Privacy and personal data protection policy
The present Privacy and Personal Data Protection Policy (hereinafter referred to as the "Policy") is developed in accordance with the requirements of Directive 2002/58/EC of the European Parliament and of the Council of July 12, 2002, concerning the processing of personal data and the protection of privacy in the electronic communications sector (Privacy and Electronic Communications Directive) and 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, and repealing Directive 95/46/EC (hereinafter referred to as the "Law").

This Policy establishes the procedure for the processing of personal data by NEXT EDUCATION GROUP LIMITED (hereinafter referred to as the "Company"), provided by customers using the website http://fibata.eu/ and its specific services for the purpose of receiving or providing services (hereinafter referred to as "Users" and "Website," respectively). The Policy defines the types of personal data collected, the purposes of using such personal data, the Company's interaction with third parties, security measures to protect personal data, conditions of access to personal data, as well as contact information for users regarding accessing, making changes, blocking, or deleting their personal data and addressing any questions that may arise regarding the practice of personal data protection.
The Company holds great respect for the confidential (personal) information of all individuals, without exception, who visit the website http://fibata.eu, as well as those who use the services provided by the Website. Therefore, the Company strives to protect the confidentiality of personal data (information or a set of information about an identified or identifiable individual), thereby creating and ensuring the most comfortable conditions for the use of the Website's services for each user.

The Policy text is accessible to users on the Internet at https://fibata.eu/privacy-policy-en. In the event of disagreement with the terms of the Policy, the user must immediately cease any use of the website.

1. Terminology and Abbreviations

  1. The terminology used in this Policy signifies the following:
1.1. Personal Data - Any information directly or indirectly related to a specific or identifiable individual (data subject).

1.2. Company - First Baltic Trading Academy, registered at the address:

1.3. Processing of Personal Data - Any action or set of actions performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

1.4. Automated Processing of Personal Data - Processing personal data using computer technology. However, automated processing of personal data does not include a system of automated processing, including profiling, that creates legal consequences for the user or similarly significantly affects the user.
1.5. Distribution of Personal Data - Actions aimed at disclosing personal data to an indefinite circle of persons.

1.6. Provision of Personal Data - Actions aimed at disclosing personal data to a specific individual or identifiable group of persons.

1.7. Blocking of Personal Data - Temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).

1.8. Use of Personal Data - Actions (operations) with personal data carried out by the Company for decision-making or other actions that have legal consequences for the data subject or other individuals or otherwise affect the rights and freedoms of the data subject or other individuals.

1.9. Anonymization of Personal Data - Actions that make it impossible, without the use of additional information, to determine the belonging of personal data to a specific data subject.

1.10. Destruction of Personal Data - Actions that make it impossible to restore the content of personal data in the information system of personal data and/or actions that result in the destruction of material carriers of personal data.

1.11. Online Program - An educational program where training is conducted exclusively using distance learning technologies on the Company's online platform, accessible at http://fibata.eu/.

1.12. Online Platform - The Company's software, representing a set of interconnected web services and modules that constitute a unified space for providing services to consumers on the Internet.

1.13. Free Session - Audiovisual material (webinar) provided by the Company free of charge to all Users who register to participate in such a webinar, including access to all related materials. The Company conducts free sessions for all interested Users. A free session is not a complete or partial educational program.

1.14. User Agreement - An agreement posted on the Internet at http://fibata.eu/offerta-en, serving as an offer by the Company to enter into an agreement with any third party using the Website under the conditions specified in the User Agreement.

1.15. Website - The collection of information, texts, graphic elements, design, images, photos, videos, and other results of intellectual activity, as well as computer programs, contained in the information system, providing access to such information on the Internet at the network address http://fibata.eu/.

1.16. Personal Account - A section of the Website that the User accesses after registering on the Website by entering a unique login and password.

1.17. Cookie Files - Data automatically transmitted to the Company during the use of the Website through the software installed on the User's device, including IP address, geographical location, information about the browser and type of the User's device's operating system, technical characteristics of the equipment and software used by the User, and the date and time of access to the Website. Cookie files can be permanent (referred to as persistent cookie files) and stored on the computer until the user deletes them or temporary (session cookie files), which are stored only until the browser is closed. Additionally, cookie files are categorized as first-party (set directly by the visited Website) and third-party (set by other websites).

