Privacy Policy for Teamco

We are really serious about the security of personal data of our customers, potential customers and other persons who contact us, so we strive to protect the confidentiality of your personal data. The Administration is committed to taking all necessary measures to prevent misuse of your personal data that becomes known to us. We will process your personal data in strict compliance with the requirements of the applicable legislation and only if there are legal grounds for such processing. You are not required to provide us with personal data, but without certain information about you, we may not be able to provide you with some of our services. Where we control the way we collect your personal data and determine the purposes for which that personal data is used, the Administration is the "controller of personal data" for the purposes of the GDPR and other applicable European data protection legislation, and the "owner of personal data" within the meaning of the Act.

1. Terms and definitions:

Personal data - information or a set of information about an individual who is identified or can be specifically identified (User);

Special categories of personal data are so-called "sensitive" personal data that could harm the data subject at work, at an educational institution, in his or her living environment, or could lead to him or her being discriminated against in society. For example, this is personal data that contains information about racial origin, political or religious views, trade union membership, health status, sexual life, biometric or genetic data. In the terminology of the Ukrainian legislation, this is personal data, processing of which carries a special risk for the subjects of personal data;

The subject of personal data is a natural person to whom personal data refers and who can be identified by that personal data, or who has already been identified;

Site Administration (Administration, as well as hereinafter we, us, we, us) - TEAMCO

Processing of personal data - any action or set of actions, such as the collection, registration, accumulation, storage, adaptation, modification, recovery, use and distribution (distribution, realization, transfer), depersonalization, destruction of personal data, including the use of information (automated) systems;

Dissemination of personal data - actions to transfer information about an individual with the consent of the subject of personal data;

The use of personal data - any action of the Administration for the processing of these data, actions to protect them, as well as actions to provide partial or full right to process personal data to other subjects of the relationship related to personal data, performed with the consent of subjects of personal data or in accordance with the laws of Ukraine;

De-identification of personal data - removal of information that directly or indirectly identifies an individual;

User- the subject of personal data, any legally capable individual who has joined this Policy in his own interest to improve his qualifications or skills as a financial expert, who has registered in the online service https://teamco.in using the Internet;

The online service, a service owned by the Administration and located at https://finacademy.net, is designed to enhance the qualifications and professional skills of financial professionals;

Personal profile is a section of the online service, which the User can access after registering in the online service https://teamco.in and entering a unique login and password. Personal profile contains personal data of the User and is designed to view and manage the available functionalities of the online service;

Registration- the User's actions to fill out and send the registration form posted in the online service, which, if the Administration has no objections to the registration, has the effect of providing access to myAlpari;

Authorization- User's login and password for logging into the Personal Area of the online service;

Policy- This Privacy Policy located at https://teamco.in;

The controller of personal datais a natural or legal person who determines the purposes and means for processing of personal data and is primarily responsible for its processing. The Personal Data Controller is the "owner of personal data" in the terminology of Ukrainian law. For the purposes of this Policy, the Controller of Personal Data is the TEAMCO;

A personal data processoris a natural person or legal entity that processes personal data for the controller on the basis of instructions (instructions, orders). A personal data processor is a "personal data processor" in the terminology of Ukrainian law;

2. General provisions

2.1 This Policy applies to all of your personal data that may be collected by Us in the course of your use of the online service. This Policy applies to personal data received both before and after the enactment of this Policy.

2.2 The purpose of this Policy is to provide you with the necessary information to assess which personal data we process and for what purpose, the methods of processing it and its security.

2.3 When using the online service, by providing the Administration with your personal data, including through third parties, you acknowledge your consent to the processing of your personal data in accordance with this Policy.

2.4 If you do not agree with the terms of this Policy, you are obliged to stop using the online service.

2.5 Consent to the processing of personal data may be withdrawn by the subject of personal data. In case of revocation of the personal data subject's consent to processing of personal data, the Administration shall be entitled to continue processing of personal data without consent of the personal data subject, if there are grounds specified in the legislation.

