Projector privacy policy

This Policy comes into force on November 29, 2021.
Changes: December 28, 2022.
Recent Changes: September 23, 2024.

I. Key information

PROJECTOR respects your privacy and commits to protecting it by following this Privacy Policy (hereinafter - the "Policy").

The purpose of this Policy is to describe how PROJECTOR, our subsidiaries, and our international branches, ("PROJECTOR," "us," "we," or "our") collect, use, and share information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to https://prjctr.com/ (collectively referred to herein as the "Site"), and what rights you have concerning this information.

Please note that we review our privacy practices from time to time and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. Be sure to return to this page periodically to ensure familiarity with the most current version of this Policy.

By continuing to use the Site after the publication of changes, you agree with the new version of the Policy. To find out when we last updated this Policy, please refer to the date listed after "Recent Changes" at the top of this Policy. If you do not agree with the changes, you should immediately stop using the Site.

If you do not understand any aspects of this Policy and (or) have any claims or questions, please feel free to contact us at hello@prjctr.com.ua.

If you do not allow the usage of your personal data to contact you in the future for any purpose, please inform us at hello@prjctr.com.ua and we will take into account your wishes.

If you reside or are located in the European Economic Area ("EEA") PROJECTOR is the data controller of all Personally Identifiable Information (as defined below) collected via the Site and of certain Personally Identifiable Information collected from third parties, as set out in this Policy.

Please read our Terms of Services carefully before using our Site or services. By joining to Terms of Services you give to PROJECTOR the right to collect, process, and store your personal data following this Policy, and to send you some messages or send us certain information.

If you do not agree with any provision of this Policy, please do not use any of the Site’s services.

This Policy applies to websites, courses, certificate programs, order processing and other services operated by PROJECTOR. For simplicity, we refer to all of these as our “services” in this Privacy Policy. This Privacy Policy also applies to the processing of your personal information by third parties with whom PROJECTOR shares your personal information. This Policy does not apply to the practices of any third-party websites, applications, or services that PROJECTOR does not own or maintain (collectively, “Third Party Services”). As further detailed below, we cannot take responsibility for the content or privacy policies of any Third-Party Services.

II. What information Projector collects from you

Information you provide us with

You choose to provide us with certain information when using our services. This includes:

When you create an account or register for a course, you provide us with at least your login credentials, as well as some other basic details necessary for the service to work, such as your name, phone number, and email address.
When you subscribe to a paid service or make a purchase directly from us, you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions, and testimonials.
When you choose to participate in our promotions, events, or contests, we collect the information that you use to register or enter.
If you contact us through the Site, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with or otherwise process information about other people, we collect the information about others that you give us in order to complete your request.

Information we receive from others

In addition to the information, you provide us directly, we receive information about you from others, including:

Other Users. Other users may provide information about you as they use our services. For instance, we may collect information from faculty members about students enrolled in our courses.
Other Service Providers. We may receive information about you from third parties that provide us with services related to our business. For example, our partners may provide us with certain metrics related to your use of our services, including details regarding your engagement with our courses, time you spend on different areas of our website, customer support interactions, or details about the success of PROJECTOR advertising campaign.

Information collected when you use our services

When you use our services, we collect information about which features you use, how you use them, and the devices you use to access our services. See below for more details:

Usage Information. We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you use, searches, clicks, and pages which have been shown to you, referring webpage address, advertising that you click on, time spent live chatting).
Device information. We collect information from and about the device(s) you use to access our services, including:
- hardware and software information such as IP address, device ID and type, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’s settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); and
- information on your wireless and mobile network connection, like your service provider and signal strength.

III. Cookies and Other Similar Data Collection Technologies

We also use (or may use) cookies or similar tracking technologies when you visit our Site. Cookies usually do not contain any personally identifiable information. However, the personal information we hold about you may be related to information stored and received from cookies.

For more information on the use of cookies, please refer to the Projector Cookie Policy.

IV. How We Use Information

We use your information (whether collected directly from you or our other users or service providers) in the following ways:

To administer your account and provide our services to you

Create and manage your account
Provide you with customer support and respond to your requests
Complete your transactions
Process refunds
Communicate with you about our services, including order management and billing

To ensure a consistent experience across your devices

Link the various devices you use to enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices, or by using partial or full IP addresses, browser versions, and similar data about your devices to help identify and link them.

To provide new PROJECTOR and our partners’ services to you

Register you for new PROJECTOR features
Administer your account on these new features
Provide you with information about our or related partner’s services (Lezo, Projector Publishing, Projector Store, and others).

