Privacy Policy

Version as of 05.09.2019


Section 1

General Provisions

1. Introduction

1.1. This Privacy Policy is a complete statement of general principles and practical approaches applied by the Company and teachmecash.com website to collect, store, process, use, transfer, modify and delete personal data received from Users. The Privacy Policy describes the principles of the Company's work with the User's information, the amount of information received by the Company from the User, the reasons for its collection, the purpose of use, the procedure for processing, storage, modification and disposal. This Privacy Policy will be amended from time to time. Amendments to this Privacy Policy are made in a way of presenting its new version. Amendments to this Policy take effect for the User once the User has reviewed the new version of the Policy.

1.2. The operator of personal data of the teachmecash.com website is the Company Vinchell Limited, with the address: ROOM 7B, One Capital Place, 18 Luard Road, Wan Chai, Hong Kong, telephone +44 077 8485 2435, email: [email protected], websites: vinchell-ltd.com, teachmecash.com.

1.3. The meanings of terms used in this Policy correspond to those defined in the Terms and Conditions of the teachmecash.com website. In the text of this Policy, the names "Company", "we", "us" in any grammatical form refer to the Company Vinchell Limited as the only operator of personal data of the teachmecash.com website. In the text of this Policy, the term "website" in any grammatical form refers to the teachmecash.com website.

1.4. Personal data is any data that pertains to an identified or identifiable natural person. Personal data includes all types of information that directly or indirectly identify a person.

1.5. Due to the fact that TeachMeCash project is implemented by posting on the website in the public domain, and some of its users may be residents of the European Union, the content of this Privacy Policy complies with the requirements of the General Date Protection Regulation (GDPR) of the European Union.

1.6. The website User may only be an adult who has reached the age of eighteen. The personal data of minor users of the website shall not be collected or processed.

1.7. In order to exercise your rights in the field of personal data protection, or if you have any questions with regard to the collection, use or processing of your personal data, please contact the Company via the website, or use the following direct contact: Mr. Illia Danylenko, email: [email protected] Telephone: +44 077 8485 2435.

2. Basic Principles and Approaches of the Company for Personal Data Collection and Processing

2.1. Observance of User data confidentiality is the fundamental principle of the Company. The Privacy Policy and methods of the Company are aimed at protecting the rights of Users and ensuring confidentiality at all stages of working with information.

2.2. Users' information shall be collected, stored, processed, used, transmitted, modified and deleted on the basis of the principles of legality, good faith and transparency.

2.3. The Company shall collect, store and process information only after obtaining the consent of the User for such collection, processing and storage. Such consent shall be explicitly and clearly provided by the User in the manner prescribed by this Policy. This consent is a prerequisite for the User's participation in TeachMeCash project.

2.4. Personal data of the Users is not subject to transfer and disclosure to third parties except as provided for in this Policy.

2.5. The Company shall collect, store and process only the data that is critical and necessary for the operation of TeachMeCash project and achieving specific goals.

2.6. The Company shall store and process personal data only for a period determined by the purpose of its use. These terms are indicated in Section 2 of this Privacy Policy for each information category separately. After the expiration of these terms, the data shall be deleted by the Company independently, since there is no longer a need to store and process it.

3. The Rights of Personal Data Subjects and the Procedure for Exercising the Rights

The moment when the Company begins to collect and process personal data, the User becomes the personal data subject within the meaning provided for by GDPR and shall have the following rights in relation to the Company as the Operator of personal data:

3.1. The User shall have the right to information. This right implies:

3.1.1. the Company's notification of the User on the collection and processing of information and obtaining consent thereto;

3.1.2. the opportunity for the User to contact the Company via the Personal account with a request about the collection and processing of their own personal data, information categories, recipients of this information, the planned storage and processing time, as well as any other parameters of the collection, storage and processing of personal data that are of interest to the User;

3.1.3. access to the personal data transferred to the Company - such data shall be constantly reflected in the Customer's Personal account in full scope.

3.2. The User shall have the right to change the personal data transferred to the Company. Such right shall be exercised by the User applying to the Company via a Personal account. When changes are made to the personal data transferred to the Company, the Company shall notify of such changes everyone whom this personal data has been transferred to, if there is a reasonable need for it. In case of receipt of the User's application to change his personal data, the Company shall conduct a procedure to replace irrelevant personal data with the current one, whereafter the current personal data shall be stored and processed, and irrelevant personal data shall be deleted.

