Privacy Policy

This Privacy Policy (hereinafter referred to as the “Policy”) governs the processing, collection, and use of your personal data when interacting with the website operating under the BetterED brand (hereinafter referred to as the “Website”), as well as when participating in online events and using other services available through the Website.

The processing of personal data on this Website is carried out by companies that are part of an international group of companies and operate under the BetterED brand (hereinafter “BetterED,” “the Group,” “We”), as joint controllers of personal data within the meaning of applicable data protection legislation, exclusively within the scope of this Website’s operation.

The Group of Companies that process personal data within the scope of this Website’s operation under the BetterED brand includes, in particular:

• ITGlobal Group OÜ, duly registered under the laws of Estonia at the address: Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-301, 10152, Estonia, legal entity registration number 16704252,
• LIMITED LIABILITY COMPANY “GO IT EDUCATION”LLC”, legal entity registration number 44512585, located at: Ukraine, 04050, Kyiv, 12 Yuri Illenko St.,
• LIMITED LIABILITY COMPANY “GO ITEENS”, legal entity registration number 43837913, location: Ukraine, 04050, Kyiv, 12 Yuri Illenko St.,
• PRIVATE INSTITUTION OF GENERAL SECONDARY EDUCATION “GOITEENS SCHOOL”, legal entity registration number 45594022, located at: Ukraine, 03150, Kyiv, 72 Velyka Vasylkivska St., office 153,
• LIMITED LIABILITY COMPANY PRIVATE HIGHER EDUCATION INSTITUTION “UNIVERSITY OF MODERN TECHNOLOGIES”, legal entity registration number 45247608, located at: Ukraine, 03022, Kyiv, 28-G Mykhailo Maksymovych St.,
• SKILLSETTER LTD, a legal entity duly registered in accordance with the laws of the Republic of Cyprus, legal entity registration number: HE 421968, located at: MEDITERRANEAN COURT, 1st floor, apartment/office A5, 3107, Limassol, Cyprus,
• GoIT Eğitim Danışmanlık LTD ŞTİ, a legal entity established in accordance with the applicable laws of the Republic of Turkey, legal entity registration number: 3961634855, located at: Selimpaşa, 1010. Sk. No:10/1, 34590 Silivri/İstanbul KHAS Teknopark.

The current list of Group companies may be updated without amending this Policy by publishing updated information on the Website.

The Website may contain links to the websites of individual Group companies or third parties. When you visit such websites, the processing of your personal data is carried out by the relevant legal entity as an independent data controller in accordance with its own privacy policy posted on that website. This Policy does not apply to such websites.

This Policy also explains how your personal data is used, transferred, and protected, what rights you have regarding your personal data, and how you can contact us.

If you have any questions regarding the processing of your personal data, wish to provide feedback, have questions or complaints, or wish to exercise your rights related to your personal data, you may contact us: 

• by sending an email to info@bettered.global – as the sole contact address for inquiries regarding the operation of this Website; and/or
• directly to the relevant company within the Group that processes your personal data, using the contact information provided in its own privacy policy.

When you visit our Website, we may process certain technical data (e.g., cookies, IP address) in accordance with this Policy. Some cookies are necessary for the website to function and do not require consent. The use of analytical and marketing cookies is subject only to your consent, which you may provide or withdraw via the cookie settings.  

We will not use your information or share it with anyone, except as described in this Policy, including among companies within the Group for the stated purposes of processing.

The terms used in this Policy have the same meanings as in our Terms of Use, which are available on the Website, unless otherwise defined in this Policy.

Legal Grounds for Processing Personal Data

We process your personal data on the following legal grounds:

• The conclusion and performance of a contract or other legal transaction to which a natural person is a party, or which is concluded for the benefit of a natural person.
• Legitimate interest – to improve our services, ensure security, and prevent fraud.
• Your consent – for marketing communications or other purposes, where required by law.
• Legal obligation – if necessary to comply with applicable law.