1.18. "IP Address" - A numerical designation used by computers in a network to identify a computer each time it connects to the Internet.

2. User Consent for the Processing of Personal Data by the Company

2.1. The User accepts the terms of the Policy and provides the Company with informed and conscious consent for the processing of their personal data under the conditions specified in the Policy and the Law:

2.1.1. During registration on the Website - for personal data that the User provides to the Company:
  • By filling out the registration form on the Internet, the User is considered to have given consent to the processing of their personal data when the checkbox in the field "I Accept the Terms of the Offer Agreement and Agree to the Personal Data Processing Policy" is checked at the moment of clicking the "Register" button.
  • By authorizing using personal data specified by the User in social networks or electronic services. The User is considered to have given consent to the processing of their personal data at the moment of clicking the button indicating the selected social network or electronic service for authorization.
By clicking the specified button, the User consents to the transfer of all personal data made publicly available by them through the profile of the respective social network or electronic service to the Company.

2.1.2. When entering or modifying personal data in the "Personal Data," "My Interests" section in the personal account - for personal data provided by the User when editing information in the "Personal Data," "My Interests" section in the personal account. The User is considered to have given consent to the processing of their newly entered or modified personal data at the moment of clicking the "Save" button.

2.1.3. When filling out the feedback form - for personal data that the User provides to the Company when filling out the feedback form on the Website and electronic services (Google, etc.). The User is considered to have given consent to the processing of their personal data entered in the fields of the feedback form at the moment of clicking the button confirming the submission of the request (buttons may be named "Send," "Submit Request," or similar).

2.1.4. When subscribing to receive informational and news materials from the Company - by filling out the subscription form located on the Internet. The subscription form becomes available after completing the registration process. The User is considered to have given consent to the processing of their personal data by checking the checkbox in the field "I hereby consent to the processing of personal data" at the moment of clicking the "Subscribe" button.

2.1.5. Enrollment in training for the Online Program - by filling out the application fields for enrollment in training located on the Internet. The User is considered to have given consent to the processing of their personal data by checking the checkbox in the "Enroll in Training" form at the moment of clicking the "Enroll" button.

2.1.6. When sending a scanned copy of the completed consent form for the processing of personal data via email – for personal data that the User provides to the Company to receive educational services on the Website as part of an additional professional education program. The User is considered to have given consent to the processing of their personal data at the moment of sending the scanned copy of the consent to the email address with the domain name @l-a-b-a.com.

2.1.7. Enrollment in a Free Session - by filling out the application fields for enrollment located on the Internet. The User is considered to have given consent to the processing of their personal data by checking the checkbox in the "Enroll in Training" form at the moment of clicking the "Enroll" button.

2.1.8. In any use of the Website - for personal data automatically transmitted to the Company during the use of the Website through the software installed on the User's device. The User is considered to have given consent to the processing of their personal data at the moment of starting to use the Website.

2.2. The User's consent to the processing of their personal data by the Company is valid from the day the consent is provided (Section 2.1 of the Policy) and during the period necessary to achieve the purposes of processing personal data (Section 5 of the Policy).

2.3. The User has the right to withdraw their consent to the processing of personal data in the form and manner provided in Section 9 of the Policy.


3. Terms of Providing User's Personal Data:

The Company operates on the understanding that when providing personal data on the Website, the User:

3.1. Confirms that they possess all necessary rights enabling them to acquire civil rights for themselves and independently exercise them. The User also asserts their ability to create civil obligations for themselves through their actions, independently fulfill them, and bear responsibility in case of non-compliance.

3.2. Provides accurate information about themselves to the extent necessary for using the Website and maintains the provided personal data up to date.

3.3. In the case of uploading their image through the personal account on the Website, provides consent on a gratuitous basis for the use of this image for purposes not related to establishing the User's identity. The User undertakes not to provide photos of third parties as their own image.

3.4. Recognizes that the information about themselves posted by the User on the Website may become accessible to other Website Users, may be copied, and distributed by such Users in cases and under conditions specified in section 6.7 of the Policy.

3.5. Acknowledges that any telephone conversations conducted with a Company employee are automatically recorded for the purpose of quality control of user service and for resolving disputable and conflict situations that may arise during such phone conversations. The User provides consent for such automatic recording of phone conversations and the storage of such recordings in accordance with the terms of this Policy.

