Privacy Policy
Last Updated: April 26, 2025
1. General Concepts
1.1. NACONIC LTD's policy regarding the processing of personal data was developed in accordance with the Data Protection Act of 2018 (DPA) and the regulations and rules of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, known as the General Data Protection Regulation (GDPR).
1.2. This Policy delineates the procedural framework for the management of personal data of users of the Platform https://elevamenta.com/ (hereinafter referred to as the "Platform"). It stipulates the conditions and principles that govern the processing of personal data, enumerates the rights of Users, and articulates the obligations of "NACONIC LTD." Additionally, it provides information regarding the measures implemented to safeguard the processed personal data.
1.3. This Policy pertains to all personal data procured by NACONIC LTD from Users of the Platform (hereinafter referred to as "Users").
1.4. Should there be disagreement with the stipulations outlined in the Policy, the User is obligated to cease utilization of the Platform without delay.
2. Terms and Definitions
2.1. The following terms are used in the Policy:
Personal data (hereinafter – PD) – information of a particular nature that pertains directly or indirectly to a natural person that is identifiable.
PD blocking – temporary suspension of PD processing is hereby declared, with the exception of cases in which processing is deemed necessary to clarify PD.
Depersonalization of PD – actions that render it impossible to determine, in the absence of additional information, whether PD belongs to a specific PD subject.
PD processing – any action or a set of actions performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of PD.
Operator – NACONIC LTD is responsible for the independent organization and execution of PD processing. The company establishes the objectives of processing the PD, determines the composition of the PD to be processed, and specifies the actions to be performed with the PD.
Personal account – A set of secure pages is created for each User upon registration. These pages are accessible upon entering the User's authentication data, which includes email address and password, into the designated fields on the WebPlatform.
Provision of PD – a plan of action that is intended to disclose PD to a specific person or group of people.
Distribution of PD – actions that are intended to disclose PD to an indefinite number of persons or to make it available for a limited number of persons include publishing PD in the media, posting it on information and communication networks, or making it accessible to any or other parties in any way. These actions are also referred to as PD transfer or disclosure.
User – a visitor to the WebPlatform, a subject of PD.
ISPD – personal data information system.
Destruction of PD – Actions that result in the irreparable loss of the content of PD in the ISPD, and/or the destruction of the material media of PD.
Cookies – NACONIC LTD gathers certain data automatically during the use of the WebPlatform when the designated software is installed on the User's device. This data includes the User's IP address, geographic location, browser information, operating system type, technical characteristics, equipment, and software utilized by the User, as well as the date and time of access to the WebPlatforms.
Cookies may be used in accordance with the Cookie Notice. Where consent is required by applicable law, non-essential cookies will only be used after the User has provided consent through a clear affirmative action via the cookie consent mechanism.
3. Legal Justifications and Objectives Underpinning the Processing of Personal Data
3.1. 3.1. Lawful Bases for Processing Personal Data
NACONIC LTD processes Users' personal data on the lawful basis that is appropriate for the specific purpose of the processing. Depending on the circumstances, the lawful bases may include:
- Performance of a contract – where processing is necessary to provide the Products and services requested by the User, manage the User's account, process purchases, provide access to purchased content, provide customer support, or otherwise fulfil NACONIC LTD's contractual obligations.
- Legal obligation – where processing is necessary for NACONIC LTD to comply with applicable legal, accounting, tax, regulatory, or other statutory requirements.
- Legitimate interests – where processing is necessary for the legitimate interests of NACONIC LTD or a third party, provided that such interests are not overridden by the User's rights and interests.
- Consent – where NACONIC LTD relies on the User's consent for a specific processing purpose, including certain marketing communications or other processing activities for which consent is required by applicable law.
The applicable lawful basis depends on the specific purpose and circumstances of each processing activity and is indicated in this Privacy Policy where relevant.
3.2. NACONIC LTD processes the User’s PD exclusively for the purposes of:
3.2.1. The User's registration and identification on the Platform is essential for full utilization of its features and resources.
3.2.2. NACONIC LTD is committed to facilitating effective communication between users and the Platform, facilitating smooth provision of its Products.
3.2.3. Fulfillment of NACONIC LTD obligations to the User under the agreements (Terms and Conditions and other relevant documents). This includes providing information regarding class dates and times, as well as sending out certificates.
3.2.4. Dissemination of advertising messages to Users, which includes email, phone, instant messaging, mail, SMS, and push notifications. These messages may contain information about products, services, special offers, promotions, or surveys.
3.2.5. Promoting content on the Platform, in official groups or social networks, and through other advertising channels and information sources for purposes not related to identifying the User such as reviews left by the user about the services provided by NACONIC LTD.
3.2.6. Enhancing the quality of Products provided and modernize the Platform by processing requests and applications from Users.