3.3. The User shall have the right to restrict the collection and processing of personal data, to object to the processing of personal data and to withdraw his statement of consent to the collection and processing of personal data. As stated above, the Company shall collect, store and process only the data that is critical and necessary for the operation of TeachMeCash project and achieving specific goals. Thus, the existing amount of information that Users transmit to the Company is that critical minimum that ensures the operation of the project and the Company's cooperation with the User. At the same time, the User shall have the right to restrict the collection and processing of personal data, to object to the processing of personal data and to withdraw a statement of consent to the collection and processing of personal data. Such rights shall be exercised by a Customer sending a request to the Company via the Personal account about the restriction of the collection and processing of personal data, about the objection to the processing of personal data or about withdrawing a statement of consent to the collection and processing of personal data.

In this regard, the implementation of these rights may be carried out at the request of a User under the terms of this Policy, but such actions shall result in termination of the User's participation in the project due to objective impossibility of such participation.

Should the User submit a statement about restricting the collection and processing of personal data, about objections to the processing of personal data or about the withdrawal of the statement of consent to the collection and processing of personal data, the Company shall carry out the procedure for closing the Customer's Personal account pursuant to the Terms and Conditions of the website, whereafter the personal data shall cease to be collected, and upon expiration of the term to store relevant information, as specified in Section 2 of this Policy, all obtained personal data shall be deleted.

3.4. The User shall have the right to delete personal data transferred to the Company. This right may be exercised in two ways:

3.4.1. Planned removal. As stated above, the Company shall store and process personal data only for a period determined by the purpose of its use. These terms are indicated in Section 2 of this Privacy Policy for each category of information separately. After the expiration of these terms, the data shall be deleted by the Company independently, since there will be no longer a need for its further storage and processing. Thus, upon the expiration of personal data use, the Company shall independently remove them as superfluous, thereby realizing the User's right to delete personal data.

3.4.2. Unplanned removal. As stated above, the Company shall collect, store and process only the data that is critical and necessary for the operation of TeachMeCash project and achieving specific goals. Thus, the existing amount of information that Users transmit to the Company is that critical minimum that ensures the operation of the project and the Company's cooperation with the User. At the same time, the right of the User shall be the right to delete his personal data. Such a right shall be exercised by the Customer sending to the Company via the Personal account a request for the early removal of all or part of his personal data.

In this regard, the deletion (both full and partial) of the information transmitted by the User to the Company may be carried out at the request of a User under the terms of this Policy, but such actions shall result in termination of the User's participation in the project due to objective impossibility of such participation.

Should the User submit a statement about removal of his personal data, the Company shall carry out the procedure for closing the Customer's Personal account pursuant to the Terms and Conditions of the website, whereafter the personal data shall cease to be collected, and upon expiration of the term to store relevant information, as specified in Section 2 of this Policy, all obtained personal data shall be deleted.

3.5. Taking into account the specifics of TeachMeCash project and within its framework, such User's right as the right to transfer his personal data to another personal data operator can be realized with extremely low probability, since TeachMeCash project is unique in its own way. Accordingly, the very existence of another similar personal data operator seems unlikely. However, the Customer is entitled to contact the Company via his Personal account with a statement about the transfer of his personal data to another personal data operator. Such statement shall be accompanied by the technical specification of another personal data operator in order to assess the technical feasibility of carrying out the transfer of information. Should it turn out to be possible, the procedure for closing the Customer's Personal account shall be performed pursuant to the Terms and Conditions of the website, whereafter the Customer's personal data shall be transferred to the new personal data operator, and upon expiration of the term to store relevant information, as specified in Section 2 of this Policy, all obtained personal data shall be deleted.

4. Obligations of the Personal Data Subject

4.1. To properly protect his information, the User must take all reasonable measures to ensure information security - to use modern and up to date antivirus protection, to store passwords to his Personal account and e-mail with due diligence, to warn an unauthorized third party access to the technical means of communication with the project, to adhere to the norms set out by the Terms and Conditions of the Website and the Cooperation Agreement.

4.2. The User must transmit to the Company only accurate and reliable information. The Company shall not be responsible for the consequences of the User's providing inaccurate or unreliable data.