COLLECTION AND USE OF INFORMATION

To improve your experience while visiting the Website and to provide and improve our services, we may ask you to provide certain personal information, including but not limited to: your name, phone number, location (residence) address, email address, etc. The information we collect will be used for communication, to identify you, and/or to provide you with relevant services.

What information do we collect

We may request your personal data for the purpose of providing you with services.

We may collect certain personal data (hereinafter “Personal Data”) voluntarily provided by visitors to the Website during their session(s) on the Website.

This Personal Data includes:

• contact information, including name, email address, phone number, and residential address;
• login and account details, including username, password, and unique user ID;
• personal data, including gender and date of birth;
• information necessary for making payments.

When interacting with the Website, certain data is automatically collected from your device or web browser, as described below in the section titled “Cookies and Pixel Tags.” This data includes:

• device identifiers, connection status, network access, and storage information; 
• cookies, IP addresses, referrer URLs, data identifying your web browser and its version, web beacons, tags, etc.

Is providing data mandatory?

• Providing mandatory data is a prerequisite for using the Website; without it, the Website will not function properly or may not function at all.
• Providing basic contact information is a prerequisite for using our services.
• Other data (e.g., marketing preferences) is voluntary, and you can change your settings at any time.

Sharing Personal Data with Third Parties

In the course of our operations, we use services from third-party providers such as Facebook (Meta Platforms, Inc.), Google Ads, and Google Analytics (Google services), as well as other similar services. This means that some of your personal data may be transferred to these third-party organizations within the scope of using the relevant services. In particular, the use of Google and Facebook advertising and analytics tools involves the exchange of data about your activity with Google and Meta. Please note that such third-party providers may process personal data on servers located outside the European Union (e.g., in the U.S.), i.e., engage in cross-border data transfers. In the event of data transfers outside the EU, we ensure the use of the necessary legal safeguards provided for by the GDPR to guarantee an adequate level of security and confidentiality for your data. Such safeguards include, in particular, standard contractual clauses or the application of other appropriate safeguards.

Partners who help us provide services include, in particular:

• Payment systems (e.g., Stripe, PayPal) for processing transactions.
• Analytics services (Google Analytics, Facebook Pixel) to improve our services.
• Advertising platforms (Google Ads, Meta Ads) – only with your consent.

Retention period for personal data

• Contact information – 3 years after the user’s last activity.
• Account data – until the account is deleted.
• Payment data – 5 years in accordance with tax legislation.
• Cookie data – up to 1 year (depending on the type of cookie, unless the user has withdrawn consent).

Processing of children’s data

We recognize the importance of protecting children’s privacy online.

• We do not collect personal data from children under the age of 16 (or the minimum age required by the user’s country’s laws) without the consent of their parents or guardians.
• If we learn that a child has provided us with personal data without verified parental consent, we will immediately delete that information.
• If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us at the address provided in this Policy.

We make reasonable efforts to verify the age of users and the existence of parental/guardian consent for individuals under the age of 16. However, if a minor user intentionally provides false information about their age or otherwise circumvents established age verification mechanisms, we cannot be held responsible for such actions by that user. If we discover that a child’s personal data is being processed without proper parental consent, we will immediately cease such processing and delete the relevant data.

Where We Collect Personal Data

Personal Data is collected only when Website users voluntarily provide it during their session(s) on the Website. We may request Personal Data in the following instances: when purchasing our service, when subscribing to the email newsletter, and/or when interacting with our managers. General data regarding Website usage is collected using cookies (please review the section on cookies below).

Your Rights Regarding Personal Data

You have the right to:

• Access your personal data.
• Correction of inaccurate or outdated data.
• Deletion of data (“right to be forgotten”).
• Restriction of processing in certain cases.
• Data portability – receiving a copy of your data in a structured format.

How to exercise your rights?

You can submit a request regarding your personal data by contacting us.