3.2.7. Statistical and other studies which are based upon anonymized information furnished by the Users.
3.3. The specific scope of PD processed for these purposes is outlined in Section 5 of the Policy.
4. Permission for NACONIC LTD to Process User PD
4.1. NACONIC LTD does not verify the PD provided by the User. In this context, NACONIC LTD operates under the assumption that when providing PD on the Platform, the User:
4.1.1. A person of capable abilities. In the absence of the User, consent for the processing of PD is provided by the User's legal representative, who has agreed to the terms of processing PD outlined in this Policy.
4.1.2. Is required to provide reliable information about himself/herself or the represented incapacitated person, as applicable, to the extent necessary to use the Platform. The User is responsible for maintaining the accuracy of the PD provided. The Terms and Conditions outline the consequences of providing false or insufficient information.
4.1.3. Should be aware that any information posted on the Platform may be visible to and potentially shared by other Users. This is governed by the Policy, which outlines the specific circumstances under which such sharing is permissible.
4.2. Lawful Basis for Processing Personal Data
NACONIC LTD processes the User's personal data on the lawful basis applicable to the specific purpose of the processing and in accordance with applicable data protection legislation.
4.2.1. Registration and Account Management
When the User registers on the Platform, NACONIC LTD processes the personal data provided through the registration form, including the User's email address and, where provided, first name and surname.
This processing is necessary for the performance of the agreement with the User, including creating and managing the User's Personal Account, identifying the User, and providing access to the Platform and Products.
4.2.2. Provision of Products and Services
NACONIC LTD processes personal data that is necessary to provide the Products and services requested or purchased by the User, including providing access to purchased courses and eBooks, managing purchases, providing customer support, communicating information related to the User's purchases, and issuing certificates where applicable.
This processing is necessary for the performance of the agreement between NACONIC LTD and the User.
4.2.3. Customer Support and Communication
Where necessary to respond to the User's requests, provide customer support, address technical issues, process refund requests, or otherwise communicate with the User regarding the Platform or Products, NACONIC LTD may process the User's name, email address, telephone number, and other information voluntarily provided by the User.
Such processing is based on the performance of the agreement where it is necessary to provide the requested service or fulfil NACONIC LTD's contractual obligations. Where processing is not necessary for the performance of a contract, NACONIC LTD may rely on its legitimate interests in managing and improving customer relationships and resolving enquiries.
4.2.4. Marketing and Promotional Communications
NACONIC LTD may send Users information about Products, services, special offers, promotions, surveys, and other marketing communications by email, telephone, SMS, instant messaging, or other communication channels where permitted by applicable law.
Where consent is required by applicable law, such marketing communications will be sent only where the User has provided the necessary consent. The User may withdraw consent or opt out of marketing communications at any time.
4.2.5. Technical, Security and Platform Data
When the User accesses or uses the Platform, NACONIC LTD may process certain technical information, including IP address, browser type, operating system, device information, and information collected through cookies or similar technologies.
Such processing may be necessary for the operation, security, maintenance, and protection of the Platform and may be based on NACONIC LTD's legitimate interests, where applicable. Where consent is required for the use of particular cookies or similar technologies, such consent will be obtained separately in accordance with applicable law.
4.2.6. Legal and Regulatory Compliance
NACONIC LTD may process and retain personal data where necessary to comply with applicable legal, tax, accounting, regulatory, or other legal obligations, as well as to establish, exercise, or defend legal claims.
Such processing is carried out on the basis of the applicable legal obligation or, where appropriate, NACONIC LTD's legitimate interests.
4.2.7. Optional Information
Where the User voluntarily provides additional personal information that is not necessary for the provision of the Products or services, NACONIC LTD will process such information only where there is an appropriate lawful basis under applicable law, including consent where consent is required.
4.3. Where processing of Personal Data is based on the User's consent, such consent will be obtained through an appropriate clear affirmative action and will be limited to the specific processing purpose for which it is provided. Where consent is not the applicable lawful basis, Personal Data may be processed on another lawful basis set out in this Privacy Policy and applicable law. Use of the Website or Platform does not, by itself, constitute consent where applicable law requires a separate affirmative action.
4.4. The User's consent to PD processing, as outlined in this Privacy Policy, is valid from the date of consent and for the period necessary to achieve the purposes of PD processing or until the User chooses to revoke this consent. This period may be extended as permitted by current legislation in the United Kingdom. The User may withdraw his/her consent to the processing of PD at any time. NACONIC LTD acknowledges the User's right to revoke consent previously provided to the processing of PD. This revocation may be made in one of the following ways:
- Submitting the relevant application via postal mail to the address provided: 55 Pentland Crescent, Rosewell, United Kingdom, EH24 9BJ.
- Submitting the relevant application in the form of an electronic document to support@elevamenta.com.
