Privacy Policy

PRIVACY NOTICE FOR PROCESSING PERSONAL DATA BY KOOD/JÕHVI

This Privacy Notice describes the purpose and extent of processing your personal data by kood/Zhytomyr (Zhytomyr Polytechnic State University).

GENERAL PROVISIONS
1. kood/Zhytomyr ensures that the processing of personal data is carried out in compliance with the Law of Ukraine “On the Protection of Personal Data” No. 2297-VI and other applicable Ukrainian laws and regulations. The organization also follows best practices for data protection and information security.
2. kood/Zhytomyr respects individuals’ right to privacy and takes all reasonable measures to protect personal data and maintain the security of its information systems.
DEFINITIONS
1. Platform – the online learning platform provided by kood/Zhytomyr and/or its authorized data processors, used by Students.
2. Processing of personal data – any action or set of actions such as collecting, registering, accumulating, storing, adapting, altering, updating, using, distributing, depersonalizing, or destroying personal data.
3. Student – a person enrolled in the educational program of kood/Zhytomyr and using the Platform.
PURPOSE OF THE PROCESSING OF PERSONAL DATA AND ITS LEGAL BASIS
1. kood/Zhytomyr processes personal data for the purposes of enrolling students in educational programs, monitoring their academic progress and achievements, providing educational tasks, resources, and communication tools, facilitating interaction between students, staff, and educators, maintaining necessary academic and administrative records, and collecting gender-related data for statistical purposes to promote diversity and inclusion in the technology sector.
2. The legal basis for processing personal data is primarily the consent of the data subject, in accordance with Article 6 of the Law of Ukraine “On the Protection of Personal Data.” In cases where data processing is necessary to fulfill the terms of education-related agreements, such processing is carried out without additional consent as permitted by Ukrainian law.
3. In certain situations, kood/Zhytomyr may also rely on legitimate interest as a legal basis for processing, provided such interests do not override the fundamental rights and freedoms of the data subjects.
4. kood/Zhutomyr is processing the following personal data:

Processing activity	Data categories	Purpose	Legal basis
Account Management	Full nameEmail address Date of birthEnrollment statusGender	To register students on the platform and create individual user accounts that allow access to courses and content	Contractual obligation (Art. 6(1)(b) of the GDPR) Art. 11 Law of Ukraine “On Protection of Personal Data” – processing necessary for execution of an agreement to which the data subject is a party
Identity Verification	Full namePersonal ID codeResidence permit informationDocument photoNationality	To identify the students’ identity prior to or in the course of enrolment	Contractual obligation (Art. 6(1)(b) of the GDPR)Art. 11 Law of Ukraine – processing for identification purposes based on pre-contractual relations or legal requirements
Personalized Learning Paths	Academic recordsCourse preferencesInteraction data (e.g., pages visited, content viewed)	To tailor the educational experience to each student’s needs and preferences, optimizing their learning outcomes	Contractual obligation (Art. 6(1)(b) of the GDPR)Art. 11 Law of Ukraine – performance of educational services contract
Course Management	Attendance recordsAssignment submissionsGrades and evaluations	To administer courses, track attendance, collect and grade assignments, and record academic achievements	Contractual obligation (Art. 6(1)(b) of the GDPR)Art. 11 Law of Ukraine – execution of agreement and compliance with education standards under Ukrainian law
Communications	Postal addressPhone numberCommunication preferences	To send updates, course notifications, and other relevant communications to students	Contractual obligation (Art. 6(1)(b) of the GDPR)Art. 11 Law of Ukraine – necessary for provision of educational and informational services to the subject
Online Assessments	Test responsesGradesFeedback comments	To administer assignments, tests, and exams, provide grades, and offer feedback on student performance	Contractual obligation (Art. 6(1)(b) of the GDPR)Art. 11 Law of Ukraine – to fulfill obligations under educational programs
Platform Analytics	Usage data (e.g., login frequency)Browser and device informationFeedback and survey responses	To analyze how the platform is used and to identify areas for technical improvement and content enhancement	Legitimate interest (Art. 6(1)(f) of the GDPR)Art. 11, 8 Law of Ukraine – processing for statistical, research and service improvement purposes, provided it does not violate rights of the data subject
Compliance with Legal Requirements	Identification dataAcademic records	To comply with legal obligations related to education law, health and safety regulations, and record-keeping standards	Legal obligation (Art. 6(1)(c) of the GDPR)Art. 11, 7 Law of Ukraine – required by national legislation on education, accounting, and health/safety
Technical Support	User account dataTechnical logsInteraction data (for troubleshooting)	To provide assistance with technical issues or account-related problems	Legitimate interest, to ensure the reliable operation of Legitimate interest (Art. 6(1)(f) of the GDPR)Art. 11 Law of Ukraine – support provision as a component of service fulfillment; legitimate interest to ensure service continuity and reliability
Security Measures	Login dataAccess logsNetwork information	To safeguard the platform from unauthorized access, cyber threats, and to ensure the integrity of student data	Legal obligation (Art. 6(1)(c) of the GDPR)Art. 6, 11 Law of Ukraine – necessary to ensure security and prevent unauthorized access or data breaches in line with data protection regulations of Ukraine