To serve you with relevant offers and ads

Administer sweepstakes, contests, discounts, or other offers
Develop, display, and track content and advertising tailored to your interests on our services and other sites
Communicate with you by email, phone, social media, or mobile device about products or services that we think may interest you

To improve our services and develop new ones

Administer focus groups and surveys
Conduct research and analysis of users’ behavior to improve our services and content
Develop new features and services

To prevent, detect, and fight fraud or other illegal or unauthorized activities

Address ongoing or alleged misbehavior on and off-platform
Perform data analysis to better understand and design countermeasures against these activities
Retain data related to fraudulent activities to prevent recurrences

To ensure legal compliance

Comply with legal requirements
Assist law enforcement
Enforce or exercise our rights

To process your information as described above, we rely on the following legal bases:

Provide our service to you (contract basis): Most of the time, the reason we process your information is to perform the contract that you have with us.
Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, to suggest offers we think might interest you, and to process information for administrative, fraud detection, and other legal purposes.
Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at hello@prjctr.com.ua.

V. How We Share Information

With other users

You share information with other users when you voluntarily disclose information on the Website (for example, in a product review or testimonial) or different chats. Please be careful with your information and make sure that the content you share may be publicly viewable and that you are ok with this.

Please note that if you disseminate the full message in public or PROJECTOR chats, you give us your consent to publish such message (dissemination on online platforms) in such a way that the text and your name (nick) are visible.

With our service providers and partners

We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, and security operations.
We share your information with other service providers for them to assist us in processing your information, as service providers, upon our instructions, and on our behalf. Assistance provided by other companies may include technical processing operations, such as data hosting and maintenance, customer care, marketing, and targeted advertising, finance, and accounting assistance, a better understanding of how our service is used and users’ behavior to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement, and other wrongdoings.
We may also share information with other companies for legitimate business purposes such as corporate audit, analysis, and consolidated reporting as well as compliance with applicable laws.
We may share information with our partners (Lezo, Projector Publishing, Projector Store, and others) to offer you the services that we believe are in your best interests.
We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.

For corporate transactions

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.

When required by law

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation, or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

To enforce legal rights

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and the legal rights of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other third parties (notably advertisers) to develop and deliver targeted advertising on our services and websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.

At the same time, disclosure of information takes place only if the recipient undertakes to protect and preserve it from unauthorized distribution under the requirements of laws and high business standards.

VI. Cross-Border Data Transfers

Sharing of your personal information sometimes involves cross-border data transfers outside of the country of your or our residence. If your personal information is transferred to another jurisdiction, then it may be accessible to the law enforcement and national security authorities of that jurisdiction.

VII. Your Rights

You can ask PROJECTOR for any personal information we have about you and receive a copy free of charge (unless the law allows us to charge a fee). PROJECTOR reserves the right to refuse to provide information at your request, within the applicable law.

You have the right to instruct us not to process your personal information for marketing purposes, by marking the appropriate form of consent. In the absence of your special waiver, it is considered that you agree that your personal information may be used for marketing purposes (if you agreed to that earlier).

You can access your personal information and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us, and request that we delete or provide you with a copy of your personal data by logging into the Site and visiting your user account page.

If you would like further information about your rights or would like to exercise any of them, you may also contact us via hello@prjctr.com.ua.

If you reside or are located in the EEA, you have the right to request that we:

provide access to any personal information we hold about you;
prevent the processing of your personal information for direct marketing purposes;
update any personal information that is out of date or incorrect;
delete any personal information which we are holding about you;
restrict the way that we process your personal information;
provide your personal information to a third-party provider of services; or
provide you with a copy of any personal information which we hold about you.

We try to answer every email promptly where possible and provide our response within the time stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs, and other records, which may or may not contain your personal information. Please also note that certain personal information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your personal information to comply with a legal obligation. When you email us with a request, we may ask that you provide us with the information necessary to confirm your identity.

VIII. How We Protect Your Information

We implement physical, organizational, and technological measures to protect your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify our Privacy Officer immediately.

IX. How Long We Retain Your Information

We keep your personal information for as long as we need it to provide the services and as permitted or required by applicable law. We delete or anonymize your information upon deletion of your account, unless:

we must keep it to comply with applicable law;
we must keep it to evidence of our compliance with applicable law;
there is an outstanding issue, claim, or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security.

X. Children’s Privacy

PROJECTOR strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 14 is prohibited, and certain regions and Content Offerings may have additional requirements and/or restrictions. In line with this belief, we do not knowingly collect or maintain personal information on our Site from persons under 14 years of age, and no part of our Site is directed to persons under 14 years of age. If you are under 14 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any personal information of persons less than 14 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such personal information.

XI. How to Contact Us

If you have any privacy-related questions, suggestions, unresolved problems, or complaints, you can reach us:
LLC “PROJECTOR SCHOOL”
01033, Kyiv, Volodymyrska str., bldg. 81-A
Tel.: +38067 418-95-78
hello@prjctr.com.ua

For the clients, located in EU or USA:
by email at prjctr.eu@prjctr.com
by mail at UAB “PROJECTOR INSTITUTE”, code 306299427, Lithuania, Vilniaus g. 31, LT-01402 Vilnius