2.6 The Administration of the site does not verify the reliability of personal data provided by the User and has no opportunity to assess its competence. However, the Administration assumes that the User acts in good faith, is prudent, provides reliable and sufficient personal data and makes all necessary efforts to keep such data up to date, and does not violate the rights of third parties.

2.7 By agreeing to the terms of this Policy, you confirm that at the time of collection of personal data you are notified about the persons to whom personal data are transferred, the content and purpose of personal data collection. You confirm (warrant) that the personal data, which are transferred to us for processing, are transferred with the consent of the owners of personal data and within the limits of the Law.

2.8 The Administration, having received personal data from the User, does not assume the obligation to inform the subjects (their representatives), whose personal data are transferred to it, on the beginning of processing of personal data, as the obligation to carry out the relevant notification, at the conclusion of the contract with the subject of personal data and / or consent to such transfer, is the User, who transferred the personal data.

2.9 The processing of your personal data shall be in accordance with the requirements of the Law. The processing of personal data of persons in the EU or who are EU citizens is governed in particular by the EU General Data Protection Regulation 2016/679 (hereinafter "GDPR"). Also the legislation of other countries may impose additional requirements.

2.10. This Policy applies to all information that the Administration can receive about the User when they use the online service, as well as in the course of the Administration of any agreements and contracts with the User.

2.11. This Policy is an internal document of the Administration.

2.12. The personal data controller shall be released from liability for the consequences arising in connection with his/her processing of personal data, if he/she is not responsible for the event that caused such consequences.

You also agree that the Owner of Personal Data has the right to access and transfer your personal data to third parties without any additional communication, solely if this does not change the purpose of its processing and only in cases stipulated by this Privacy Policy and/or the legislation of Ukraine.

No one under the age of 18 should provide personal information to us through the Online Service. We do not knowingly collect personal information from anyone under the age of 18. Parents and guardians should monitor their children's related activities at all times.

3. Composition of personal data

3.1. Administration, in order to carry out its activities and to fulfill its obligations, processes personal data of the User, provided by him when registering on the site https://teamco.in and stored in a personal account.

3.2 The personal data of the User include: surname, first name, patronymic, e-mail address, mobile / landline phone number, country of residence, place of work, position, date of birth.

We ask you to provide only the personal data that is necessary to provide the service you have chosen, to receive a newsletter or to respond to your special request/claim. At the same time, if you choose to provide us with additional personal data, we can also process it with the necessary level of protection.

3.3 The Administration has the right to establish requirements to the composition of personal data, which must be provided when using online service. If certain information is not marked by the Administration as mandatory, its provision or disclosure is at the discretion of the User.

3.4 Data that is automatically transmitted to the Administration when the User uses the online service with the software installed on the device: IP-address, browser information and type of operating system of the device, hardware and software specifications, date and time of access to the online service.

4. Basis and purpose of personal data processing

4.1 The grounds for processing personal data are:

1) the consent of the subject of personal data to the processing of his personal data by the Administration;

2) the conclusion and performance of the contract, one party of which is a personal data subject or which is concluded in favor of the subject of personal data, or to carry out activities preceding the conclusion of the contract at the request of the subject of personal data;

3) the need for the Administration to comply with the requirements of the legislation.

4.2 The purpose of processing personal data is:

• Performance of the functions assigned to the Administration in accordance with the laws of Ukraine and the GDPR;
• The collection, storage and processing of personal data obtained in an online service under the Act and the GDPR;
• To send the User commercial (marketing) notifications containing additional information about services, current promotions and special offers related to the services provided by the Administration through the online service.
• Identification of the subject of personal data when using the online service;
• Communication with the subject of personal data, if necessary, including the sending of proposals, information materials, messages, information and inquiries, advertising, as well as processing requests of the subject of personal data;
• Improving the quality of the online service, convenience of its use, development of new functionalities and improvement of the quality of service;
• Improving the professional skills and qualifications of the User;
• Conducting statistical and other studies based on anonymized data;
• Performance by the Administration of contractual and other obligations to the User on the transactions concluded between the

Administration and the User or third parties in the interests of the User.