5. Personal Data Processed by NACONIC LTD
5.1. Processing of User PD is carried out under the following conditions:
| Purpose for PD utilization | Volume of processed PD |
|---|---|
| Registration on the Platform (clause 3.2.1) | last name, first name; email address; Address, including post box number, city and country; profile avatar; |
| Identification on the Platform (clause 3.2.1) | email address; |
| Displaying a profile for other Platform Users (clause 3.2.2) | last name and first name; profile avatar; nickname; |
| Establishing and maintaining communication between User and NACONIC LTD, consulting on the provision of services (clause 3.2.3) | last name and first name; phone number; email address; |
| Conclusion of contracts, fulfillment of obligations under them (clause 3.2.4) | last name and first name; phone number; email address; address of actual residence; bank details (if necessary to fulfill obligations); |
| Sending advertising messages, newsletters, providing advertising information in writing (clause 3.2.5) | last name and first name; phone number; email address; |
| Posting photos and videos, received during the provision of NACONIC LTD Products, User comments regarding the NACONIC LTD Products (clause 3.2.6) | last name and first name; profile avatar; |
| Improving the quality of products and User experience and modernizing the Platform (clause 3.2.7) | cookies; |
| Statistical and other studies based on anonymized information (clause 3.2.8) | cookies; |
6. Processing of the User PD
6.1. NACONIC LTD processes PD based on the following principles:
- The principles of legality and procedural fairness.
- The processing of PD must be limited to the fulfillment of specific, predetermined, and legitimate purposes.
- Preventing the processing of PD which is incompatible with the purposes of collecting PD.
- Preventing the consolidation of databases containing PD that is processed for purposes that are not compatible with each other.
- Processing of PD is conducted in a manner that is solely for the purposes for which the data was collected.
- Ensuring that the content and volume of processed PD align with the established objectives of processing.
- Ensuring that the processing of PD remains proportionate to the initially stated objectives of its use.
- Ensuring the accuracy, sufficiency, and relevance of PD in relation to the purposes of PD processing.
- The legitimate grounds for destruction or depersonalization of PD include the achievement of the purposes for which it was processed or the expiration of the need to achieve these goals. Other grounds for destruction include a request by the User or revocation of consent for processing PD.
6.2. NACONIC LTD processes Users' personal data (recording, systematization, accumulation, storage, clarification, and retrieval) using databases on the territory of the United Kingdom.
6.3. NACONIC LTD processes users' PD, both with and without the use of automated systems.
6.4. NACONIC LTD and other parties with access to PD are obligated to refrain from disclosing or distributing such data to third parties without the express consent of the individual concerned, unless corresponding law stipulates otherwise.
6.5. The processing of the User's PD encompasses a series of actions that include collection, recording, systematization, accumulation, storage, clarification (e.g., updating and changing), extraction, use, transfer (distribution, provision to third parties, or access), depersonalization, blocking, deletion, and destruction.
6.6. Users' PD is stored on electronic media for security and compliance purposes. NACONIC LTD is authorized to extract and store PD for the purpose of fulfilling obligations under agreements with the User. The storage of such PD is carried out for the period established by the legislation of the United Kingdom. The specific location of PD storage is:
- Until the User deletes PD, it will remain in the "My Profile" and "Settings" sections of Personal Account on the Platform.
- NACONIC LTD will comply with the User's request to revoke consent for the processing of PD or request the destruction of PD.
- The consent will remain in effect until the expiration date indicated in clause 4.4 of this Privacy Policy.
6.7. NACONIC LTD reserves the right to transfer PD in accordance with the United Kingdom's legislation or the consent of the subject to whom the PD pertains to third parties, namely:
6.7.1. NACONIC LTD collaborates with a variety of partners, including platform and application owners, advertising networks, and other entities that offer services related to the placement and display of advertising on platforms, programs, products, or services owned or controlled by these partners.
6.7.2. Elevamenta collaborates with external partners to deliver Products to Users on the Elevamenta Platform, accessible at https://elevamenta.com/.
6.8. The transfer of PD to third parties as specified in clause 6.7 of this Privacy Policy is contingent upon the fulfillment of the following conditions:
- A third party processes PD using databases on the territory of the United Kingdom.
- The third party is obligated to maintain the confidentiality of PD during processing and use and is prohibited from disclosing or distributing the PD of Users without their consent.
- The following measures have been implemented by the third party in order to guarantee compliance with security requirements for the processing of PD: the use of security information technology tools; the detection and recording of any incidents related to the unauthorized access of PD, as well as taking measures for the restoration of the aforementioned data; the restriction of access to PD; the registration and the recording of all actions with PD; and the monitoring and assessment of the effectiveness of the security measures taken.
- The following list enumerates the methods that are deemed permissible for the processing of PD: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.