5. Acceptance of the Privacy Policy and Consent to the Collection, Storage and Processing of Personal Data

5.1. The Company shall collect, store and process data only from those Users who have given their consent to the collection, storage and processing of this data.

5.2. The consent of the User to the collection, processing and storage of data shall be provided in the process of registering the User on the website by agreeing with the terms and conditions of this Policy and shall be recorded by putting the mark "I have read and agree to the Privacy Policy Terms and Conditions. I agree to the collection, storage and processing of personal data".

5.3. Users who do not agree with this Privacy Policy shall not be granted access to the website. Users who agreed to this Privacy Policy, but subsequently changed their opinion, and found this Privacy Policy unacceptable should contact the Company via a Personal account with a statement about the withdrawal of the statement of consent to the collection and processing of personal data and then stop using the website.

6. Transfer of Personal Data to Third Parties

6.1. The personal data of the Users are not subject to transfer and disclosure to third parties except for the following cases:

6.1.1. transfer of personal data to employees and partners of the Company in order to fulfill their responsibilities for servicing Users;

6.1.2. if the User has agreed to such transfer;

6.1.3. if such transfer is stipulated in the Cooperation Agreement;

6.1.4. if the purpose of such data transfer is directly related to the purpose for which personal data was initially collected;

6.1.5. if it is necessary for the preparation, clarification and execution of a Cooperation Agreement (conclusion of an agreement, its implementation, payment, amendment of conditions);

6.1.6. if it is required by law, administrative or judicial decision;

6.1.7. if it is required to substantiate or defend against lawsuits or to defend in court;

6.1.8. if it is necessary to fulfill the legitimate demands of state authorities, including national security services and law enforcement agencies;

6.1.9. if it is necessary as part of KYC, AML or other similar procedures;

6.1.10. if it is necessary to prevent abuse or other illegal actions, such as coordinated hacker attacks.

7. Legal Foundations for Personal Data Processing (for Subjects of the GDPR Regulation)

7.1. If the Company obtains consent from the personal data subject to implement personal data processing procedures, Clause 1 (a) of Article 6 of the GDPR shall be the legal foundation.

7.2. If the processing of personal data is necessary to fulfil a contract to which the personal data subject is a party, Clause 1 (b) of Article 6 of the GDPR shall serve as the legal foundation. The same applies to the processing procedures required for the implementation of precontractual activities.

7.3. If the processing of personal data is necessary to fulfill the legal obligation imposed on the Company, Clause 1 (c) of Article 6 of the GDPR shall serve as the legal foundation.

7.4. If the need to process personal data is caused by the vital interests of the personal data subject or another individual, Clause 1 (d) of Article 6 of the GDPR shall serve as the legal foundation.

7.5. If data processing is necessary in order to respect the legitimate interest of the Company or a third party and interests, and the fundamental rights and freedoms of the personal data subject do not have priority over the above interest, Clause 1 (f) of Article 6 of the GDPR shall serve as the legal foundation.

8. SSL/TLS Encryption

8.1. To ensure confidentiality of communication with the User, the Company shall use the so- called SSL/TLS encryption of the modern level. You can identify the connections encrypted in this way by the name "https://" in the website address, which appears in the address bar of your browser, as well as by the green lock icon in the address bar. Websites without encryption are designated as "http://". Data transmitted to Internet websites using the function of SSL/TLS encryption (for example, when making purchases or requests), is not available for viewing by third parties, thanks to SSL/TLS encryption.

Section 2

Types of User Information, Its Receiving, Handling and Removal

9. Accessing the Website

9.1. Description: each time the website is accessed, our system automatically collects data and information from the computer system used to gain the access.

9.2. Content of information: as part of this procedure, the Company shall receive the following information: type and version of the browser, operating system, Internet provider, IP address of the User, date and time of access, Internet websites used by the User to access our web page.

9.3. Information collection procedure: information shall be transmitted from the User to the Company via the website automatically, and shall be stored in the registration files of our system. Storage of this data together with other personal data of the User shall be excluded.

9.4. Use of information: Temporary storage of an IP address by the system is a prerequisite for the Internet website delivery to a User's computer. To accomplish this, the User's IP address must be saved throughout the session. Saving to the registration file shall be performed in order to ensure the operability of the webpage. In addition, we need the data to optimize the website and ensure the security of our information technology systems.

