Privacy Policy

Privacy Policy

Last Updated: April 26, 2025

1. General concepts

1.1. The policy of APRINDER LIMITED regarding the processing of PD (hereinafter referred to as the Policy) was developed in accordance with regulations and rules of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of PD and on the free movement of such data, known as the General Data Protection Regulation (GDPR).

1.2. This Policy defines the procedure for processing PD of users of the site https://learninghow.eu/ (hereinafter referred to as the Website), the conditions and principles for processing PD, the rights of Users and obligations of “APRINDER LIMITED“, information on the measures taken to protect the processed PD.

1.3. This Policy applies to all PD that APRINDER LIMITED receives from users of the Website (hereinafter – Users, User).

1.4. In case of disagreement with the terms of the Policy, the User must immediately stop any use of the Website.

2. Terms and definitions

2.1. The following terms are used in the Policy:

Website – an Internet site located at https://learninghow.eu/.

PD (hereinafter – PD) – any information relating directly or indirectly to a specific or identifiable natural person (PD subject).

PD blocking – temporary suspension of PD processing (except when processing is necessary to clarify PD).

Depersonalization of PD – actions as a result of which it is impossible to determine, without the use of additional information, whether PD belongs to a specific PD subject.

PD processing – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with PD, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of PD.

Operator – APRINDER LIMITED independently organizes and carries out the processing of PD, and also determines the purposes of processing the PD, the composition of the PD to be processed, the actions (operations) performed with the PD.

Personal account – a set of secure pages of the Website created as a result of registration of the User and available when entering his authentication data (e-mail address and password) in the fields provided for this on the Website.

Provision of PD – actions aimed at disclosing PD to a certain person or a certain circle of persons.

Distribution of PD – actions aimed at disclosing PD to an indefinite number of persons (PD transfer) or familiarizing with PD of an unlimited number of persons, including publication of PD in the media, posting in information and telecommunication networks or providing access to PD to any or in any other way.

User – a visitor to the Website, a subject of PD.

ISPD – PD information system.

Destruction of PD – actions as a result of which it is impossible to restore the content of PD in the ISPD, and (or) as a result of which the material media of PD are destroyed.

Cookies (cookies) – data that is automatically transmitted to APRINDER LIMITED during the use of the Website using the software installed on the User’s device, including IP address, geographic location, information about the browser and type of operating system of the User’s device, technical characteristics equipment and software used by the User, date and time of access to the Website.

By accepting the terms of the Policy, you agree to the use of cookies.

3. Legal grounds and purposes of the processing of PD

3.1. The legal grounds for processing PD by APRINDER LIMITED are:

1. Civil Code of the Republic of Cyprus.
2. GDPR of 27 April 2016.

• Other applicable regulatory legal acts of the Republic of Cyprus (hereinafter referred to as Cyprus).

1. Local legal acts APRINDER LIMITED.
2. Consent of the User to the processing of PD.

3.2. APRINDER LIMITED processes the User’s PD exclusively for the following purposes:

3.2.1. Registration and identification of the User on the Website, providing the User with the opportunity to fully use the Website.

3.2.2. Displaying the User’s profile for other Users of the Website.

3.2.3. Establishing and maintaining communication between the User and APRINDER LIMITED, consulting on the provision of APRINDER LIMITED services.

3.2.4. Conclusion of agreements and fulfillment of APRINDER LIMITED obligations to the User under them (in particular, the User Agreement and other agreements). Fulfillment of obligations, in particular, includes informing the User about the date and time of classes, sending certificates, etc.

3.2.5. Sending of advertising messages to the User, newsletters about products, services of APRINDER LIMITED and its partners, about special offers, promotions, sweepstakes, competitions, surveys to the User’s email address, by the User’s phone number (User’s name) in instant messengers “WhatsApp”, “Viber”, “Telegram”, by mail, SMS messages, push notifications.

3.2.6. Posting on the Website, in official groups of social networks, other advertising and information sources, for purposes not related to identifying the User − Video materials received during the provision of services, − Reviews left by the User about the services provided by APRINDER LIMITED.

3.2.7. Improving the quality of service for the User and modernizing the Website by processing requests and applications from the User, as well as for the purpose of recording telephone conversations with APRINDER LIMITED, to improve the quality of service to preserve evidence in case of disputes between APRINDER LIMITED and the User.