5. Basic principles of personal data processing

5.1 Processing of personal data by the Administration is based on the principles of:

5.1.1 Legality of the purposes and methods of personal data processing;

5.1.2 The integrity of the Administration, as the owner of personal data, is achieved by complying with the requirements of Ukrainian legislation regarding the processing of personal data;

5.1.3 To achieve specific, predetermined objectives for processing personal data;

5.1.4 Compliance of the purposes of personal data processing with the purposes predetermined and stated when collecting personal data;

5.1.5 Compliance of the list and volume of processed personal data, as well as the methods of processing personal data with the stated processing purposes;

5.1.6 Reliability of personal data, their sufficiency for the purposes of processing, inadmissibility of processing of personal data redundant in relation to the purposes of personal data processing;

5.1.7 Ensuring during the processing of personal data the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purpose of personal data processing.

5.1.8 Inadmissibility of combining databases containing personal data whose processing is carried out for purposes incompatible with each other;

5.1.9 Retention of personal data in a form that allows to identify the subject of personal data, no longer than required by the purposes of its processing.

5.1.10. Processed personal data is subject to destruction or depersonalization upon attainment of the processing purposes or when it is no longer necessary to attain these purposes, unless otherwise provided by the legislation of Ukraine and the GDPR.

5.1.11. We must also consider the periods for which we may need to retain your personal information to comply with our legal obligations to you or regulatory authorities.

5.1.12. We may, over time, minimize your personal data that we use or may even make your data anonymous so that it can no longer be linked to you personally. In that case, we will be able to use this information for statistical or other purposes without further notice to you, because such information ceases to be personal data.

5.2 Processing of personal data is carried out by the Administration for statistical or other research purposes, subject to mandatory depersonalization of personal data.

5.3 The Administration does not process personal data concerning racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, criminal convictions, as well as data concerning health, sex life, biometric and genetic data.

5.4 Processing of personal data shall be carried out in compliance with the conditions defined by the legislation of Ukraine and the GDPR.

6. Terms of personal data processing

6.1. The terms of processing of personal data shall be determined based on the purposes of processing, but not longer than it is defined by the Law.

6.2 Personal data, the period of processing (storage) of which has expired, shall be destroyed or depersonalized, unless otherwise provided by the Law. Personal data shall be stored in a form that allows identification of the subject of personal data, no longer than required by the purposes of personal data processing, unless the period of storage of personal data is specified by the Law. Processed personal data shall be destroyed or depersonalized upon attainment of the purposes of processing or when it is no longer necessary to attain those purposes, unless otherwise provided by the Act. We must also consider the periods for which we may need to retain your personal data in order to comply with our legal obligations to you or the supervisory authorities (in accordance with EC Regulation 261/2004).

6.3 We may, over time, minimize your personal data that we use or may even make your data anonymous so that it can no longer be linked to you personally. In this case, we will be able to use this information without informing you further.

7. The range of persons allowed to process personal data by the Administration

7.1 To achieve the objectives of this Policy, only those employees of the Administration, who are entrusted with such a duty in accordance with their official (employment) duties, are allowed to process personal data. Access of other employees may be granted only in cases provided by law. The Administration guarantees from its employees to observe confidentiality and security of personal data during their processing.

7.2 The Administration has the right to transfer personal data to third parties in the following cases:

- the subject of personal data has expressed his or her consent in writing for such actions;

- transfer is stipulated by the Ukrainian or other relevant legislation in the framework of the procedure established by law. At the same time, access to personal data shall not be granted to a third party, if the said person refuses to undertake obligations to ensure compliance with the requirements of the Law or is unable to ensure them.

7.3 The Administration has the right to entrust the processing of personal data to a third party with the consent of the subject of personal data, unless otherwise provided by the legislation of Ukraine, on the basis of a contract concluded with the third party, the condition of which is confidentiality and non-disclosure of personal data.

