PRIVACY POLICY

(Last update: 21.10.2024)

Thank you for joining FINANCIAL FREEDOM ACADEMY, whose main expert and ambassador is Oleksandr Orlovskyi (hereinafter also referred to as “FFA”, “we”, “us”, “our”). We respect your privacy and are committed to ensuring transparency in the collection of your personal data and compliance with your rights in this context.

This Privacy Policy (hereinafter referred to as the “Privacy Policy”) describes how IT Brains LLC, which is registered under the laws of the United States, registration number L23000138051, address: 2200 Sole Mia Sq Lane, North Miami, FL, USA, 33181 as a data controller, collects, uses, discloses and protects personal data provided by visitors and users of the orlovskyi.com website and / or any FFA affiliated websites or related services (hereinafter referred to as the “User”, “you”, “your”), including when you receive the Services that we provide or may provide in the future. This Privacy Policy forms an integral part of the Terms of Use.

Unless otherwise stated, this Privacy Policy applies whenever you visit or use the orlovskyi.com website and/or any FFA affiliated websites and/or related services (hereinafter collectively also referred to as the “Platform”).

By using our Services, you confirm your consent to this Privacy Policy. Please read this Privacy Policy carefully each time before using the Services and before providing us with any personal data. If you do not agree to the terms of this Privacy Policy or any other agreement governing your use of the Services, please refrain from using our Services and Platform or any other aspect of our activities.

DEFINITION

In this Privacy Policy, the following terms are used with the following meanings:

Bot means an automated account in the Telegram messenger, functioning on the basis of a special application programming interface (API) and providing automated processing of requests, provision of information and assistance to you in obtaining the Services.

Personal data mean any information that directly or indirectly identifies an individual. This may include, but is not limited to: (i) information provided by the User when using the Platform; (ii) data that is automatically collected when using the Platform, such as IP address, cookies, browser data or other technical data, including information about hardware and software, date and time of access, addresses of requested pages, etc.; (iii) any other information about the User, the processing of which is provided for by this Privacy Policy.

Services mean the range of services provided to you, which may include, but is not limited to, temporary access to paid and free trainings, seminars and conferences held in the format of webinars or online broadcasts, courses, thematic information channels on third-party Discord platforms, Telegram and other types of licensed content.

IP address means a unique network address of a device in a computer network using the IP protocol.

Personal data processing means any operation or set of operations with personal data, such as collection, registration, organization, storage, adaptation, retrieval, use, disclosure through transmission, distribution, erasure or destruction.

Confidentiality of personal data means a mandatory requirement to prevent disclosure of personal data without the consent of the data subject or other legal basis.

Controller means an individual or a legal entity who, alone or jointly with others, determines the purposes and means of personal data processing.

Consent means any freely given, specific, informed and unambiguous indication of the User's wishes by which he or she, by making a statement or by showing clear affirmative actions, confirms agreement to the processing of his or her personal data.

All terms not defined in this Privacy Policy shall be construed in accordance with the definitions given to them in the Terms of Use.

Unless the context otherwise requires, a reference to one gender includes a reference to the other genders; words in the singular include the plural and words in the plural include the singular; any words following the terms “including,” “in particular,” “for example,” “including but not limited to,” or any similar expressions shall be construed as illustrative and shall not limit the meaning of the words, description, definition, phrase, or term preceding such terms; the headings of any sections shall not affect the interpretation of this Privacy Policy.

GENERAL PROVISIONS

This Privacy Policy applies to all personal data obtained through the Platform, as well as any other resources used to provide access to the Services.

The Platform includes all web pages, interactive features, widgets, blogs, social media plugins, as well as any online and offline services or offerings that directly link to this Privacy Policy.

By providing us with your personal data, clicking the checkbox on this Privacy Policy, or otherwise indicating your consent on the Platform, you give us your explicit and unambiguous consent to process your personal data in accordance with this Privacy Policy. The personal data processing includes their collection, storage, use, transfer, dissemination, organization, combination, restriction, erasure or destruction, possibly involving third parties acting as data processors in accordance with the provisions of applicable law.

We ensure that all operations with personal data are carried out in accordance with the security and confidentiality standards provided for by applicable law, and you have the right to withdraw your consent at any time in accordance with the mechanisms provided for in this Privacy Policy.

LEGAL BASIS

We collect and process your personal data based on the following legal bases:

Necessity to perform an agreement: The processing of your personal data is necessary for the performance of an agreement between you and us or for the implementation of measures preceding the conclusion of an agreement.

Fulfillment of a legal obligation: We process your personal data to comply with a legal obligation imposed on us in accordance with applicable law, for example in the field of accounting, tax or financial regulation.

