Privacy Policy

1. INTRODUCTION

1.1. This Privacy Policy describes how IE Martynov Evgeny Igorevich (TIN 575310590533, OGRNIP 325570000000711), operating the educational platform "Codik" (hereinafter referred to as "we", "us", "the Company", or "the Service"), collects, uses, stores, and protects your personal data when you use our website at itcodik.com and the Codik mobile application.

1.2. By using the Service, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your data as described herein.

1.3. If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, additional rights under the General Data Protection Regulation (GDPR) apply to you. If you are a resident of California, USA, the California Consumer Privacy Act (CCPA) grants you additional rights as described in Section 10.

2. DATA CONTROLLER

2.1. The data controller responsible for your personal data is:

• IE Martynov Evgeny Igorevich
• Address: 302027, Russia, Orel region, Orel, Matveeva st., 14, apt. 18
• Email: support@itcodik.com

2.2. For any questions regarding data protection, please contact us at support@itcodik.com.

3. DATA WE COLLECT

3.1. Account data (provided by you):

• Name and email address (for identification and communication)
• Profile photo (optional, if provided via social login)
• Authentication data from third-party providers (Yandex, VK) if you choose to sign in with them

3.2. Learning data (generated through your use of the Service):

• Course progress and completion status
• Quiz and exercise results
• Achievements and statistics
• Project submissions

3.3. Payment data (processed by our payment provider):

• Payment card details are processed and stored exclusively by our payment provider (CloudPayments) and are never stored on our servers
• We retain only transaction identifiers, amounts, and dates

3.4. Technical data (collected automatically):

• IP address, browser type, operating system
• Device information (for mobile application)
• Pages visited, features used, session duration
• Cookies and similar technologies (see our Cookie Policy)

4. LEGAL BASIS FOR PROCESSING (GDPR)

4.1. We process your personal data on the following legal bases:

• Contract performance (Art. 6(1)(b) GDPR): Processing necessary to provide the Service, manage your account, and fulfill subscription obligations
• Legitimate interests (Art. 6(1)(f) GDPR): Analytics, service improvement, fraud prevention, and technical security
• Consent (Art. 6(1)(a) GDPR): Optional cookies, marketing communications (where applicable)
• Legal obligation (Art. 6(1)(c) GDPR): Compliance with applicable laws and regulations

5. HOW WE USE YOUR DATA

5.1. We use your data exclusively for:

• Providing and maintaining the educational service
• Processing payments and managing subscriptions
• Personalizing your learning experience
• Communicating with you about your account and the Service
• Analyzing usage to improve the Service
• Ensuring security and preventing fraud
• Complying with legal obligations

5.2. We do not sell your personal data to third parties.

5.3. We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects.

6. DATA SHARING

6.1. We may share your data with:

• Payment processors: CloudPayments — to process subscription payments. CloudPayments acts as an independent data controller for payment data
• Hosting and infrastructure providers: For storing data and ensuring the Service operates reliably
• Analytics services: Anonymized or aggregated data for service improvement
• Law enforcement: When required by law or valid legal process

6.2. All third-party service providers are contractually obligated to protect your data and use it only for the specified purposes.

7. INTERNATIONAL DATA TRANSFERS

7.1. The Company is based in the Russian Federation, and your data may be stored and processed on servers located in Russia.

7.2. If you are located in the EEA, UK, or Switzerland, please note that Russia is not considered by the European Commission to provide an adequate level of data protection. By using the Service, you consent to the transfer of your data to Russia.

7.3. We implement appropriate technical and organizational measures to ensure an adequate level of protection for your data regardless of where it is processed.

8. DATA RETENTION

8.1. We retain your personal data for as long as your account is active or as needed to provide you with the Service.

8.2. After account deletion, we retain your data for up to 1 (one) year for dispute resolution and legal compliance purposes, after which it is permanently deleted.

8.3. Payment transaction records are retained as required by applicable tax and accounting laws.

8.4. Anonymized or aggregated data that cannot identify you may be retained indefinitely for analytical purposes.

9. YOUR RIGHTS (GDPR)

9.1. If you are located in the EEA, UK, or Switzerland, you have the following rights:

• Right of access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate or incomplete data
• Right to erasure: Request deletion of your personal data ("right to be forgotten")
• Right to restrict processing: Request limitation of how we use your data
• Right to data portability: Receive your data in a structured, machine-readable format
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time

9.2. To exercise any of these rights, please contact us at support@itcodik.com.

9.3. We will respond to your request within 30 days. You also have the right to lodge a complaint with your local data protection authority.

10. YOUR RIGHTS (CCPA — CALIFORNIA RESIDENTS)

10.1. If you are a California resident, you have the following rights under the CCPA:

• Right to know: You may request information about the categories and specific pieces of personal information we have collected about you
• Right to delete: You may request deletion of your personal information
• Right to opt-out of sale: We do not sell your personal information
• Right to non-discrimination: We will not discriminate against you for exercising your CCPA rights

10.2. To exercise your rights, contact us at support@itcodik.com.

11. CHILDREN'S PRIVACY

11.1. The Service is not directed at children under the age of 13 (or 16 in EEA countries where applicable). We do not knowingly collect personal data from children under these ages.

11.2. If you are a parent or guardian and believe your child has provided us with personal data, please contact us and we will promptly delete it.

12. DATA SECURITY

12.1. We implement appropriate technical and organizational measures to protect your personal data, including:

• Encrypted connections (TLS/SSL) for all data transfers
• Regular data backups
• Access controls limiting who can view personal data
• Security monitoring and incident response procedures

12.2. While we strive to protect your data, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

13. CHANGES TO THIS POLICY

13.1. We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised "Last updated" date.

13.2. For material changes, we will notify you via email or through the Service before the changes take effect.

13.3. Your continued use of the Service after any changes constitutes acceptance of the updated Privacy Policy.

14. CONTACT US

14.1. If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

• Email: support@itcodik.com
• Website: itcodik.com