Why and how we use your personal data

We use your personal data in the following cases:

Sharing Your Personal Data

We may share each category of Personal Data we collect with the following types of businesses for the following business purposes:

• Service providers process Personal Data (including the Personal Data listed in the “What Information We Collect” section) for business purposes on our behalf, such as to process credit cards and payments, manage and maintain our data, distribute emails, conduct research and analysis, advertising, analytics, manage brand and service promotion, and administer certain services and features, including on the Website;
• Other third parties to the extent necessary to: (i) comply with a government agency request, court order, or applicable law; (ii) prevent unauthorized use of the Website or violations of the Website’s Terms of Service and our other policies; (iii) defending against third-party claims and lawsuits; and (iv) assisting in the prevention or investigation of fraud (e.g., forgery);
• To any third party, provided you have given your consent.

We may also transfer personal data we hold about you in the event of a sale or transfer of all or part of our business or assets (including in the event of a reorganization, spin-off, or liquidation).

If we transfer personal data outside the EU (for example, to the U.S. for processing by Google or Meta services), we ensure an adequate level of protection in accordance with legal mechanisms.

Please note that we do not sell your personal data.

Protection and Management of Your Personal Data

Secure Payment Processing

The website uses secure verification to transfer your payment card data from a secure web page to a secure payment application.

We partner with Stripe, PayPal, and other payment providers to process payments. All transactions are processed in accordance with PCI DSS standards.

Payment data is processed based on the performance of the service agreement and compliance with GDPR legal obligations (e.g., for financial accounting). We do not store your full payment card information in any of our systems. Payment card information is transmitted during the secure checkout process to our partner for payment confirmation and authorization. After the payment is processed, the only payment card information we may store is the card type (Visa, MasterCard, etc.), the last 4 digits of the card used, and the card’s expiration date. We do not store the full payment card number or the payment card’s CVV/CSC. This practice helps us protect your information.

Communication

By providing your contact information, you agree to receive certain electronic communications from us. You agree that any notice, agreement, or other communication we send to you electronically will satisfy all legal requirements regarding such notices and/or communications, including the requirement that such notices/communications be in writing. All calls, emails, and other communications between you and us may be recorded.

By providing us with your email address, phone number, and other personal data, or by subscribing via the subscription form on the Website, you consent to our sending you marketing offers, advertisements, and other communications and notifications regarding our services.

COOKIES and Pixel Tags

We collect information, which may include Personal Data, when you use the Website. We use various methods, such as cookies and pixel tags, to collect this information, which may include your (i) IP address; (ii) unique cookie ID, cookie information, and information about whether your device has software to access certain features; (iii) a unique device identifier and device type; (iv) domain, browser type, and language; (v) operating system and system settings; (vi) country and time zone; (vii) previously visited websites; (viii) information about your interaction with the Website, such as click behavior, orders, and specified preferences; and (ix) access times and referring URLs.

A cookie is a small amount of information that is downloaded to your computer or device when you visit the Website. We use several different types of cookies, including functional, performance, advertising, and social media or content cookies. Cookies enhance your browsing experience by allowing the website to remember your actions and settings (such as your username and region selection). This means you don’t have to re-enter this information every time you return to the site or switch from one page to another. Cookies also provide information about how people use the website, such as whether they are visiting for the first time or are frequent visitors.

We use cookies and pixel tags to track usage of the Website and understand our customers’ preferences. This allows us to provide services to our customers and improve their online experience. We also use cookies and pixel tags to gather aggregate data about Website traffic and interactions with the Website to identify trends and obtain statistics so that we can improve the Website. The Website typically uses three categories of cookies:

• Functional: These cookies are necessary for the basic functioning of the website, so they are always active. They include cookies that allow us to recognize you while you browse the Website during a single session or, at your request, from session to session. They help, for example, to enable the checkout process, as well as assist with security and compliance with other regulations.
• Performance cookies: These cookies allow us to improve the functionality of the Website by tracking its usage. In some cases, these cookies improve the speed at which we can process your request and allow us to remember the website settings you have selected. Opting out of these cookies may result in poorly tailored recommendations and a slower website.
• Social Media and Advertising: Social media cookies allow you to connect to your social media accounts and share the Website’s content via social media. Advertising cookies collect information to help tailor advertisements to your interests. In some cases, these cookies involve the processing of your personal data. Opting out of these cookies may result in you seeing ads that are not as relevant to you, or you may not be able to effectively connect with Facebook, Twitter, or other social networks and/or share content on social media.