7.4 Representatives of public authorities (including controlling, supervising, law enforcement and other bodies) shall have access to personal data processed by the Administration to the extent and in the manner prescribed by law.

8. Implementation of personal data protection

8.1 The processing of personal data in information systems by the Administration is inextricably linked to the protection by the Administration of confidentiality of information received, if it is not contrary to applicable law.

8.2 Personal data protection system includes organizational and (or) technical measures, determined taking into account current threats to security of personal data and information technologies used in information systems. The administration shall update these measures with the emergence of new technologies, if necessary.

8.3 The exchange of personal data during their processing in information systems shall be carried out via communication channels protected by technical means of information protection.

8.4 When processing personal data in information systems, the Administration shall ensure:

• carrying out activities aimed at preventing unauthorized access to personal data and (or) their transfer to persons not entitled to access such information;
• timely detection of unauthorized access to personal data;
• avoiding the impact on the technical means of automated processing of personal data, as a result of which their functioning may be disrupted;
• The possibility of immediate recovery of personal data modified and destroyed due to unauthorized access to it;
• Constant monitoring of the level of security of personal data.

8.5 Personal information is kept confidential, except when the technology of the online service or the settings of the software used by the User provide for an open exchange of information with other Users of the online service or with any users of the Internet.

8.6 The Administration implements the following requirements of the legislation of Ukraine in the field of personal data:

• Personal data confidentiality requirements;
• requirements to ensure that the subject of personal data realizes his or her rights;
• requirements to ensure the accuracy of personal data and, where necessary, the relevance in relation to the purposes of personal data processing (with the adoption (ensuring adoption) of measures to remove or clarify incomplete or inaccurate data);
• requirements for the protection of personal data from unauthorized or accidental access, destruction, distortion, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
• other requirements of the Act.

8.7 In accordance with the Law, the Administration shall independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations under the law in the field of personal data from unauthorized or illegal processing and from unintentional loss, destruction or damage.

The administration adheres to the principle of minimizing personal data. We only process information about you that we need, or that you agree to provide beyond the limits of the necessary processing. Furthermore, we have customized all interfaces of our Online Service and service applications to respect the greatest possible degree of privacy, which can be adjusted to your personal preferences. When transmitting personal data to government authorities, we always use the safest and most proven ways of transmitting such data.

8.8. Cookies and other tracking technologies.

Cookies are small text files that store sites on your computer or mobile devices the moment you start using them. In this way, the site will temporarily remember your benefits and the actions you have taken, including so that you don't have to re-enter this data. Our cookies themselves do not identify the individual user, but only the computer or mobile device you are using.

Cookies and other tracking technologies in our online service may be used in various ways, such as for the purpose of operating an online service, analyzing traffic or for advertising purposes. We use cookies and other tracking technologies in particular to improve the quality and effectiveness of our services.

For more information on what cookies are, how they work, how to manage them, or how to delete them, go to www.allaboutcookies.org.

We inform you that you can set some Internet browsers to disable cookies and other tracking technologies. However, you should be aware that if you disable some cookies, the functionality of the online service may be limited and you may not be able to take full advantage of it, and some pages may not work correctly.

9. Rights of the subject of personal data

9.1 The rights of subjects of personal data in accordance with the legislation of Ukraine:

9.1.1 Know the sources of collection, the location of their personal data, the purpose of their processing, the location of the disposer of personal data or give appropriate instructions to obtain this information to authorized persons, except as required by law.

9.1.2 Receive information about the terms of access to personal data, including information about third parties to which his personal data is transferred.

9.1.3. to access their personal data.

9.1.4 To receive no later than thirty calendar days from the date of receipt of the request, except in cases provided by law, the answer as to whether his personal data is processed, and what kind of personal data.

9.1.5. Submit a motivated request to the Administration to object to the processing of his personal data.

9.1.6 Submit a reasoned request to change or destroy their personal data, if the data is processed illegally or is unreliable.

9.1.7. to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as protection from the provision of information that is inaccurate or defame the honor, dignity and business reputation of an individual.

