, we collect information about individual web pages or products you view, which websites or search terms redirected you to the Website, and information about how you interact with the Website. We call this automatically collected information "Device Information".

We collect Device Information using the following technologies:

• "Cookies" are data files that are placed on your device or computer and often contain an anonymous unique identifier. For more information about cookies and how to disable cookies, visit www.allaboutcookies.org.
• "Log files" track actions occurring on the Website and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. – "Web beacons", "tags", and "pixels" are electronic files used to record information about how you browse the Website.

We use the device information we collect to detect potential risk and fraud (specifically, your IP address), and generally to improve and optimize our Website (for example, by generating analytics about how Users browse and interact with the Website, and to evaluate the success of our marketing and advertising campaigns). We also use Google Analytics to help understand how our Users use the Website. You, as a Visitor or Registrant, provide your voluntary consent to the collection and processing of this data and its transfer to third parties to ensure the functioning of the Website and its proper operation.

3.4. The above information may be requested and/or collected by us before activating your account through the Website and/or before we provide any services available through the Website. Any doubts about the authenticity and authenticity of the information you provide are considered a significant reason for refusing access to the Website and/or related services.

3.5. You, as a User, hereby expressly agree, declare and warrant that all information provided by you is current, complete and accurate.

3.6. We also process User requests to the Website support service.

3.7. When you access the Website or use our services, we (or Google Analytics or a similar service provider on our behalf) may place small data files called cookies on your computer or other device. We use these technologies to mark you as our user; customize our Website and advertising; measure advertising effectiveness and collect information about your computer or other device; to reduce possible risks, help prevent fraud and increase trust and security.

3.7.1. Most browsers are set to accept cookies by default. You can control the use of cookies in your internet browser settings. You should refer to your browser's instructions, Help section, or similar resource to learn more about how to manage cookies and possibly reset your browser settings to refuse all cookies. Or you can specify in your browser settings that you want to receive notifications when cookies are sent. However, if you do not accept cookies, some pages on our Website may not display correctly and some features may not work properly. If you have any questions about cookie disabling rules, please contact your browser developer.

3.8. YOU AGREE THAT YOUR PERSONAL DATA MAY BE PROCESSED AND STORED BY US AND/OR OUR CONTRACTORS FOR THE TIME NECESSARY TO PERFORM THE TASKS ARISING FROM THE FUNCTIONAL PURPOSE OF THE WEBSITE.

We use the information received from you for the following purposes.

4.1. We collect only the User data that is necessary to implement the functional purpose of the Website. Thus, we use your Personal Data for:

• implementation of functions and/or administration of the Website and/or provision of services, including but not limited to providing assistance in searching for higher education institutions,
• obtaining additional information about such institutions, highlighting admission conditions, obtaining statistical data on enrollment in higher education institutions, etc.
• sending you technical notifications, support service notifications and administrative notifications;
• tracking and analyzing actions related to the use of the Website and/or our services;
• providing third parties with statistical information about Users (but these third parties will not be able to identify any individual User from the information we provide);
• checking compliance with the TERMS AND CONDITIONS OF USE "ABITLY";
• improving the quality of the Website (its services), convenience of its use for Users, developing new services and services;
• targeting advertising materials;
• conducting statistical and other research based on anonymized data.
• processing complaints and comments.

4.2. The Website Owner is the sole controller and processor of Personal Data, except in cases where there is an objective need for the Website Owner to process and/or store information using contractors.

5.1. The Website Owner will apply all measures determined by applicable law to maintain the confidentiality of your Personal Data, including, but not limited to, firewalls and data encryption, physical access control to our data processing centers and authorization of information access, control measures (which are designed in accordance with the requirements of applicable law and regulations), authorization of access to Personal Data only for those employees or contractors who need it to perform their official duties.