3.2.8. Statistical and other studies based on anonymized information provided by the User.

3.3. The specific volume of PD processed for the above purposes is defined in section 5 of the Policy.

4. Conditions and procedure for providing consent to the processing of PD at APRINDER LIMITED

APRINDER LIMITED does not check the PD provided by the User. In this regard, APRINDER LIMITED assumes that when providing PD on the Website, the User:

4.1.1. Is a capable person. In the event of incapacity of the person using the Website, consent to the processing of PD is provided by the legal representative of the User, who has read and accepted the conditions for processing PD specified in this Policy.

4.1.2. Indicates reliable information about himself or about the represented incapacitated person (clause 4.1.1) to the extent necessary to use the Website. The User independently keeps the provided PD up to date. The consequences of the User providing false or insufficient information are defined in the User Agreement.

4.1.3. Understands that information on the Website posted by the User about himself/herself may become available to other Users of the Website and may be copied and distributed by such Users in cases provided for in the Policy.

4.2. The user accepts the terms of the Policy and gives APRINDER LIMITED informed and conscious consent to the processing of his PD under the conditions provided for by the Policy and the Law:

4.2.1. When registering and identifying on the Website – for PD that the User provides APRINDER LIMITED: by filling out the registration form located on the Internet at the address https://learninghow.eu/my-account/. The User is considered to have given consent to the processing of his/her PD at the moment he clicks the “Register” button.

4.2.2. When entering or changing PD in the “Settings” section of your Personal Account – when editing or adding information in the “Settings” section. At the User’s request, the following information may be indicated in the Personal Account: gender; image (photo uploaded through the sites or a link from a social network / other electronic service); links to profiles on social networks. The specified PD can be used to fulfill the APRINDER LIMITED obligations stipulated by the User Agreement and the Terms and Conditions of the Website’s services. The user is considered to have given consent to the processing of his/her newly entered or changed PD at the time of completion of their editing. After filling out any of the fields specified in the “Settings” section, the PD is updated automatically.

4.2.3. When filling out the feedback form the User provides APRINDER LIMITED when filling out the feedback form on the Internet on the Website and electronic services. The user is considered to have given consent to the processing of his PD entered in the fields of the feedback form at the moment he clicks the button confirming the submission of the application.

4.2.4. When subscribing to receive information, advertising and news materials from LearningHow – by filling out the newsletter subscription form located on the Internet at https://learninghow.eu/purchase-guide/. The User is considered to have given consent to the processing of his PD when clicking on the “Subscribe Now” button

4.2.5. For any use of the Website – for PD that is automatically transferred to APRINDER LIMITED during the use of the Website using the software installed on the User’s device. The User is considered to have given consent to the processing of his PD at the time of starting to use the Website.

4.3. By performing the actions specified in clause 4.2 of this Policy, the User gives APRINDER LIMITED consent to the processing of the relevant PD, the list of which is specified in section 5 of this Policy, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision to third parties, access), depersonalization, blocking, deletion, destruction of PD with or without the use of automation tools in accordance with the purposes specified in Section 3 of this Policy.

4.4. The consent to PD processing provided by the User in accordance with this Policy is valid from the date of provision of such consent and for the period necessary to achieve the purposes of PD processing or until the User withdraws this consent, unless otherwise provided by the current legislation of the United Kingdom. The consent to the processing of PD provided by the User in accordance with this Policy may be withdrawn by the User at any time. The user may revoke the previously provided APRINDER LIMITED consent to the processing of PD in one of the following ways:

1. By sending the corresponding application by mail to the address: Arch. Makariou III, 1, MITSI BUILDING 3, 3rd floor, flat/Office 310, 1065, Nicosia, Cyprus;
2. By sending a corresponding application in the form of an electronic document to email address: support@learninghow.eu.
3. PD processed in APRINDER LIMITED