9.1.8 To appeal with complaints about the processing of their personal data to the Administration to the Ombudsman of the Verkhovna Rada of Ukraine or to the court.

9.1.9 Apply legal remedies in case of breach of legislation on personal data protection.

9.1.10. Make reservations about restricting the right to process their personal data when giving consent.

9.1.11. Withdraw consent to the processing of personal data.

9.1.12. Get acquainted with the mechanism of automatic processing of personal data.

9.1.13. To be protected from an automated decision that has legal consequences for him/her.

9.1.14. The Administration has the right to entrust the processing of personal data to a third party with the consent of the subject of personal data, unless otherwise provided by the laws of Ukraine, on the basis of a contract concluded with the third party, the condition of which is confidentiality and non-disclosure of personal data.

9.1.15. Representatives of public authorities (including regulatory, supervisory, law enforcement and other authorities) have access to personal data processed by the Administration in the amount and manner prescribed by the legislation of Ukraine.

9.2 Other rights of personal data subjects under the GDPR:

In addition to the Ukrainian legislation on the protection of personal data, the Administration is careful to ensure your rights under the GDPR.

9.2.1 The Right to Information.

We are willing to provide data subjects with information about which of their personal data we process.

If you would like to know what personal data we process, you can make a request for this information at any time, including by contacting the Administration. You can find a list of the data that we must provide to you in Articles 13 and 14 of the GDPR. When you do so, you must inform us of your specific requirements so that we can lawfully consider your request and respond.

Please note that in the event that we are unable to verify your identity by email or telephone, or in case of reasonable doubt about your identity, we may ask you to provide proof of identity, including by personal appearance at the location of the Administration. Only in this way can we avoid disclosure of your personal data to a person who may impersonate you.

We will process requests as quickly as possible, but at the same time, please remember that providing a complete and legitimate response regarding personal data is a complex process that can take up to a month.

9.2.2 The right to correct the data in You.

If you find that some of the personal information we process about you is incorrect or out of date, please let us know. In this case, we may ask you to PRESENT an identification document, including by personal appearance at the location of the Administration.

If you want to correct the personal data that we process, you can make the correction yourself by logging into your personal account in the online service or by contacting the Administration.

In some cases, we will NOT be able to change your personal data. In particular, this may be the case when your personal data has already been used in the execution of a contract and/or it is contained in a tax document that has been drawn up in accordance with the Tax Law.

9.2.3 Withdrawal of consent to personal data processing and the right to be forgotten

If the Administration processes your personal data on the basis of consent to the processing of personal data (in particular, for the purpose of marketing/advertising mailings), further processing can be stopped at any time. It is sufficient to withdraw your consent to such processing.

You may also exercise your right to be forgotten. In the cases provided for in Article 17 of the GDPR, the Administration will destroy your personal data that it processes, with the exception of personal data that we will be required to retain by law.

Also in this case, for security reasons, the Administration may ask you to provide proof of identity, including directly to the location of the Administration.

10. Place of storage of personal data

The administration has a large database of personal data. To ensure their security, we use the cloud services of DigitalOcean, LLC. The data are located in data centers in Frankfurt am Main, Germany.

11. Changing the privacy policy

11.1 This Policy may be unilaterally changed or terminated by the Administration without prior notice to Users, including if it is required by applicable law. A new edition of the Policy comes into effect from the moment of its posting on the online service, unless otherwise provided by the new edition of the Policy. Therefore, we ask that you visit the online service https://teamco.in to ensure that you have up-to-date information.

12. Who you can contact to protect your personal data

12.1 If you have any questions, comments, complaints or requests regarding the protection and processing of personal data, you can contact E-mail: bv@teamco.in

Be sure to include your name, email address, and detailed questions, comments, complaints or demands in all correspondence.

12.2 The administrative authority for protection of personal data in Ukraine is the Department on protection of personal data of the Secretariat of the Parliamentary Commissioner for Human Rights of Ukraine. You can apply to it with complaints or suggestions, if you think that your rights are violated in connection with the processing of personal data.