9.5. Information severity: the information specified in this Clause is critical in the sense that without it, the use of the Website by the User shall not be possible from a technical point of view.

9.6. Terms of information storage: data shall be deleted as soon as it ceases to be necessary to achieve the purpose for which it is collected. In the case of data collection for accessing a website, this is the moment the session ends. In the case of saving data to the registration files, this moment comes no later than seven days after the end of the session. Data may be stored longer than the specified period. In this case, the IP addresses of the User shall be deleted or distorted so that they can no longer be correlated with the Customer accessing the website.

9.7. The possibility of limiting, objection, modification and early deletion: collecting data when accessing the website and storing data in the registration files is absolutely essential for the website operation. Thus, there shall be no possibilities for the User to restrict, object, modify or prematurely delete this information. If you object to the collection and processing of such information - you should immediately stop using the website.

10. Use of Cookies by the Website

10.1. Description and procedure for collecting information: the teachmecash.com website uses cookies. A cookie is a text file containing an identifier (a string of letters and numbers) that is sent by the website to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the website, thereby helping us identify the users of the website.

Cookies can be "immutable" or "sessional". Immutable cookies will be stored in a web browser and will remain valid until the expiration date has passed, unless the User deletes them before the expiration date. The sessional cookie is deleted automatically at the end of the User session when the web browser is closed. On the website, we use both sessional and immutable cookies.

You can learn more about these files on the following third-party resources: https:// en.wikipedia.org/wiki/HTTP_cookie or http://www.allaboutcookies.org/.

When accessing our website, the information banner provides the User with the information about the use of cookies, and the link is provided to the cookie policy, as well as the User's consent to the processing of personal data, used in this regard, is requested.

10.2. Content and use of information: as it has already been determined, cookies enable us to identify users of our website. The purpose of this identification is to facilitate the work of users with our website. Using this file, the website memorizes your actions and settings (username, language, font size, and other information display options). Thanks to this, you do not need to specify them again every time you access the website or switch from one page to another.

A User of a website that uses cookies, is not required, for example, to re-enter his login data every time he visits the website, as the website itself and the cookies, stored in the User's computer system, do this for him.

The purpose of using cookies for technical reasons is to simplify the User experience of working with a website. Some features of our website may turn out to be unavailable without the use of cookies. For these functions, it is necessary for the browser to be also recognized after changing the page.

The purpose of using cookies, created for the analysis, is to improve the quality of our web site and its content. Thanks to cookies, developed for the analysis, we can find out exactly how the website is used, and constantly optimize the delivery of information.

The User's data, collected in such a way, is ensured anonymity with the help of technical means. Thus, it becomes impossible to compare the data with the User accessing the website. Such data is stored separately from the other personal data of the User.

10.3. Terms of storage and deletion of information: the retention of immutable cookies vary depending on their purpose, but, as a rule, does not exceed six months. Sessional cookies shall be deleted automatically at the end of the User session when the web browser is closed. Early deletion of cookies can be performed by the User at any time by means of an Internet browser or another program.

10.4. Information severity, the possibility of restriction, objection, modification and premature removal: the User may at any time prohibit our website to create cookies for him, having chosen the appropriate settings of the browser used, and thereby expressing an objection to the creation of cookies on a long-term basis. Previously created cookies can be also deleted at any time by means of an Internet browser or another program. All common Internet browsers allow for this.

Under certain conditions, as a result of deactivation by the User of cookies creation in the Internet browser used, the use of all the functions of our website in its entirety may not be possible. In this regard, the use of cookies is critical in the sense that without such use, not all functions of the website will work correctly.

11. User's Registration on the Website

11.1. Description: to access the website services, the User, in the manner determined by the Terms and Conditions of the website, shall undergo a registration procedure, during which he sends his basic contact information to the Company.

11.2. Information content: as part of the registration procedure, the User shall send the following information to the Company: a password (entered twice to avoid an error), an email address (verified), a phone number (verified), last name and first name, and notification of attainment of majority.

11.3. Information collection procedure: information shall be transferred from the User to the Company via a Personal account during the registration procedure. The Company shall block the progress of the User during the registration procedure in the case of failure to provide the information.