4. HOW KOOD/JÕHVI COLLECTS PERSONAL DATA

kood/Zhytomyr collects personal information on the Platform directly when the Student:
1. registers an account on the Platform, providing information such as name, email address, date of birth, and enrolment details;
2. participates in educational activities, including forum discussions, assignments submission, and assessments, wherein they input personal academic data;
3. customizes their user profile and learning experience by entering preferences, learning styles, and feedback;
4. engages with communication tools on the platform, for instance, when sending messages or emails, contributing to discussions, or requesting support;
kood/Zhytomyr collects personal information indirectly on the Platform when:
1. the administrative system of kood/Zhyromyr integrates with the platform, transferring necessary student information such as accounts, enrolment status, and academic history;
2. kood/Zhytomyr inputs grades, evaluations, and feedback into the system related to student performance and participation;
3. kood/Zhytomyr collects data via cookies and similar technologies to facilitate platform functionality, including but not limited to login data, IP addresses, browser types, and access times;
4. the Platform automatically generates records of student interactions, such as time spent on learning materials, progress tracking, and resource access patterns;

kood/Zhyromyr provides aggregated data for the purpose of educational research or analytics that may contain information derived from student performance and usage metrics.

5. TRANSMISSION OF THE PERSONAL DATA

kood/Zhytomyr processes personal data within Ukraine or within countries that are recognized by Ukrainian law as providing an adequate level of personal data protection. All data is received, transmitted, and processed digitally, in accordance with applicable Ukrainian data protection legislation.

6. DISCLOSURE OF PERSONAL DATA

kood/Zhytomyr engages third-party service providers to provide, operate, and maintain the Platform on its behalf. These service providers have access to personal data only to the extent necessary to perform their services and are contractually obligated to ensure the confidentiality and security of the information in accordance with Ukrainian data protection laws. Personal data may be disclosed if required by law or in good faith belief that such action is necessary to comply with legal obligations under Ukrainian legislation, including obligations related to anti-money laundering or tax information exchange. Infrastructure service providers are required to implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, or disclosure.

Data Processor	Processing activity	Territory
FutureCoders OÜ	Providing, running, and maintaining the Platform	Estonia
Veriff OÜ	Identity verification	EEA

7. RETENTION AND DELETION OF PERSONAL DATA

The storage period of personal data depends on the legal obligations to store data (i.e. accounting regulations), contractual obligations, and legitimate interest or consent to provide the best services:

Data type	Purpose	Retention time
User Account Information	To manage student accounts on the platform and provide access to services	Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement, except for information necessary for accounting purposes, which shall be retained for 7 years after expiry of the student agreement
Verification Data	To identify the students’ identity prior to or in the course of enrolment	Retained for as long as the processor conducting identity verification retains the data. For further information, refer to the privacy policy of the processor
Academic Records	To document the educational history and achievements of students	Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement
Coursework and Assignments	To evaluate student performance and provide a record of work completed	Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement
Examination Data	To maintain a record of assessments for accreditation and educational continuity	Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement
Communication Logs	To provide a record of communications for accountability and to facilitate educational services	Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement
Personalized Learning Data	To support individualized learning experiences and improvements to educational offerings	Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement
Technical Logs and Usage Data	To ensure the integrity, security, and improvement of the platform	Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement, then securely deleted or anonymized
Feedback and Survey Responses	To enhance the educational services and platform features	Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement, then anonymized for further analysis if needed

8. RIGHTS OF THE STUDENT (DATA SUBJECT)

The Student (data subject) shall have the right at any time to request:
access to personal data (accessed via the Platform);
correction of inaccurate personal data;
require the deletion of personal data;
restriction of processing of personal data;
withdrawal of data-processing consent (if applicable).
In order to exercise these rights, the Student must submit a declaration to info-ua@kood.tech. The application shall be responded to within a maximum of 30 calendar days.
The Student has the right to lodge a complaint against the processing of personal data with the supervisory authority, which is the Estonian Data Protection Inspectorate.

9. CHANGES AND VALIDITY

kood/Zhytomyr reserves the right to amend the conditions for personal data processing in accordance with applicable Ukrainian data protection laws. In the event of substantial changes, kood/Zhytomyr will notify users at least 1 (one) month in advance through the Platform before such changes take effect. Continued use of the Platform after the changes take effect will constitute acceptance of the updated terms. The current conditions for processing personal data are valid from 01.01.2024.