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.

By accepting the terms of the Policy, an individual indicates their consent to the utilization of cookies.

3. Legal Justifications and Objectives Underpinning the Processing of Personal Data

3.1. The legal justification for processing PD by NACONIC LTD is:

Civil Code of the United Kingdom.
GDPR of 27 April 2016.
Data Protection Act of 2018 (DPA).
Other applicable regulatory legal acts of the United Kingdom.
Consent of the User to the processing of PD.

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. Displaying the User's profile for other Users of the Platform.
3.2.3. NACONIC LTD is committed to facilitating effective communication between users and the Platform, facilitating smooth provision of its Products.
3.2.4. 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.
3.2.5. 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.
3.2.6. 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.
3.2.7. Enhancing the quality of Products provided and modernize the Platform by processing requests and applications from Users. This also includes recording telephone conversations with NACONIC LTD, with the aim of improving service quality and preserving evidence in the event of disputes between NACONIC LTD and its Users.
3.2.8. 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 Use'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. By accepting the terms of the Privacy Policy, the User gives NACONIC LTD voluntary consent to process User PD in accordance with the Privacy Policy and applicable law:

4.2.1. Registering and identifying on the Platform, note that Elevamenta will require User to provide PD, which will be collected when User fill out the registration form located at https://elevamenta.com/registration/. By clicking the "Sign up" button, the User indicates his/her consent for the processing of PD.

4.2.2. When editing or entering PD in the "Settings" section of your Personal Account. At the User's request, the following information may be specified in the Personal Account: gender; image uploaded through the Platform or via a link from a social network, but not limited to, also links to profiles on social networks. The specified PD can be used to fulfill NACONIC LTD's obligations stipulated by the Terms and Conditions or current Privacy Policy. The User is considered to have consented to the processing of newly entered or changed PD. After filling out the fields specified in the 'Settings' section, the PD will be updated automatically.

4.2.3. When filling out the Feedback form, including applications for courses, NACONIC LTD will collect your PD. By clicking the button confirming the submission of the application, the User gives consent for the processing of PD entered in the Feedback form fields.

4.2.4. Subscribing for receiving, advertising, and news materials from Elevamenta on the Elevamenta website at https://elevamenta.com/. By clicking on the "Subscribe Now" button, the User indicates his/her consent for the processing of PD.

4.2.5. For every instance of using the Platform, there is a transfer of PD to NACONIC LTD, facilitated by the software installed on the User's device. By using the Platform, Users therefor, consent to the processing of PD.

4.3. Performing the actions specified in clause 4.2 of this Privacy Policy, the User gives NACONIC LTD consent to process the specified PD, the list of which is specified in section 5 of this Privacy Policy. This includes collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision to third parties, access), depersonalization, blocking, deletion, and destruction of the PD with or without the use of automation tools, in accordance with the purposes specified in Section 3 of this Privacy Policy.

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; data from accounts on social networks, messengers;
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; data from accounts on social networks;
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's personal data (recording, systematization, accumulation, storage, clarification, and retrieval) using databases on the territory of the United Kingdom.

6.3. NACONIC LTD processes users's 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.