3.6. Has acquainted themselves with this Policy, expresses their informed and conscious agreement with it.

4. Personal Data Processed by the Company

4.1. The personal data processed by the Company concerning the User includes:
  • Last name, first name, patronymic;
  • Mobile phone number;
  • Email address;
  • Data of accounts on social networks and electronic services (links to User profiles on VKontakte, Facebook, Linkedin, Skype, Google, Twitter, etc.);
  • Image;
  • Workplace;
  • Country, city;
  • Date of birth;
  • Profession;
  • Data on work experience and occupation;
  • IP address;
  • Cookies files;
  • Parameters and settings of internet browsers (User-agent).

4.2. The Company protects the data that is automatically transmitted during the viewing of advertising blocks and when visiting pages with the installed statistical script of the system ("pixel"):
  • IP address;
  • Information from cookies;
  • Information about the browser (or other program that accesses advertising display);
  • Time of access;
  • Address of the page containing the advertising block;
  • Referrer (address of the previous page).
4.3. All logins to the system are recorded when visiting the Website. Other user traffic information is not processed and not stored.

4.4. The Company does not collect any information subject to specific legislative requirements, such as information about racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties and trade unions, condemnation to criminal punishment for committing a crime or criminal punishment, as well as data related to health, sexual life, biometric, or genetic data.

4.5. The Company collects data on website visit statistics. The information may include details about connections, traffic, user browser, as well as the date, time, duration of internet activity, and presence on the Website.

4.6. Any other personal information not mentioned above (visit history, used browsers and operating systems, etc.) is subject to secure storage and non-disclosure.
5. Using Cookies

5.1. The Company cares about its users and strives to make their stay on the Website as comfortable as possible. For this purpose, the Company needs to analyze user behavior, preferences, and interests through cookies. Such analysis helps the Company enhance the user experience on the Website, identify the most user-friendly interface, and improve Service navigation.

5.2. According to the International Chamber of Commerce classification, the Company uses the following categories of cookies:
  • Strictly Necessary Cookies - essential for users to navigate web pages and use specific services, such as accessing secure pages, registration, and authentication, as well as conducting searches on the Website. They also help remember the user's previous actions when navigating back to the previous page within the same session.
Operational Cookies - aggregate information on how the Website is used. These data are stored on the user's device between web browser sessions. Examples of such data may include metrics such as time spent on the Website, most frequently visited pages, understanding which sections and services of the site were most interesting to the user, and the effectiveness of specific advertising and/or marketing campaigns, etc. All information collected through operational cookies is intended for statistical and analytical purposes. Some cookie data may be provided to third parties with permission from the web resource, solely for the purposes mentioned above.

Functional Cookies - used to store settings or configurations on the user's device between web browser sessions. Examples of such data may include metrics such as the username, profile photo, information about posted comments, language preferences, location, whether any information or selected preferences were provided to the user previously, as well as other Site settings. These cookie data also enable users to watch videos, participate in interactive elements (surveys, polls), and interact with social networks.

To enhance the user experience after visiting the site, the specified cookies remember the information provided by the user, increasing the effectiveness of interaction with the website. Some cookie data may be provided to third parties with permission from the web resource, solely for the purposes mentioned above.

Targeting Cookies - used to provide content that may be of interest to the user. These data are stored on the user's device between web browser sessions. Examples of such data may include metrics such as tracking recommended text, graphics, audio, and video content to avoid repeated display, managing targeted advertising, evaluating the effectiveness of advertising campaigns, information about the user's visits to other resources during transitions, as well as other site settings.

The website may share this information with other parties, including media clients, advertisers, agencies, and partners in related businesses, to enable them to provide high-quality targeted advertising.
Third-party service and analytics cookies:

For prompt delivery, improved display, and detailed content analysis on the website, the Company utilizes services owned by other third-party companies such as Facebook, Twitter, Instagram, Alphabet Inc., Gemius, and others. The companies mentioned as examples may use cookies on the user's device while using the website.