Legitimate interests: We may process your personal data based on our legitimate interests, in particular to effectively manage the Platform and Services and to improve the user experience. Our legitimate interests include ensuring the security and proper functioning of the Platform, improving our products and services, and marketing activities. We always carefully assess the impact of such processing on your rights and interests to ensure that our interests do not outweigh your privacy rights.

Consent: In some cases, we process your personal data based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing that took place before the withdrawal of consent.

DATA WE COLLECT ABOUT YOU

Depending on how you use the Platform, the Services, we may collect, process, store and transfer various types of personal data, in particular:

Personal Data voluntarily provided by you: you provide to us this data when you apply for Services, contact support, send e-mails or otherwise interact with us. Such data may include, but is not limited to: your first and last name, e-mail address, phone number, as well as other information that you voluntarily provide to us.

Information from external services: If you connect to the Platform via external services (e.g. Telegram), we receive certain information such as your first and last name, profile picture and unique user identifier (UID). We use this data to provide access to the Bot and offer services. If you click on any third-party links, the collection, use and transfer of your data will also be governed by the privacy policy and other agreements of that third party.

Technical Data: We automatically collect certain information when you visit or use the Platform. This information does not directly identify you, but may include information on your device and Platform usage, such as your IP address, browser and device characteristics, operating system, language preferences, redirect URLs, device name, country, location, Platform usage information and other technical data. Such information is necessary to ensure the security and functioning of the Platform, as well as for internal analytics and reporting purposes. We may also use cookies and similar technologies to collect this information.

Location Data: We may collect data about your device’s location, which may be precise or approximate. The amount of data collected depends on the type of device you use and your settings. We may use GPS and other technologies to collect data about your current location (based on your IP address). You can limit our access to this data by changing your device settings. However, if you refuse access, some features of our Platforms may not be available.

Communication Data: We may collect your correspondence with the Manager, support, e-mails, registration forms and other communications, as well as your responses to our requests.

Payment Data: If you place an order, we collect certain data about your order necessary to process it. Please note that you provide certain payment information directly to our payment service providers, including your first and last name, credit card information, billing address, zip code, etc. We do not collect or store your payment information.

User Content: We allow you to share content publicly, including by posting reviews of the Services, asking questions, and providing answers to questions. Such User Content may be publicly available to others depending on where it is hosted.

We may process aggregated data that does not reveal your identity for the purpose of market analysis and improvement of the Platform, the Services. Such aggregate data may be derived from your personal data, but it is not considered personal because it does not identify you. If we combine this data with your personal data, it will be processed in accordance with this Privacy Policy.

We do not collect any special categories of personal data, such as information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation or political views.

COLLECTION OF PERSONAL DATA

We use various methods to collect personal data about our Users, including through:

Direct interactions with you: you personally provide us with your personal data when you interact with us, such as when you visit the Platform, request the Services, use the Services, participate in surveys, provide feedback or contact us, etc.;

Automated technologies or interactions: During your interactions with the Platform, we may automatically collect technical data about your device, your actions and browsing patterns. We collect this personal data using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites that use our cookies;

Third parties: we may receive personal data about you from external services (e.g. Telegram, through an existing account on the Educational Platform; payment service providers, analytics providers, advertising networks, search information providers, technical providers, etc.);

Open sources for obtaining information about you: for example, receiving information from government agencies, publicly available information on the Internet.

We collect only those personal data that were knowingly and voluntarily provided by you as a subject of personal data for the purpose of using the Platform and Services, which, in accordance with the requirements of the current legislation, is the consent of the subject of personal data to the processing of personal data in accordance with the purpose and objectives set forth in this Policy.

PURPOSES OF USE OF PERSONAL DATA

We process and use your personal data to fulfill our obligations under the agreement with you, to comply with legal requirements, based on your consent and to ensure our legitimate interests.

We will use your personal data for the following purposes:

conducting pre-contractual negotiations and communications, as well as concluding the Terms of Use;

performing the terms of the agreement and managing the contractual relationship, including, but not limited to, providing the Services, monitoring compliance with the Terms of Use, providing you with support and communicating with you, resolving disputes, etc.;

managing our relationship with you, including sending messages through the communication channel chosen by you (e.g. e-mail, Telegram messenger, other means of electronic communication chosen by you) including, but not limited to, about changes to the Services, the Terms of Use or this Privacy Policy, requests for feedback or taking part in a survey;

to constantly update our data on how users use the Services;

collecting market data to study user behavior, including their benefits, interests, determining our marketing campaigns and developing our business;

to administer, update, maintain, protect and improve the Platform, the Services, including for the purpose of ensuring network security and preventing fraud;

to store information containing personal data in backup systems;

to disclose data to our service providers, agents, subcontractors and other related organizations, our group companies and affiliates;

for internal business purposes, in particular, but not limited to, to help us improve the content and functionality of the Platform, the Services; to better understand our users; to protect you from illegal activities; to provide you with service; for market research purposes; for strategic development;

for our marketing and advertising purposes, in particular, but not limited to, sending relevant advertising messages via e-mail, SMS marketing, media program, etc.;

disclosure of data to government agencies, regulatory and law enforcement agencies;

disclosure of data to our legal advisers for the establishment, exercise or defence of legal claims, whether in court or in an administrative or out-of-court procedure, concerning our rights, the rights of our users or employees;

arranging the sale or merger of our company and providing information for legal or other audits and data exchange;

disclosure of data to successors in title and/or potential acquirers of the company;

for any other purpose for which you give your consent.