11.4. Use of information: the information, specified in this Clause, shall be collected for the purpose of the User's registration on the website, his identification and verification, security, communications with the User (including sending newsletters with the ability to unsubscribe), ensuring the ability to create a Customer's Personal account, the ability to conclude Cooperation Agreement with the User and ensuring the implementation of such an Agreement. In addition, if the User participates in the Referral or Career programs, his name, surname, e-mail address and telephone number will be available to the participants of the nearest referral lines in order to establish communication.

This data shall be transmitted only to participants directly related to the Customer - participants using the referral link of the Customer and the participant whose referral link was used by the Customer.

11.5. Information severity: since the participation of the User in the project involves the creation of a Personal account and the conclusion of an agreement with him, the subject of which is the mutual provision of information services and the reciprocal payment for such services, it shall be objectively impossible to achieve such a goal without collecting, processing and storing the information specified in this Clause. In this regard, the information specified in this Clause is critical in the sense that without it the participation of the User in TeachMeCash project shall not be possible.

11.6. Terms of information storage: the information specified in this Clause shall be stored by the Company from the moment the registration process ends until seven years have passed from the date the last Cooperation Agreement concluded has expired, whereafter it shall be automatically deleted. In case of early deletion of information at the request of the User, the specified period begins on the date when the Customer's Personal account is closed. Such terms of information storage are subject to the law applicable under a Cooperation Agreement, according to which the general period of limitation constitutes six years. Since the participation of the User in the project involves the conclusion of a contract with him, the subject of which is the mutual provision of information services, as well as the reciprocal payment of such services, without ensuring the storage and processing of the specified information during the specified period, the Company's rights cannot be fully protected.

11.7. The possibility of limiting, objection, modification and early removal: the collection of data during the Use registration and its subsequent storage and processing is an absolute prerequisite for the participation of the User in TeachMeCash project and for the conclusion of the Cooperation Agreement with the User. Thus, if you have objections to the collection of information specified in this Clause, you should immediately stop using the website.

On the initiative of the User, the information specified in this Clause may be limited in the collection and processing, an objection may be raised against its collection and processing, or said information may be prematurely deleted.

In case of receipt of the User's application to limit, object, or early remove his personal data, the Company shall perform the procedure of closing the Customer's Personal account in accordance with the Terms and Conditions of the website, whereafter his personal data shall cease to be collected, and upon the expiration of seven years from the closing date of the Customer's Personal account, all personal data obtained shall be deleted.

On the initiative of the User, the information specified in this Clause may be modified. In case of receipt of the User's application to change his personal data, the Company shall perform the procedure for replacing irrelevant personal data with the current data, whereafter the current personal data shall be stored and processed, and irrelevant personal data shall be deleted.

12. Responses to Surveys

 12.1. Description: in order to fulfill the terms and conditions of the Cooperation Agreement, the Customer shall send to the Company responses to Surveys to be used by the latter for marketing purposes as a feedback from the market. Responses to Surveys help to understand the needs and trends of the online education markets.

12.2. Information content: as part of providing responses to the Surveys, the User shall transfer the following information to the Company: personal opinions of the Customer, reflecting his view on the current state and development prospects of the online education market in various segments of interest to the Company (subject, territorial, time, financial).

12.3. Information collection procedure: information shall be transmitted from the User to the Company via a Personal account.

12.4. Use of information: the information specified in this Clause shall be collected for the purpose of obtaining marketing and statistical information in order to create online education courses or for transferring to third parties for their creation of online education courses. In other words, this information shall be used as a market response to questions about where and which online education courses will be in demand. Such use of information is entirely dictated by the goals for which the information is initially collected.

12.5. Information severity: since the User's participation in the project implies his participation in the Surveys, the purpose of which is to obtain information, and the value of such information directly depends on the possibility of its differentiation and conducting marketing information segregation, it would be objectively impossible to achieve such goals without collecting, processing and storing the information specified in this Clause. In this regard, the information specified in this Clause is critical in the sense that without it the participation of the User in TeachMeCash project shall not be possible.

12.6. Terms of information storage: the information specified in this Clause shall be stored by the Company from the moment it is received until the moment the Customer’s Personal account is closed, whereafter it shall be automatically deleted. In case of early removal of information at the request of the User, the information shall be deleted simultaneously with the closure of the Customer’s Personal account.

