Privacy Policy

General Provisions

kood/Ukraine ensures that the processing of personal data is carried out in compliance with the Law of Ukraine "On the Protection of Personal Data" No. 2297-VI and other applicable Ukrainian laws and regulations. The organisation also follows best practices for data protection and information security.

kood/Ukraine respects individuals' right to privacy and takes all reasonable measures to protect personal data and maintain the security of its information systems.

Definitions

Platform

The online learning platform provided by kood/Ukraine and/or its authorised data processors, used by Students.

Processing of personal data

Any action or set of actions such as collecting, registering, accumulating, storing, adapting, altering, updating, using, distributing, depersonalising, or destroying personal data.

Student

A person enrolled in the educational programme of kood/Odesa or kood/Zhytomyr and using the Platform.

Purpose of Processing Personal Data and Its Legal Basis

kood/Ukraine processes personal data for the purposes of enrolling students in educational programmes, monitoring their academic progress and achievements, providing educational tasks, resources, and communication tools, facilitating interaction between students, staff, and educators, maintaining necessary academic and administrative records, and collecting gender-related data for statistical purposes to promote diversity and inclusion in the technology sector.

The legal basis for processing personal data is primarily the consent of the data subject, in accordance with Article 6 of the Law of Ukraine "On the Protection of Personal Data." In cases where data processing is necessary to fulfil the terms of education-related agreements, such processing is carried out without additional consent as permitted by Ukrainian law. In certain situations, kood/Ukraine may also rely on legitimate interest as a legal basis for processing, provided such interests do not override the fundamental rights and freedoms of the data subjects.

How kood/Ukraine Collects Personal Data

kood/Ukraine collects personal information on the Platform directly when the Student:

• —registers an account, providing name, email address, date of birth, and enrolment details;
• —participates in educational activities including forum discussions, assignment submission, and assessments;
• —customises their user profile by entering preferences, learning styles, and feedback;
• —engages with communication tools such as messages, discussions, or support requests.

kood/Ukraine collects personal information indirectly when:

• —the administrative system integrates with the platform, transferring student information such as accounts, enrolment status, and academic history;
• —data is collected via cookies and similar technologies including login data, IP addresses, browser types, and access times;
• —the Platform automatically generates records of student interactions such as time spent on materials, progress tracking, and resource access patterns.

Transmission of Personal Data

kood/Ukraine processes personal data within Ukraine or within countries recognised by Ukrainian law as providing an adequate level of personal data protection. All data is received, transmitted, and processed digitally, in accordance with applicable Ukrainian data protection legislation.

Disclosure of Personal Data

kood/Ukraine engages third-party service providers to operate and maintain the Platform. These providers have access to personal data only to the extent necessary to perform their services and are contractually obligated to ensure confidentiality and security in accordance with Ukrainian data protection laws.

Retention and Deletion of Personal Data

Rights of the Student (Data Subject)

The Student has the right at any time to request:

• —access to personal data (accessed via the Platform);
• —correction of inaccurate personal data;
• —deletion of personal data;
• —restriction of processing of personal data;
• —withdrawal of data-processing consent (if applicable).

To exercise these rights, submit a request to info-ua@kood.tech. Requests will be responded to within 30 calendar days. The Student also has the right to lodge a complaint with the supervisory authority.

Changes and Validity

kood/Ukraine reserves the right to amend the conditions for personal data processing in accordance with applicable Ukrainian data protection laws. In the event of substantial changes, users will be notified at least 1 month in advance through the Platform. Continued use of the Platform after changes take effect constitutes acceptance of the updated terms. The current conditions are valid from 01.01.2024.