We may process your personal data for other purposes, provided that we disclose the purposes and terms of use to you at the relevant time and that you consent to the proposed use of the personal data, there are other legal grounds for the new purposes of processing or the new purpose is compatible with the initial purpose stated above.

You may receive marketing communications from us if you have requested information from us or used the Services and in any event you have not opted out of receiving such marketing communications. You can ask us to stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you or by contacting us at any time.

DISCLOSURE OF PERSONAL DATA

We keep your personal data confidential, except for cases where you have voluntarily provided the relevant information for general access to an unlimited number of persons. By using certain features of the Platform, the Services, you agree that some of your personal data may become publicly available.

We do not sell, trade, or transfer your personal data to any other company for any reason without your consent, except as stated in this Privacy Policy.

We reserve the right to disclose any personal data we have collected at any time when:

it is permitted or required by law; or

it is done to protect against, prevent, investigate actual or potential fraud, security issues, technical problems, unauthorized transactions or other violations; or

it is done to enforce the Terms of Use or other agreements; or

it is done to protect against violations of our rights or safety, right or safety of our Users or the public, as required or permitted by law; or

you have given your consent to do so.

We may also transfer personal data to our successor in connection with a corporate merger, consolidation, partial or complete sale of assets, bankruptcy or other corporate changes.

We transfer your personal data to our third-party service providers, agents, subcontractors and other related entities, our group companies and affiliates to provide the functionality of the Platform, the Services. These companies include, but are not limited to, those we have hired to manage the technical infrastructure necessary to provide the Services, assist in the protection and security of our Platforms, the Services, assist in promoting the Services, etc. Our Platform may contain links to websites or services of our partner networks, payment service providers, etc. If you follow a link to any of these websites or services, please note that these websites and any services that may be accessible through them have their own privacy policies and we do not accept any responsibility for these policies or for any information, including personal data, that may be collected through these websites or services, such as contact and location data, payment data, etc. Please review these policies before submitting any information or personal data to these websites or using these services.

SECURITY

We use appropriate data collection, storage and processing practices and security measures to protect your personal data against unauthorized access, alteration, disclosure, destruction or other processing. Only our authorized employees, agents and contractors (who have agreed to keep personal data secure and confidential) have access to personal data on a need to know basis.

You agree and acknowledge that the global Internet may be subject to security breaches and that the transmission of data over the global Internet may be insecure. We strive to use reasonable means to protect any personal data you provide us with access to, however, we cannot guarantee its absolute security.

Depending on the nature of the risks associated with the proposed processing of your personal data, we will apply the following security measures:

organizational measures (including, but not limited to, staff training and policy development);

technical measures (including, but not limited to, physical protection of data, pseudonymization and encryption);

ensuring the continued availability and integrity (including, but not limited to, maintaining adequate back-up copies of personal data).

We have put in place procedures to identify and deal with any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.

RETENTION OF PERSONAL DATA

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as long as required by applicable law. This period may extend beyond the end of your relationship with us, but only for as long as is reasonably necessary for us to pursue our legitimate business interests, carry out audits, comply with (and demonstrate compliance with) legal obligations (such as tax purposes), resolve disputes, and enforce our agreements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer need your personal data, we will destroy, delete or pseudonymise it.

INTERNATIONAL PRIVACY LAWS

We operate in many countries around the world. Accordingly, personal data may be transferred to and stored in many countries around the world, including the European Union (“EU”), the United States of America, and other countries in which we operate and/or our contractors operate. These regions often have different data protection standards. Recognizing these differences, when we transfer personal data to other countries, we protect that information as described in this Privacy Policy.

We take appropriate steps to ensure that the transfer of personal data complies with applicable laws and is carefully controlled to protect your privacy rights and interests.

We ensure that the information we receive (including personal data) is adequately protected to meet the requirements of cross-border transfers of personal data.

SAFETY OF MINORS

We do not permit minors (persons under 18 years of age or such other age of majority as established by the laws of the relevant jurisdiction, if such age is over 18) to use the Platform, the Services and, therefore, we do not knowingly process personal data of minors. If we discover that a minor is receiving the Services, we will take appropriate measures to immediately delete their account on the Educational Platform and personal data from our database.