5.2. We reserve the right to store, process and transfer your Personal Data to our servers in various jurisdictions where our infrastructure facilities and/or our service providers are located. Your data may also be processed by employees working for us and/or one of our service providers. Such personnel may be involved in providing our services and/or processing your data and/or providing support. By submitting your personal data, you agree to this transfer, storage and processing. We take necessary measures to ensure the safe handling of your Personal Data in accordance with this Privacy Policy.

6.1. We may transfer your Personal Data to:

• our contractors and service providers who help us, as well as specific Users where necessary, to achieve the goals and purpose of the Website;
• our banking partners;
• companies with which we plan to merge and/or be acquired (in case of such merger, we will require the newly formed company to follow the Privacy Policy terms regarding the processing of Personal Data);
• law enforcement agencies, government officials and/or other third parties when we are obliged to do so by virtue of law, court decision and/or other similar legal basis; or when we in good faith believe that disclosure of Personal Data is necessary to prevent physical harm and/or financial loss, to report suspected illegal activity and/or to investigate violations of our policies;
• our partners and/or contractors for processing Personal Data, hired by us and/or cooperating with us, whose services we need from a practical point of view;
• other third parties – 1) only with your prior consent or 2) at your direction, or 3) in connection with your active actions related to your participation in events conducted by us, or 4) in connection with filling out relevant registration or other forms/questionnaires/applications, etc. on the Website.

7.1. Our Website may from time to time contain links to websites and/or mobile applications of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Website is advertised). If you follow a link to any of these websites and/or mobile applications, please note that these websites and any services that may be available through them have their own privacy policies, and that we bear no responsibility for these policies and/or for any Personal Data that may be collected through these websites and/or services (for example, contact information, location data). Please review these policies before submitting any personal data through such websites and/or using third-party services.

8.1. In accordance with applicable law and as necessary to ensure the proper functioning of the Website and Website services, we may store your Personal Data. This requirement is due to the need to comply with legal obligations and resolve possible disputes. We may store your Personal Data for as long as necessary to fulfill the goals and purpose of the Website services. Moreover, your Personal Data may be stored beyond the specified period of time and for as long as we need to have relevant information to respond to any questions that may arise later.

9.1. We use appropriate electronic and organizational security measures to protect the information you provide from loss, misuse, disclosure, alteration and destruction.

10.1. We reserve the right to change and/or supplement this Privacy Policy at any time. You should regularly review this Privacy Policy. By continuing to use the Website, you agree to all amendments and updates to the Privacy Policy.

11.1. You, as a data subject, have rights under the provisions of the General Data Protection Regulation (EU) 2016/679 (the General Data Protection Regulation (EU) 2016/679) and the Law of Ukraine "On Personal Data Protection". You agree that the method of exercising your rights is governed by the terms of this Privacy Policy.

11.3. ACCESS TO PERSONAL DATA<br/>You have the right to access your personal information so that you can view the Personal Data we have stored and make corrections to your personal data. You can request access to information or make corrections by writing to us at the email address listed below in the "OUR CONTACTS" section. If the information is unavailable or has been changed, we will inform you of the reasons for this.

12.1. You have the right to request correction or deletion of your personal data by sending us an email to [email protected]. You can withdraw your consent to the processing of Personal Data at any time.

12.2. If you withdraw your consent to the processing of Personal Data and we have no legal grounds to continue processing your data, we will stop processing your Personal Data. If we have legal grounds for processing your data, we have the right to continue using your Personal Data within the limits provided by law.

12.3. Please note that we may retain some or all of the User's personal data and not delete it until all possible requirements related to the User's Personal Data have been met (for example, regarding the provision of services, fraud prevention, compliance with any legal obligations, dispute resolution, execution of agreements, etc.). If we delete any data created by the User, including Personal Data, such data will be deleted from the active database, but may remain in our archives. The archived version of the data is not intended for use as a backup and is not available to the general public.

13.1. If you have questions about this Privacy Policy, please contact us at the contact information below: [email protected]