Privacy Policy
Effective date: 10 February 2026
Last updated: 10 February 2026
This Privacy Policy (the “Policy”) describes how Sole Proprietor Rybalchenko Nataliia Oleksandrivna (“we,” “us,” “our”) collects, uses, stores, and protects personal data when you visit or use our website (the “Website”) and/or our online products and services, including our U.S. accounting training course (the “Services”).
1) Controller and Contact Details
Data Controller: Sole Proprietor Rybalchenko Nataliia Oleksandrivna, Ukraine
Registered address: 03148, Kyiv, Yakuba Kolasa St., 2/425
Email (privacy inquiries): nataliia.acct@gmail.com
Payment details (if needed for payments):
IBAN: UA943220010000026007320056549
Bank: JSC "Universal Bank"
If you have questions about this Policy or your personal data, contact us using the details above.
2) Personal Data We Collect
Depending on how you use the Website and Services, we may collect:
2.1 Data you provide directly
Name and surname;
Email address, phone number;
Account credentials (login information; passwords are stored in hashed/encrypted form);
Payment details / proof of payment (typically processed by payment providers; we may receive payment status and limited transaction details such as transaction ID, amount, and date/time);
Invoice/billing details: we do not collect additional invoicing details (address/company, etc.) beyond what is necessary to provide the Services and confirm payment;
Messages you send via chat support, contact forms, email, or other communications.
2.2 Data collected automatically
IP address and device identifiers;
Browser and device information, language, time zone;
Website usage data (pages visited, clicks, session duration, referring source);
Cookies and similar technologies (see Section 9).
2.3 Course-related data (where applicable)
Learning progress, test/homework results, instructor/mentor feedback;
Files/materials you upload for review (homework submissions).
Please do not submit sensitive personal data (e.g., health data). If you include sensitive data in a message or homework submission, we will process it only to respond/provide support and may delete it where feasible.
3) How We Use Your Data (Purposes)
We use personal data to:
provide and operate the Services (course access, learning platform Kwiga, and account management);
process payments (WayForPay, PayPal, and bank transfer where applicable) and provide payment confirmations;
communicate with you (service notices, confirmations, support), including via email and scheduling/communication tools (Calendly, Telegram where applicable);
review homework and provide feedback (where applicable);
maintain security, prevent fraud, and troubleshoot issues;
improve the Website and Services (performance, user experience, and operational needs);
send marketing communications (only where we have a lawful basis, such as consent, or as otherwise permitted by law).
4) Legal Bases (EEA/UK and similar jurisdictions)
Where applicable (e.g., GDPR), we process personal data under one or more of the following legal bases:
Contract: to provide the Services you requested;
Consent: e.g., marketing emails and non-essential cookies where required (if/when used);
Legitimate interests: e.g., service improvement, security, fraud prevention;
Legal obligation: e.g., accounting/tax recordkeeping where required.
5) Sharing and Disclosure
We may share personal data with trusted service providers (“processors”) only as necessary to deliver the Services, such as:
Payment processors: WayForPay, PayPal;
Course/LMS/CRM provider: Kwiga;
Scheduling tool: Calendly (where applicable);
Customer support/communication channel: Telegram (where applicable, if you contact us there);
Hosting/infrastructure providers necessary to operate the Website (where applicable);
Contractors and staff (instructors, mentors, support) with limited access for their tasks.
We do not sell your personal data.
6) International Data Transfers
Your data may be processed in countries other than your country of residence (for example, due to payment providers or infrastructure providers). Where required by law, we use appropriate safeguards for international transfers (such as standard contractual clauses where applicable).
7) Data Retention
We retain personal data only for as long as necessary to:
provide the Services and fulfill the purposes described in this Policy;
comply with legal obligations (e.g., accounting/tax requirements);
resolve disputes and enforce agreements.
8) Your Rights
Depending on your jurisdiction, you may have the right to:
access your personal data;
correct inaccurate or incomplete data;
request deletion (where applicable);
restrict processing;
object to processing (including marketing);
withdraw consent (where processing is based on consent);
data portability (where applicable);
lodge a complaint with a supervisory authority.
To exercise your rights, contact us at nataliia.acct@gmail.com.
9) Cookies and Similar Technologies
We use cookies and similar technologies to:
ensure the Website functions properly (essential cookies);
enhance functionality and user experience.
If/when we use non-essential cookies (such as analytics or marketing cookies), we will request consent where required before placing such cookies. You can also manage cookies through your browser settings.
10) Security
We use reasonable technical and organizational measures to protect personal data. However, no online service can guarantee absolute security.
11) Children’s Privacy
Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will take appropriate steps.
12) Changes to This Policy
We may update this Policy from time to time. The updated version will be posted on this page with a new “Last updated” date.