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U&A Intelligence Academy · Legal

PRIVACY POLICY

for the website and OSINT training courses

Contents
1. TERMS AND SCOPE 2. DATA CONTROLLER 3. PERSONAL DATA WE MAY PROCESS 4. SOURCES OF DATA 5. PURPOSES AND LEGAL BASES 6. SPECIAL CATEGORIES AND THIRD-PARTY DATA 7. MINORS 8. RECORDINGS, PHOTOS, VIDEO AND TESTIMONIALS 9. RECIPIENTS OF PERSONAL DATA 10. COOKIES AND SIMILAR TECHNOLOGIES 11. RETENTION 12. DATA-SUBJECT RIGHTS 13. REQUEST PROCEDURE 14. DATA SECURITY 15. SECURITY INCIDENTS 16. AUTOMATED DECISIONS AND PROFILING 17. THIRD-PARTY RESOURCES 18. CHANGES TO THIS POLICY 19. CONTACTS

Reference English translation. The Ukrainian version is the official legal text and prevails in the event of any discrepancy.

This Privacy Policy explains how Uglava & Azones Intelligence LLC, company code / tax number 46023605, with registered and actual address at 44 Antonovycha Street, Kyiv, 03150, Ukraine, collects, uses, transfers, stores and protects personal data relating to website visitors, customers, course participants, prospective clients and other persons interacting with us.

The Policy forms an informational part of the Public Offer Agreement for information, consulting and training services in OSINT and is applied in accordance with the laws of Ukraine.

1. TERMS AND SCOPE

Personal data means information relating to an identified or identifiable individual. Processing covers any operation performed on personal data, including collection, recording, organisation, storage, alteration, use, transfer, anonymisation and deletion. This Policy applies to data obtained through the website, learning platform, email, messengers, registration forms, online and offline events, telephone communications, payment services and other interaction channels.

2. DATA CONTROLLER

The controller is Uglava & Azones Intelligence LLC, company code / tax number 46023605. Registered address: 44 Antonovycha Street, Kyiv, 03150, Ukraine. Actual address: 44 Antonovycha Street, Kyiv, 03150, Ukraine. Privacy requests may be sent to [email protected] or made by telephone at +380 (98) 600 07 07. Corporate customers that provide participant data are responsible for having a lawful basis and informing those participants.

3. PERSONAL DATA WE MAY PROCESS

We may process identification and contact data, order and contract data, payment and accounting information, professional and organisational details, learning progress and assignment data, materials submitted by users, audiovisual information from recorded sessions, communications, technical logs, cookies and similar identifiers. Full payment-card numbers, CVV/CVC and PIN data should remain with the certified payment provider.

4. SOURCES OF DATA

Data is obtained directly from users during registration, payment, learning and support interactions; from corporate customers, payment providers and authorised platforms; automatically from technical systems; and, where lawful and necessary, from public registers, open sources or authorised third parties for fraud prevention, payment verification and protection of rights.

5. PURPOSES AND LEGAL BASES

Processing supports conclusion and performance of contracts, access to courses, teaching, assessment, certification, support, refunds, accounting and legal compliance. Additional bases may include legitimate interests in security, fraud prevention, quality control and protection of rights, as well as consent for marketing, optional cookies, testimonials and public use of a participant’s name, image or voice.

6. SPECIAL CATEGORIES AND THIRD-PARTY DATA

The Academy does not intentionally collect sensitive categories of data unless this is expressly lawful and necessary. Users should avoid submitting excessive, sensitive or unlawfully obtained information about third parties and should anonymise practical materials where identification is unnecessary. A person providing another individual’s data confirms a lawful basis for doing so.

7. MINORS

Services are generally intended for persons aged 18 and over. Participation by a minor is permitted only under the conditions set out in the Public Offer Agreement and with the involvement or consent of a legal representative where required.

8. RECORDINGS, PHOTOS, VIDEO AND TESTIMONIALS

Online sessions may be recorded for participant access, quality control and dispute resolution when participants are informed before recording begins. Public use of a participant’s name, image, voice, testimonial, learning results or story requires separate consent or another valid legal basis. Consent may be withdrawn for future use.

9. RECIPIENTS OF PERSONAL DATA

Data may be shared, to the extent necessary, with teachers, mentors, administrators, contractors, the WayForPay payment provider, banks, accounting and fiscal services, hosting and cloud providers, CRM and learning platforms, communications services, professional advisers, public authorities and lawful successors to the business. Personal data is not sold or provided for independent direct marketing without a separate legal basis.

10. COOKIES AND SIMILAR TECHNOLOGIES

The website may use necessary, functional, analytical and marketing cookies or similar technologies. Users can manage optional categories through cookie settings or browser controls. Blocking necessary cookies may affect website functionality.

11. RETENTION

Personal data is retained only for as long as required for the stated purposes, performance of contracts, legal compliance and protection of rights. Data is then deleted, destroyed or anonymised unless another lawful retention basis applies. Deleted data may remain in protected backups until scheduled overwrite.

12. DATA-SUBJECT RIGHTS

Subject to Ukrainian law, users may request information about processing, access their data, correct inaccurate information, request deletion where applicable, object to processing, withdraw consent, learn about automated processing and seek protection from decisions producing significant legal effects. Users may also complain to the Ukrainian Parliament Commissioner for Human Rights or a court.

13. REQUEST PROCEDURE

Requests may be sent to [email protected] with the subject line “Personal Data”. The request should describe the requirement and provide enough information to identify the applicant and locate the relevant data. Additional verification may be requested to prevent disclosure to an unauthorised person.

14. DATA SECURITY

Organisational and technical measures may include access controls, multi-factor authentication, encryption in transit, backups, logging, software updates, staff training, confidentiality obligations, contractor review and incident-response procedures. Access is limited to persons who need the data for their duties.

15. SECURITY INCIDENTS

Suspected loss, unauthorised access or other security incidents are documented, contained, investigated and remediated. Individuals and competent authorities are notified where and as required by applicable law. Security concerns should be reported to [email protected].

16. AUTOMATED DECISIONS AND PROFILING

The Academy does not ordinarily make solely automated decisions that produce significant legal effects. Automated rules may be used for access after payment, spam filtering, suspicious-activity detection, mailing segmentation or content recommendations. Human review may be requested where an automated process has a material effect.

17. THIRD-PARTY RESOURCES

The website and learning materials may link to public registers, search engines, social networks, OSINT tools and other external resources. Those services process data under their own terms and privacy policies. Users are responsible for assessing the legality and security of sending data to third-party services.

18. CHANGES TO THIS POLICY

The Policy may be updated to reflect changes in law, services, technology or providers. A new version applies from publication unless stated otherwise. Material changes may be communicated through the website, email or the user account, and new consent will be sought where required.

19. CONTACTS

Uglava & Azones Intelligence LLC; company code / tax number 46023605; registered address: 44 Antonovycha Street, Kyiv, 03150, Ukraine; actual address: 44 Antonovycha Street, Kyiv, 03150, Ukraine; [email protected]; +380 (98) 600 07 07; Academy website: https://academy.uglavaazones.com/; publication date of this version: 13 August 2026.

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