5.1. Processing of User PD is carried out under the following conditions:

Purpose of using PD	Volume of processed PD
Registration on the Website (clause 3.2.1)	i)      last name and first name ii)    email address iii)  floor iv)   profile avatar
Identification on the Website (clause 3.2.1)	v)    email address
Displaying a profile for other Website Users (clause 3.2.2)	vi)      last name and first name vii)    profile avatar viii)  nickname
Establishing and maintaining communication between User and APRINDER LIMITED, consulting on the provision of services (clause 3.2.3)	ix)      last name and first name x)       phone number xi)      email address xii)    data from accounts on social networks
Conclusion of contracts, fulfillment of obligations under them (clause 3.2.4)	xiii)      last name and first name xiv)      phone number xv)        email address xvi)      passport data (series, number, code xvii)     divisions, date of issue, by whom, date and place of birth) xviii)   permanent registration address xix)      address of actual residence xx)        information about the level of education and xxi)      educational institutions (if necessary to fulfill obligations) xxii)     work experience, positions held (if xxiii)   necessary to fulfill obligations) xxiv)   experience (if necessary for performance xxv)     obligations) xxvi)   salary amount (if necessary xxvii)  to fulfill obligations) xxviii) bank details (if necessary to fulfill obligations)
Sending advertising messages, newsletters, providing advertising information orally and in writing (clause 3.2.5)	xxix)  last name and first name xxx)    phone number xxxi)  email address
Posting photos and videos, received during the provision of APRINDER LIMITED services, User comments regarding the APRINDER LIMITED services (clause 3.2.6)	xxxii)    last name and first name xxxiii)  profile avatar xxxiv)  data from accounts on social networks
Improving the quality of User Service and modernizing the Website (clause 3.2.7)	xxxv)    cookies
Statistical and other studies based on anonymized information (clause 3.2.8)	xxxvi)  cookies

6. Processing of PD

6.1. APRINDER LIMITED processes PD based on the following principles:

1. Legality and fairness.
2. Limiting the processing of PD to the achievement of specific, predetermined and legitimate purposes.

• Preventing the processing of PD is incompatible with the purposes of collecting PD.

1. Preventing the merging of databases containing PD, the processing of which is carried out for purposes incompatible with each other.
2. Processing only those PD that meet the purposes of their processing.
3. Compliance of the content and volume of processed PD with the stated purposes of processing.

• Preventing the processing of PD that is excessive in relation to the stated purposes of their processing.
• Ensuring the accuracy, sufficiency and relevance of PD in relation to the purposes of PD processing.

1. Destruction or depersonalization of PD upon achievement of the purposes of their processing or in the event of loss of the need to achieve these goals, receipt from Users of a request for the destruction of PD, receipt from the User of withdrawal of consent to the processing of PD.

6.2. APRINDER LIMITED processes Users’ PD (recording, systematization, accumulation, storage, clarification (updating, changing), retrieving) using databases on the territory of the Republic of Cyprus.

6.3. Processing of Users’ PD is carried out by APRINDER LIMITED both with and without the use of automated means.

6.4. APRINDER LIMITED and other parties who have access to PD are obliged not to disclose to third parties or distribute PD without the consent of the PD subject, unless otherwise provided by effective law.

6.5. Processing of the User’s PD includes the following actions: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision to third parties, access), depersonalization, blocking, deletion, destruction.

6.6. Users’ PD is stored on electronic media. When processing PD to fulfill obligations under agreements with the User, APRINDER LIMITED can extract PD and store them on tangible media. The storage of such PD is carried out for the period established by the legislation of the United Kingdom on education and archiving. PD is stored (depending on which event occurs first):

1. Until they are deleted by the User in the “My Profile” and “Settings” sections in the personal account on the Website:
2. Until their destruction APRINDER LIMITED – if the User receives a withdrawal of consent to the processing of PD or a request for the destruction of PD.

• Until the consent expires (clause 4.4 of the Policy).

6.7. APRINDER LIMITED has the right to transfer PD in accordance with the requirements of the legislation of the Republic of Cyprus or the consent of the subject of PD processing to third parties, namely:

6.7.1. Partners, such as site and application owners, advertising networks and other partners who provide APRINDER LIMITED services related to the placement and display of advertising on sites, programs, products or services owned or controlled by such partners.

6.7.2. Partners engaged by LearningHow to provide services to Users on the LearningHow platform at https://learninghow.eu/.

6.8. The transfer of PD to third parties specified in clause 6.7 of the Policy is subject to the following conditions:

1. A third party processes PD using databases on the territory of the Republic of Cyprus.
2. The third party ensures the confidentiality of PD during their processing and use, undertakes not to disclose to other people, and also not to distribute the PD of Users without their consent.

• The third party guarantees compliance with the following measures to ensure the security of PD during their processing: the use of information security tools, detection and recording of facts of unauthorized access to PD and taking measures to restore PD, restricting access to PD, registration and recording of actions with PD, monitoring and assessing the effectiveness of measures taken to ensure PD security.