Your browser can help you manage cookies. You can choose to have your computer warn you each time a cookie is sent, or you can turn off all cookies. You can do this through the settings on each browser and device you use. Each browser is slightly different, so check your browser’s “Help” menu to learn how to properly manage cookies. If you disable cookies, you may not have access to many features that make the Website more effective, and some of our services may not function properly.

Facebook Ads Conversion Tracking (Facebook Pixel) 

Facebook Ads Conversion Tracking (Facebook Pixel) is an analytics service provided by Meta Platforms, Inc. that links data from the Facebook advertising network with actions taken on this website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram, and the Audience Network. Personal data collected: cookies, usage data.

Google Ads Conversion Tracking (Google Inc.) 

Google Ads Conversion Tracking is an analytics service provided by Google LLC or Google Ireland Limited, depending on the location from which this application is accessed, which links data from the Google Ads advertising network with actions performed within this application. Personal data collected: cookies, usage data.

Google Analytics Media Advertising Extension (Google Inc.) 

Google Analytics in this application may use Google interest-based advertising, other audience data, and information from DoubleClick cookies to enhance analytics with demographic indicators, interests, and data on interactions with advertisements. Personal data collected: cookies, usage data.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. Google Inc. uses the collected data to track and examine the use of this application, to prepare reports on its activity, and to share these reports with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. Personal data collected: cookies, usage data.

Application of the GDPR (for users from the EU/EEA)

If the processing of personal data concerns you as a data subject located within the European Union or the European Economic Area, such processing is carried out in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679, GDPR). In the context of this Website’s operation, the companies within the Group operating under the BetterED brand act as joint controllers of personal data within the meaning of the GDPR. The key aspects of the division of responsibilities among the joint controllers are set forth in the relevant internal agreement between the Group companies. If you have any questions regarding the division of responsibilities among the joint controllers concerning your Personal Data, please contact us (contact details are provided in this Policy).

The processing of personal data is carried out on the legal grounds specified in Article 6 of the GDPR, in particular:

• – to perform a contract or take steps prior to entering into a contract;
• – based on your consent (in particular for marketing communications and the use of non-essential cookies);
• – to comply with our legal obligations;
• – to pursue our legitimate interests (ensuring security, preventing fraud, improving services).

You have the rights provided for by the GDPR, including the right to access your personal data, to have it corrected, erased, or processing restricted, to object to processing, to data portability, and the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to such withdrawal.

You also have the right to lodge a complaint with the competent data protection supervisory authority in the European Union member state of your habitual residence, place of work, or the place where the alleged infringement occurred.

The transfer of personal data outside the EU/EEA is carried out exclusively with appropriate legal safeguards in accordance with the GDPR, in particular through the use of standard contractual clauses or other permitted safeguards.

Application of California Law (CCPA / CPRA)

If you are a resident of the State of California (USA), the processing of your personal data is carried out in accordance with the California Consumer Privacy Act (CCPA), taking into account the amendments made by the California Privacy Rights Act (CPRA).

You have the right to know what categories of personal data we collect and for what purpose, the right to access, correct, and delete personal data, the right to restrict the use of sensitive personal data, and the right to opt out of the sale or transfer of personal data, if such actions were to occur.

We do not sell users’ personal data as defined by the CCPA, nor do we transfer it to third parties for commercial sale.

Exercising your rights under the CCPA/CPRA will not result in any discrimination against you, including denial of service or a reduction in service quality.

Requests to exercise rights under the CCPA/CPRA may be submitted by contacting us using the contact information provided in this Policy and will be processed within the timeframes and in the manner prescribed by applicable law, subject to verification of the requester’s identity.