12.7. The possibility of limiting, objection, modification and early removal: data collection for the purpose of differentiating the information obtained in the framework of the Surveys and its subsequent storage and processing is an absolutely necessary condition for the User’s participation in TeachMeCash project. Thus, if there are objections to the collection of information specified in this Clause, you should immediately stop using the website.

On the initiative of the User, the information specified in this Clause may be limited in its collection and processing, an objection may be raised against its collection and processing, or said information may be prematurely deleted.

In case of receipt of the User's application to limit, object, or remove his personal data prematurely, the Company shall perform the procedure of closing the Customer’s Personal account in accordance with the Terms and Conditions of the website, whereafter his personal data shall cease to be processed and shall be deleted.

On the initiative of the User, the information specified in this Clause may be modified. In case of receipt of the User's application to change his personal data, the Company shall perform the procedure for replacing irrelevant personal data with the current data, whereafter the current personal data shall be stored and processed, and irrelevant personal data shall be deleted.

13. Differentiation of Information Received in Surveys

 13.1. Description: in order to fulfill the terms and conditions of the Cooperation Agreement, the Customer shall send to the Company responses to Surveys to be used by the latter for marketing purposes as a feedback from the market. In order to differentiate the information received as part of the Surveys (to obtain marketing information segregation), the User, in the manner determined by the Terms and Conditions of the website, shall provide the Company with differentiating information.

13.2. Information content: as part of the provision of differentiating information, the User shall transfer the following information to the Company: date of birth, gender, place of birth (state and locality), place of residence (state and locality), address in one or more social networks and (or) message services, data on the level of education, specialty, work experience, field of activity, position of the Customer, his hobbies, level and sources of his income, and expenses.

13.3. Information collection procedure: information shall be transmitted from the User to the Company via the website. The process of collecting information can take place in several stages. The Company shall determine the sequence of information collection on its own. The Company shall have the right to block the progress of the User in the Personal account in case of failure to provide information.

13.4. Use of information: the information specified in this Clause shall be collected to differentiate the results of the Surveys with the intention to obtain marketing information segregation when processing the results of the Surveys. Such use of information is entirely dictated by the goals for which the information is initially collected.

13.5. Information severity: since the User's participation in the project implies his participation in the Surveys, the purpose of which is to obtain information, and the value of such information directly depends on the possibility of its differentiation and conducting marketing information segregation, it would be objectively impossible to achieve such goals without collecting, processing and storing the information specified in this Clause. In this regard, the information specified in this Clause is critical in the sense that without it the participation of the User in TeachMeCash project shall not be possible.

13.6. Terms of information storage: the information specified in this Clause shall be stored by the Company from the moment it is received until the moment the Customer’s Personal account is closed, whereafter it shall be automatically deleted. In case of early removal of information at the request of the User, the information shall be deleted simultaneously with the closure of the Customer’s Personal account.

13.7. The possibility of limiting, objection, modification and early removal: data collection for the purpose of differentiating the information obtained in the framework of the Surveys and its subsequent storage and processing is an absolutely necessary condition for the User's participation in TeachMeCash project. Thus, if there are objections to the collection of information specified in this Clause, you should immediately stop using the website.

On the initiative of the User, the information specified in this Clause may be limited in its collection and processing, an objection may be raised against its collection and processing, or said information may be prematurely deleted.

In case of receipt of the User's application to limit, object, or remove his personal data prematurely, the Company shall perform the procedure of closing the Customer’s Personal account in accordance with the Terms and Conditions of the website, whereafter his personal data shall cease to be processed and shall be deleted.

On the initiative of the User, the information specified in this Clause may be modified. In case of receipt of the User's application to change his personal data, the Company shall perform the procedure for replacing irrelevant personal data with the current data, whereafter the current personal data shall be stored and processed, and irrelevant personal data shall be deleted.

14. Financial Information

 14.1. Description: in order to fulfill the terms and conditions of the Cooperation Agreement, the Customer shall pay the cost of the TeachMeCash subscription in favor of the Company, and the Company shall pay the cost of the Surveys in favor of the Customer. In the process of making these payments, the Company shall collect, process and store related financial information.