1. List of permitted methods for processing PD: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
2. A third party is prohibited from transferring and distributing PD.
3. Measures taken by APRINDER LIMITED to protect PD

7.1. APRINDER LIMITED takes necessary and sufficient legal, organizational and technical measures to protect information provided by Users from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties with it. Such actions include, but are not limited to:

1. Application of organizational and technical measures to ensure the security of PD during their processing in information systems.
2. Monitoring instances of unauthorized access to PD and taking measures to prevent similar incidents in the future.

• Monitoring the measures taken to ensure the security of PD and the level of security of PD information systems.

8. 8. User Rights

8.1. The User decides to provide his PD and consent to their processing freely, of his own free will and in his own interest. The user expresses his consent to the processing of PD in the manner described in clause 4.2 of this Policy.

8.2. The User has the right to receive APRINDER LIMITED information regarding the processing of his PD.

8.3. The User has the right to send APRINDER LIMITED his requests and demands (hereinafter referred to as the Appeal), including regarding the use of his PD, as well as the withdrawal of consent to the processing of PD. The appeal can be sent in the following ways:

8.3.1. In writing to the address APRINDER LIMITED (clause 4.4 of the Policy).

8.3.2. In the form of an electronic document (scan, photocopy of the document). The document must be sent from the User’s email address specified when registering on the LearningHow Website to the email address: support@learninghow.eu.

9. Updating, correction, deletion and destruction of PD

9.1. APRINDER LIMITED undertakes to inform the User or his/her representative in the manner prescribed in article 20 of the GDPR, information about the availability of PD related to this User, as well as provide the opportunity to review these PD when contacted by the User or his/her representative within 10 (ten) days from the date of receipt of the request of the User or his/her representative. This period may be extended, but not more than by 5 (five) working days, after a reasonable notice is sent to the User indicating the reasons for the extension.

9.2. APRINDER LIMITED undertakes to provide, free of charge, the User or his/her representative with the opportunity to familiarize himself with the PD relating to this User.

9.3. Within a period not exceeding 7 (seven) working days from the date the User or his/her representative provides information confirming that the PD is incomplete, inaccurate or irrelevant, APRINDER LIMITED undertakes to make the necessary changes to them.

9.4. Within a period not exceeding 7 (seven) business days from the date the User or his/her representative provides information confirming that such PD is illegally obtained or is not necessary for the stated purpose of processing, APRINDER LIMITED undertakes to destroy such PD. APRINDER LIMITED also undertakes to notify the User or his representative about the changes made and measures taken and to take reasonable measures to notify third parties to whom the PD of this User has been transferred.

9.5. If it is confirmed that the PD is inaccurate, APRINDER LIMITED, based on the information provided by the User or his representative or the authorized body for the protection of the rights of PD subjects, or other necessary documents, undertakes to clarify the PD or ensure their clarification (if the processing of PD is carried out by another person acting on behalf of APRINDER LIMITED) within 7 (seven) working days from the date of submission of such information and remove the blocking of PD.

9.6. APRINDER LIMITED undertakes to stop processing PD or ensure that the processing of PD is stopped by a person acting on behalf of APRINDER LIMITED:

1. In case of detection of unlawful processing of PD carried out by Operator or a person acting on behalf of APRINDER LIMITED, within a period not exceeding 3 (three) working days from the date of this detection.
2. If the User withdraws consent to the processing of his PD.

• If the purpose of processing PD is achieved.

9.7. APRINDER LIMITED undertakes to destroy the User’s PD or ensure its destruction (if PD processing is carried out by another person acting on behalf of APRINDER LIMITED) within a period not exceeding 30 (thirty) days from the date the purpose of PD processing is achieved.

9.8. If it is not possible to destroy PD within the period specified in clause 9.7 of the Policy, APRINDER LIMITED blocks such PD or ensures their blocking (if the processing of PD is carried out by another person acting on behalf of APRINDER LIMITED) and ensures the destruction of PD within a period not more than 6 (six) months, unless another period is established by federal laws.

10. Policy changes

10.1. APRINDER LIMITED reserves the right to make changes to the Policy. The User is obliged to familiarize himself with the text of the Policy each time he/she uses the Website.

10.2. The new version of the Policy comes into force from the moment it is posted in the appropriate section of the Website APRINDER LIMITED. Continued use of the Website or its services after the publication of a new version of the Policy means acceptance of the Policy and its terms by the User. In the case of disagreement with the terms of the Policy, the User must immediately stop using the Website and its services.

10.3. Please direct all questions regarding this Policy to the email address support@learninghow.eu.