It should be noted that the website cannot influence the operation of cookies used by these services. All necessary information about their usage can be obtained by visiting the respective resources.
Google Analytics Terms of Service - http://www.google.com/analytics/terms/ru.html
Cookie Management:

Major web browsers (listed below) are configured to automatically accept cookies. To disable them, use the help feature in your browser. You can access the help feature through the menu or by pressing the F1 key.
Important:

  • The cookie settings configuration for web browsers on mobile devices may vary.
  • It's essential to note that the full functionality of the website is available only when using cookies.
  • Disabling cookies may restrict access to content and result in the incomplete functioning of the site's services.
If a user does not enable the use of cookies or intentionally deletes all cookies from their web browser, they will be prompted to enable and use cookies again when revisiting the site.
Information about users obtained through cookies is not sold, disclosed publicly, and remains the property of the company that owns the resource.

6. Purposes of Processing Personal Data

The Company processes the personal data of users exclusively for the following purposes:

6.1. Registration of the user by the Company on the website, providing the user with the opportunity for full use of the site's services.

6.2. Displaying the user's profile on the website in the personal account.

6.3. Establishing and maintaining communication between the user and the Company, providing consultation on service-related matters, offering customer and technical support in case of issues related to the use of the website.

6.4. Fulfilling the Company's obligations to the user who has enrolled in online programs, signed up for free classes, or entered into agreements with the Company.

6.5. Sending advertising messages of the Company to the user's email address; targeting advertising materials.

6.6. Improving the quality of user service and upgrading the Company's website by processing user requests and applications.

6.7. Conducting statistical and other research based on anonymized information provided by the user.

6.8. Publishing on the Company's online platform, available at http://fibata.eu/, in official social media groups and other online communities maintained by the Company, as well as in other advertising and informational sources, for purposes unrelated to establishing the user's identity:
  • Video materials obtained during the provision of services.
  • Reviews left by the user about the services provided by the Company.
Users have the right to opt out of receiving newsletters. In this case, their name and email address will be automatically removed from the database. To do this, simply click on the corresponding option available in each received email.

7. Processing of Personal Data

7.1. The processing and storage of provided personal data are carried out in data centers housing the equipment that ensures the operation of the Site's services. The provided personal data is processed and may be stored in the Personal Data Database or in a separate table of the Site Database. As the Company's servers are located in different regions worldwide, a specific user's information may be processed not in the country where they reside. The level of information protection and legislative norms in this area may differ in various countries. Regardless of where the processing of user data takes place, the Company employs the same security measures described in this Policy. The Company also adheres to various legislative norms regarding data transfer, including the EU-US Privacy Shield Framework for data transferred between the United States and the European Union, as well as a similar agreement between the United States and Switzerland, known as the Swiss-US Privacy Shield Framework.

7.2. Personal data is processed using automated systems unless non-automated processing of personal data is required in connection with legal requirements.

7.3. The processing of user personal data by the Company includes the following actions: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction.

7.4. The collection of user personal data is carried out in cases specified in section 2.1 of the Policy.

7.5. The storage of personal data is carried out until the earlier of the following events:
  • Until the user deletes them in the "My Profile and Programs" and "Settings" sections of the personal account;
  • Until their destruction by the Company - in case the user submits a withdrawal of consent to the processing of personal data or a request for the destruction of personal data;
  • Until the expiration of the consent period (section 2.2 of the Policy) or the achievement of the goals of processing personal data.

7.6. Clarification of personal data can be performed by the user independently in the "Personal Information," "My Interests" sections of the Personal Account, or by the Company upon the user's request.

7.7. Distribution of personal data by the Company can only occur in the following cases:

7.7.1. When processing personal data with the purpose of displaying the user profile for other Site users to maintain communication, including when providing services remotely. In this case, the user's personal data may be accessible to users registered on the Site in accordance with sections 2.1.4, 2.1.8.

7.7.2. For the purpose of posting reviews about the services provided by the Company, left by users, in various information sources.

7.7.3. For the purpose of posting video materials obtained during the provision of services, in various information sources.

7.8. The Company has the right to transfer personal data to third parties (Company Processors) while adhering to the following conditions:
  • The third party ensures the confidentiality of personal data during their processing and usage, pledging not to disclose or distribute the personal data of users to others without their consent.
  • The third party guarantees the implementation of the following security measures during the processing of personal data: the use of information protection means, detection and recording of instances of unauthorized access to personal data with measures taken to restore the personal data, restriction of access to personal data, registration and record-keeping of actions with personal data, control and evaluation of the effectiveness of applied security measures.