14.2. Information content: in the process of preparing, receiving and making payments under the Cooperation Agreement, the Company shall collect, process and store the following information: the quantity, cost and dates of the purchased TeachMeCash Subscriptions, the quantity, cost and dates of the processed Surveys, the number, amounts and dates of accrued and withdrawn funds, the number, amount and date of all expenditure and income transactions on the Posting account, the payment details of the Customer, used to make the payment, the payment details of the Customer, which were or will be used to receive payments. The content of information pertaining to the payment details shall be determined by the payment instrument that was chosen by the Customer for making settlements (e-wallet number, link for making payment in cryptocurrency, bank card number, bank account number).

14.3. Information collection procedure: information shall be collected in several ways - transferred from the User to the Company via the website for making payments, collected when making payments, transferred to the Company by means of payment instruments used for making payments.

14.4. Use of information: the information specified in this Clause shall be collected to ensure settlements under the Cooperation Agreement, ensure the efficiency and informativeness of the Customer’s Personal account, inform the Customer about the progress of the Cooperation Agreement, as well as to accumulate information on the proper implementation of mutual obligations by the Customer and the Company under the Cooperation Agreement and confirmation, if necessary, of the fact of the corresponding payment.

14.5. Information severity: since the User's participation in the project involves the creation of a Personal account and the conclusion of an agreement, the subject of which is the mutual provision of information services and the reciprocal payment for such services, it would be objectively impossible to achieve such goals without collecting, processing and storing the information specified in this Clause. In this regard, the information specified in this Clause is critical in the sense that without it the participation of the User in TeachMeCash project shall not be possible.

14.6. Terms of information storage: the information specified in this Clause shall be stored by the Company from the moment it is received until the moment when seven years have passed from the expiration date of the last concluded Cooperation Agreement, whereafter it shall be automatically deleted. In case of early removal of information at the request of the User, the specified term shall commence on the date the Customer's personal account is closed. Such terms of information storage are subject to the law applicable under the Cooperation Agreement, according to which the general limitation period constitutes six years. Since the participation of the User in the project involves the conclusion of an agreement with him, the subject of which is the mutual provision of information services, as well as the reciprocal payment for such services, the mutual rights of the Company and the Customer cannot be fully protected without ensuring the storage and processing of the specified information during the specified period.

14.7. Possibility of limiting, objection, modification and early removal: the collection of financial data and its subsequent storage and processing is an absolutely necessary condition for the participation of the User in TeachMeCash project. Thus, if there are objections to the collection of information specified in this Clause, you should immediately stop using the website.

On the initiative of the User, the information specified in this Clause may be limited in its collection and processing, an objection may be raised against its collection and processing, or said information may be prematurely deleted. In case of receipt of the User's application to limit, object, or remove his personal data prematurely, the Company shall perform the procedure of closing the Customer's Personal account in accordance with the Terms and Conditions of the website, whereafter his personal data shall cease to be collected, and after seven years have passed from the date the Customer's Personal account was closed, all obtained personal data shall be deleted.

Taking into account the specifics of financial information, its modification shall not be possible. In addition, such a modification would violate the rights of the Parties to the Cooperation Agreement and contradict the principle of information accuracy.

15. KYC and AML Procedures

15.1. Description: the TeachMeCash website and project do not carry out identification and verification of their Customers by their personal, banking and other documents. We consider that the data specified above is sufficient for identification and verification of the Customer. At the same time, in the future, a situation may arise when such identification and verification is required (for example, when developing a project or using new payment instruments). In this regard, we consider it necessary to notify Users in advance of the possible occurrence in the future of the need to transfer to the Company a certain amount of personal data related to the KYC (Know Your Client) and AML (Anti-Money Laundering) procedures. Please note that this scope of documents may be required in the future, for all or part of Users. You may learn in more detail about these procedures by visiting the links: https://en.wikipedia.org/wiki/ Money_laundering, https://www.fatf-gafi.org/.

15.2. Information content: should it become necessary to perform KYC and (or) AML procedures, the User shall submit to the Company details and (or) copies of identity documents, certificates from banks servicing the Customer, utility bills and payment confirmations, tax payments confirmation, proof of legal origin of the funds used for payment, photos of the Customer with identity documents, or other similar documents.

15.3. Information collection procedure: information shall be transmitted from the User to the Company via a Personal account. The Company shall block the User's progress in the project in case of failure to provide information.