If you believe that a minor is using the Platform, please contact us at: info@mindmafia.io.

EU USER RIGHTS

You may contact us at any time to exercise any of the rights granted to you by applicable EU data protection laws, including the following:

The right of access, as provided in Article 15 of the General Data Protection Regulation 2016/679 adopted by the European Parliament and the Council on 27 April 2016 (hereinafter also referred to as the “GDPR”).

You have the right to ask us whether we are processing your personal data and, if so, to obtain access to such data in the form of a copy. When providing the right of access, we will also provide you with additional information, such as the categories of personal data, the purpose of their processing, as well as any other information necessary for you to exercise such right of access.

To be able to process your written request, we must thoroughly verify your identity, so we reserve the right to request additional information to verify your identity depending on the criticality of the requested data. In particular, this serves to protect user data from unauthorized access by third parties.

The right to rectification, pursuant to Article 16 of the GDPR.

You have the right to have the data corrected if it is inaccurate or incomplete. We will correct any incomplete or inaccurate data we hold about you at your request, although we may need to verify the accuracy of new data you provide to us.

The right to erasure ("right to be forgotten"), pursuant to Article 17 of the GDPR.

This enables you to ask us, and where possible, other controllers to whom your personal data has been provided by us, to delete such data, unless there are compelling reasons for us to continue to process it. The deletion of personal data can only take place in certain cases provided for by law, listed in Article 17 of the General Data Protection Regulation (GDPR). This excludes situations when personal data are no longer needed by us in view of the primary purpose of their processing. Due to the way we provide certain services, it may take some time for backups to be removed.

The right to restriction of processing, pursuant to Article 18 of the GDPR.

This enables you to ask us to suspend the processing of your personal data in the following cases: (a) if you want us to establish the accuracy of the data; (b) if our processing of the data is unlawful, but you do not want us to delete it; (c) if you require us to retain the data, even if we no longer need it, because you need it to establish, exercise or defend in legal claims; or (d) you have objected to us using your data, but we need to check whether we have an overriding legal basis for using it.

The right to data portability pursuant to Article 20 of the GDPR.

This means that you can request transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format as far as is technically feasible. Please note that this right only applies to automated information for which you have first given us consent to use or where we used the information to perform a contract with you.

The right to object, pursuant to Article 21 of the GDPR.

This means that you can request that we no longer process your personal data. In this case, we will no longer process your personal data unless we prove that there are compelling legitimate grounds for such processing that outweigh your interests, rights and freedoms or for the formation, implementation and protection of legal claims.

You also have the right to object to the use of your personal data for direct marketing purposes where your personal data is processed for this purpose, including profiling to the extent that it is related to direct marketing. You can withdraw your consent to the processing of personal data at any time according to special instructions. For example, you have the right to withdraw consent by clicking on the "unsubscribe" link in the e-mail. You can also contact us with a corresponding request by sending a message to the e-mail address: info@mindmafia.io

We try to respond to all legitimate requests within 1 month. Sometimes we may need more time if your request is particularly complex or if you have made multiple requests. In this case, we will notify you of the expected deadline and keep you informed.

We reserve the right not to process requests that are excessive in nature or that are received without appropriate proof of identity. For example, deny access if it is necessary to protect the rights and freedoms of others, or deny the deletion of personal data if the processing of this data is necessary to fulfill obligations.

FOR US RESIDENTS

If at any time you decide that you no longer want to receive information about us, our Services, you can opt out by sending an appropriate e-mail to our e-mail address: info@mindmafia.io.

FOR CALIFORNIA RESIDENTS

California residents have the right to access personal data in a portable format, request correction or deletion of their personal information collected on the Platform. If you wish to exercise this right, or if you have any questions about our Privacy Policy and compliance with California law, please contact us by sending an e-mail to our e-mail address: info@mindmafia.io.

OTHER JURISDICTIONS

You may also have certain additional rights in relation to the information we hold about you under other data protection and privacy laws. For more information, please contact us at:info@mindmafia.io regarding your specific situation.

CHANGES

We may change this Privacy Policy unilaterally, without prior notice. We will notify you of any changes by posting a new version of the Privacy Policy on the Platform and by updating the "Last Update" date at the top of this document. In addition, we may (but will not be obligated to) provide additional notice of changes by e-mail. By continuing to use the Platforms, the Services, you agree to such changes. If you do not agree to the changes to this Privacy Policy, you should immediately stop using the Platform, the Services or any other aspect of our business.

The new Privacy Policy enters into force from the moment of its publication on the Site, unless otherwise provided by the new version of the Privacy Policy.

OUR CONTACTS:

IT Brains LLC

Registration code: L23000138051

Address: 2200 Sole Mia Sq Lane, North Miami, FL, USA, 33181

E-mail address: info@mindmafia.io