7.9. The destruction of personal data is carried out by the Company in the following cases:
  • Deletion of personal data by the user in the "My Profile and Programs" and "Settings" sections of the personal account.
  • Receipt of a user's withdrawal of consent for the processing of personal data.
  • Receipt of a user's request for the destruction of personal data.
  • Expiration of the consent term (section 2.2 of the Policy).

The Company does not transfer personal data to third parties unless such transfer is required by law, at the request of the data subject, or in other cases outlined in this Policy. The Company acknowledges that personal information is a valuable asset and an integral component, including the personal non-property rights of any individual. Therefore, it takes all possible measures to protect the personal information voluntarily and consciously provided by users to the Company.

7.10. Cross-border Transfer of Personal Data
The Company must ensure that a foreign country, to which the transfer of personal data is intended, provides adequate protection of the rights of data subjects before initiating such transfer.
Cross-border transfer of personal data to territories of foreign countries that do not ensure adequate protection of the rights of data subjects may be carried out in cases such as:
  • Written consent from the data subject for the cross-border transfer of their personal data.
  • Performance of a contract in which the data subject is a party.

8. Protection of Personal Data

The Company implements necessary and sufficient legal, organizational, and technical measures to protect the information provided by users from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other unlawful actions by third parties. However, despite all efforts, the Company cannot guarantee absolute protection against any threats that may arise beyond the Company's regulation.

The Company employs standard methods such as encrypted communication, secured premises, network protection systems, and password protection systems to ensure the confidentiality of personal data. The Company provides access to information and personal data only to authorized employees who have agreed to maintain the confidentiality of such information and data in accordance with the Company's requirements.

The Site may contain links to other websites (solely for informational purposes). When following a link to other websites, the provisions of this Policy will not apply to such sites. Therefore, the Company recommends reviewing the privacy and personal data policies of each site before transmitting personal data that may identify you. Read more here.


9. Rights of Users

The User has the right to:
9.1. Voluntarily provide the Company with personal data for processing, according to the conditions specified in the Policy. Some of the provided personal data are essential for entering into a User Agreement, and failure to provide them makes it impossible to conclude such a User Agreement.

9.2. Independently make changes and corrections to their personal data in the "Personal Information," "My Interests" section of the personal account, provided that such changes and corrections contain current and accurate information.

9.3. Delete personal data by editing the "Personal Information," "My Interests" section in the personal account.

9.4. Request the Company to clarify its personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated processing purposes. Users can also take legal measures to protect their rights.

9.5. Receive a response from the Company within thirty calendar days from the date of the request, except in cases stipulated by law, regarding whether personal data are being processed, and obtain the content of such personal data.

9.6. Present a substantiated request to the owner of personal data objecting to the processing of their personal data.

9.7. Apply legal remedies in case of violation of personal data protection legislation, including filing a complaint with the supervisory authority.

9.8. To update, gain access, make changes, block, or delete their personal data, revoke consent to the processing of personal data provided to the Company in accordance with this Policy, or in case of any comments, wishes, or claims regarding their personal data processed by the Company, please contact the Company via email at info@fibata.eu.

9.9. Direct their requests and demands to the Company, including those related to the use of their personal data, as well as the withdrawal of consent to the processing of personal data. Requests can be submitted in writing to the Company's address (Section 11 of the Policy) or via email (the document must be sent from the User's email address provided during registration on the Site or in the agreement as the authorized email address) at info@fibata.eu. The Company considers User requests, provides responses, and/or takes necessary actions within 30 calendar days from the receipt of the request.

9.10. In addition to the rights listed in this Policy, the User has the opportunity to exercise any right provided by law.

10. Changes to the Policy

10.1. The Company reserves the right to periodically make changes and additions to the Policy, including changes in legislative requirements, without prior notice to the user. It is the User's responsibility to review the Policy each time the Site is used.

10.2. The new version of the Policy comes into effect from the moment it is posted in the relevant section of the Company's website. Continued use of the Site or its services after the publication of a new version of the Policy indicates the User's acceptance of the Policy and its terms. In case of disagreement with the terms of the Policy, the User must immediately cease using the Site and its services.

10.3. We encourage you to periodically review the Policy to stay informed of any changes or additions.

11. Company Information

First Baltic Trading Academy
Name: Vitali Filimonov

Address: Voidu pr. 3 - 60
Narva, Ida-Virumaa
Estonia 21008

Phone: +372.5533059
Email Address: info@fibata.eu