15.4. Use of information: the information specified in this Clause may be collected solely for the purpose of meeting the requirements of banking and financial institutions as well as state and (or) intergovernmental bodies and organizations that perform KYC and (or) AML procedures, or other similar procedures aimed at combating illicit money laundering; combating the financing of terrorism and combating the proliferation of weapons of mass destruction.

15.5. Information severity: according to the methodology of organizations that perform KYC and (or) AML procedure, failure to undergo such procedures, should there be a need to, shall result in the denial to establish business relationship and (or) the denial to perform transactions. In this regard, the information specified in this Clause is critical in the sense that its absence will make it impossible to conduct financial operations of the Company and the Customer, which in turn will make it impossible to implement the terms of the Cooperation Agreement.

15.6. Terms of information storage: the information specified in this Clause shall be stored by the Company from the moment it is received until the moment when ten years have passed from the expiration date of the last concluded Cooperation Agreement, whereafter it shall be automatically deleted. In case of early removal of information at the request of the User, the specified term shall commence on the date the Customer's Personal account is closed. Such terms of information storage are determined by the methodology of the KYC and (or) AML procedures.

15.7. Possibility of limiting, objection, modification and early removal: the collection of data and its subsequent storage and processing is an absolutely necessary condition for the participation of the User in TeachMeCash project and implementation of the Cooperation Agreement. Thus, if there are objections to the collection of information specified in this Clause, you should immediately stop using the website.

On the initiative of the User, the information specified in this Clause may be limited in its collection and processing, an objection may be raised against its collection and processing, or said information may be prematurely deleted.

In case of receipt of the User's application to limit, object, or remove his personal data prematurely, the Company shall perform the procedure of closing the Customer's Personal account in accordance with the Terms and Conditions of the website, whereafter his personal data shall cease to be collected, and after ten years have passed from the date the Customer's Personal account was closed, all obtained personal data shall be deleted.

Taking into account the specifics of information, specified in this Clause, its modification shall not be possible. In addition, such a modification would be contrary to the principle of reliability of information and the purposes of its collection and storage.

16. Google Analytics

16.1. The website uses Google Analytics technologies and other similar services to collect and store data for marketing research and website optimization. These technologies use cookies, which are detailed in Clause 10 of this Privacy Policy. These cookies within the specified services are written to your web browser not by the Company, but by the respective service provider.

16.2. User may at any time prohibit the creation of cookies for him, by performing the appropriate settings of the browser used and thereby expressing an objection to creating cookies on a long-term basis. Previously created cookies can be also deleted at any time by means of an Internet browser or another program. All common Internet browsers allow for this.

16.3. Under certain conditions, when the User has deactivated cookies creation in the Internet browser used, the use of all the functions of our website in its entirety may not be possible. In this regard, the use of cookies is critical in the sense that without such use, not all functions of the website will work correctly.

17. Google Recaptcha

17.1. To protect the forms of entry to the website, we use Google Inc. Recaptcha service. The use of this service makes it possible to recognize whether the corresponding data entry is performed by a person or in an unauthorized way — by an automated machine processing system.

17.2. The IP address and other data that may be collected by Google Company as part of this service, shall be transmitted to Google Company. These services are subject to the Privacy Policy of the provider of this service Google Inc. Company.

18. Plugins

18.1. The website uses integrated video content of third-party providers such as YouTube.

18.2. The Privacy Policy of third-party providers is beyond the control of the Company, therefore for more information on the Privacy Policy in this section you should read the Privacy Policy of each such third-party provider.

19. Links to Other Websites

19.1. The website, the Customer's Personal account and subscription materials may contain links to third-party websites. The Company tries to monitor such links by checking their functionality and security during posting. But at the same time, the Company cannot guarantee that the link, which is working and safe today, will remain the same tomorrow.

19.2. In this regard, the Company declares that it does not bear the responsibility for the Privacy Policies of third-party websites, since it has no influence on these policies.

By making the following mark, I agree that:
I am of age, which means reaching the age of full 18 years;
I have read and agree to the Website Terms and Conditions and Privacy policy and also agree to the collection, storage and processing of my personal data;
This website uses cookies for the convenience of using the website, I have read and agree to the Cookie policy.