- Third parties are strictly forbidden from transferring or distributing PD.
7. Measures implemented by NACONIC LTD to safeguard PD
7.1. NACONIC LTD has implemented comprehensive security measures to safeguard the information provided by users. These measures are designed to prevent unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions by third parties. The following actions are exemplary, although not exhaustive:
- The implementation of organizational and technical measures to secure PD during its processing in information systems.
- For establishing a comprehensive monitoring system to identify and address any instances of unauthorized access to PD. This system should be designed to proactively prevent such incidents from occurring in the future.
- For monitoring the measures taken to ensure the security of PD, as well as the level of security of PD information systems.
8. User Rights
8.1. The User voluntarily chooses to furnish PD and consent to its processing, acting in his/her own self-interest. The User hereby expresses his/her consent to the processing of PD in the manner delineated in clause 4.2 of this Privacy Policy.
8.2. Pursuant to the provisions stipulated in the relevant legislation, the User is entitled to receive information from NACONIC LTD regarding the processing of his PD.
8.3. The User reserves the right to submit claims to NACONIC LTD regarding the use of his/her PD and the revocation of consent for the processing of PD. The claim may be submitted via the following methods:
8.3.1. In accordance with the stipulations outlined in clause 4.4 of this Privacy Policy.
8.3.2. The document is to be submitted in digital format, such as a scanned or photocopied image of the original document. The document must be dispatched from the User's email address, as specified during the registration process on the Elevamenta Platform, to the email address: support@elevamenta.com.
9. Update, Correction, Deletion and Destruction of PD
9.1. NACONIC LTD is committed to providing Users or their representatives with the information outlined in Article 20 of the GDPR. This includes details regarding the availability of PD relevant to the User. Additionally, NACONIC LTD is obligated to offer Users or their representatives the opportunity to review these PDs. This opportunity is available upon request within 10 (ten) days from the date of receipt of the User's or their representative's request. This period may be extended, but not more than by five (5) working days, after reasonable notice is sent to the User indicating the reasons for the extension.
9.2. NACONIC LTD is committed to providing Users or their representatives with the opportunity to acquaint themselves with the PD relating to this User at no cost.
9.3. NACONIC LTD will make the necessary changes to the PD within 7 (seven) business days of receiving confirmation from the User or their representative that the PD is incomplete, inaccurate, or irrelevant.
9.4. NACONIC LTD will destroy any illegally obtained or unnecessary PD within 7 (seven) business days of receiving confirmation from the User or their representative that the PD is either illegally obtained or not necessary for the stated purpose of processing. NACONIC LTD also strives to notify the User or their representative about any changes made, as well as the measures taken. Furthermore, reasonable measures are taken to notify third parties to whom the PD of this User is transferred.
9.5. In the event that the PD is found to be inaccurate, NACONIC LTD will, in accordance with the information provided by the User or his/her representative or the authorized body for the protection of the rights of PD subjects, or other necessary documents, undertake to clarify the PD or ensure clarification (if the processing of PD is carried out by another person acting on behalf of NACONIC LTD) within 7 (seven) business days from the date of submission of such information and removal of the PD blocking.
9.6. NACONIC LTD is committed to ceasing the processing of PD or ensuring that the processing of PD is halted by an individual acting on behalf of NACONIC LTD:
- In the event that illegal processing of PD is detected by the Operator or an individual acting on behalf of NACONIC LTD, the Operator will notify the affected individuals within 3 (three) business days from the day of detection.
- If the User revokes consent for the processing of his/her PD.
- The objective of processing PD is to be achieved.
9.7. NACONIC LTD is committed to destroying the User's PD or ensuring its destruction (if PD processing is carried out by third party acting on behalf of NACONIC LTD) within 30 (thirty) days from the date the purpose of PD processing is achieved.
9.8. If it's not possible to permanently delete the PD within the time limit mentioned in clause 9.7 of this Privacy Policy, NACONIC LTD will block the PD or make sure it's blocked (if third party is processing the PD on behalf of NACONIC LTD) and make sure the PD is deleted within 6 (six) months, unless the provisions stipulated in the relevant legislation say otherwise.
10. Privacy Policy Changes
10.1. NACONIC LTD has the right to change this Privacy Policy. The User is obliged to familiarize himself with the text of this Privacy Policy each time he/she uses the Platform.
10.2. The new version of this Privacy Policy will be effective as of the moment it is published on the designated section of the NACONIC LTD Platform. Continued use of the Platform or its Products after the publication of a new version of this Privacy Policy indicates acceptance of it and its terms by the User. In the event of a disagreement with the terms of this Privacy Policy, the User must immediately cease using the Platform and its Products.
10.3. Should you have any inquiries regarding this Privacy Policy, please direct them to the following email address: support@elevamenta.com.