Receiving Information from Us

Email 

When you submit a request on the Website, we may send you an email confirming your request. Similarly, when you create an account on the Website, we may send you an email confirming the creation of your account. You will receive these emails, also known as transactional emails, regardless of whether you choose to subscribe to our newsletter. Please note that receiving these transactional emails does not automatically sign you up for our email subscription program.

We periodically send emails to our subscribers to inform you about our new services, features, and/or special promotions. We only send emails to visitors who have registered during the application process or subscribed to our newsletter on the Website. In every email we send, we include instructions on how to unsubscribe from our newsletter.

By providing us with your email address, phone number, and other personal information, or by subscribing through our newsletter form on the Website, you consent to receiving marketing offers, promotional and other messages and notifications regarding our services from us.

You may opt out of receiving these or future emails at any time by clicking the “unsubscribe” link in the footer of such emails.

Phone Number

By entering your phone number in the special form on the Website or by subscribing via our newsletter form, you consent to our sending you text notifications and text marketing offers. Text marketing messages will not exceed 3 per month. You acknowledge that this consent is not a condition for any order.

If you wish to unsubscribe from receiving text marketing messages and notifications, reply STOP to any text message sent by us, or use the unsubscribe link provided in any of our messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests, will not be considered reasonable means of opting out. You agree that you may be charged for such messages.

If you have any questions, send a message with the word HELP to the number from which you received the message. You may also contact us for additional information. 

Objection to the Processing of Personal Data

You have the right to object to the processing of your personal data (right to object to processing) if such processing is not necessary for the provision of services to you or your use of the Website.

In particular, you may:

• – opt out of receiving marketing communications (email, SMS, ads),
• – opt out of the use of your data for analytics or personalized advertising, unless such processing is necessary.

After your objection, we will cease processing the relevant data unless there are other legal grounds for doing so (e.g., contractual or legal obligations).

However, if you object to the processing of your personal data that is necessary for providing you with services or using the Website, this may result in our inability to provide you with services or allow you to use the Website.

You may exercise your rights by contacting us at the email address provided at the beginning of this Policy, or by following the steps described in the “Receiving Information from Us” section of this Policy.

Changes to Our Privacy Policy

By using the Website, you consent to our collection and use of your Personal Information.

Please also note that applicable laws and our practices may change from time to time. If we decide to update our Privacy Policy, we will post the changes on the Website. If we make significant changes to how we process your Personal Data, we will provide you with advance notice or, if required by law, seek your consent before implementing such changes. We recommend that you review our Privacy Policy and stay informed about our practices and future changes.

Automated Decision-Making. 

We do not make any decisions based solely on the automated processing of personal data (including profiling) that could have legal consequences for users or otherwise significantly affect them. 

Questions, Complaints, and Feedback

You have the right to contact us with requests regarding the exercise of your rights under the GDPR (access to data, rectification, erasure, restriction of processing, objection, etc.). We will review such requests without undue delay and respond no later than 30 days from the date of receipt of the request, following successful verification of the applicant’s identity. If necessary, given the complexity or volume of requests, this period may be extended by a maximum of 60 days. 

Identity Verification. To protect your privacy and ensure that the request is made by the correct data subject, we must verify your identity before providing information or taking action in response to the request. If we have reasonable doubts regarding the identity of the requester, we may request additional information necessary to confirm the requester’s identity. For example, we may send a response to the request only to the email address specified in your account, or ask you to provide information already in our systems (to verify a match). The 30-day response period begins upon verification of identity. Our responses to requests are provided free of charge to the user, unless the request is manifestly unfounded or excessive.

Contact Information.

If you wish to send feedback, have questions or complaints, or wish to exercise your rights regarding your Personal Data, you may contact us:

• by sending an email to info@bettered.global – as the sole contact address for inquiries regarding the operation of this Website; and/or
• directly to the relevant company within the Group of Companies that processes your personal data, using the contact information provided in its own privacy policy.