Privacy Policy

1) Who we are and how to contact us

Service provider: glowfenn.com (PE).

• Address: 18 Volodymyrska St, Kyiv, 01001, Ukraine
• Email: contact@glowfenn.com
• Phone: +380 933 559 7388
• Legal representative: Sara Bauer, Managing Director
• Registration (EDRPOU): 81302803

We provide information services and exam preparation. This site is intended for users in Ukraine.

2) Personal data we collect

Depending on how you use the site, we may collect:

• Contact and identity data: name, email, phone number.
• Request/lead data: information you enter in contact or request forms (e.g., your questions, preferred timeframes, and notes).
• Service and scheduling data: course/exam-related information you provide for booking, rescheduling, and communications.
• Communications: messages you send to us and related metadata (time sent, channel).
• Device and usage data (if applicable): technical logs and, if enabled, cookie-derived information (see Section 7).

We do not require you to provide more personal data than necessary to request the service.

3) How we use personal data

We process personal data to:

• provide exam preparation and related scheduling/communications;
• respond to inquiries and manage requests;
• maintain service quality and operational continuity;
• fulfill legal obligations and enforce our rights;
• operate and improve the website, including security and error monitoring.

If any message on the site is considered advertising, we ensure that it is not misleading and does not imply guaranteed results.

4) Legal basis for processing (Ukraine)

We process personal data in accordance with applicable Ukrainian law, including:

• Consent and/or necessity to provide the requested service: where you submit a request, we process the data to fulfill that request and communicate with you.
• Legal obligations: where required by law.
• Legitimate interests: where applicable and not overridden by your rights.

We cite: Law of Ukraine “On Protection of Personal Data” № 2297-VI.

Electronic commerce and information communications on this site are also provided with reference to the Law of Ukraine “On Electronic Commerce” № 675-VIII.

5) Data retention

We keep personal data only for as long as necessary for the purposes described in this Policy, including the provision of services, communications, and compliance with legal requirements. After that period, data is deleted or anonymized, unless retention is required by law or for lawful defense of claims.

6) Your rights

Under Ukrainian law, you may have the right to access your personal data, request correction, deletion, and other lawful actions, as well as to withdraw consent where processing is based on consent. You may also object to processing in cases provided by law.

If you are a consumer, you may exercise consumer rights and seek remedies in accordance with Ukrainian legislation. For the purpose of exercising consumer rights and dispute resolution, you can contact us at contact@glowfenn.com or by phone.

We cite: Law of Ukraine “On Protection of Personal Data” № 2297-VI and Law of Ukraine “On Consumer Rights Protection” № 3153-IX.

7) Cookies and tracking

We may use cookies or similar technologies to make the website work properly and to understand usage patterns. Where cookies are used for analytics/marketing purposes, we provide transparency and mechanisms for consent or refusal, in accordance with the Law of Ukraine “On Protection of Personal Data” № 2297-VI.

You can manage cookie preferences through your browser settings. Note that disabling cookies may affect some website functions.

8) Security

We take reasonable administrative and technical measures to protect personal data from unauthorized access, loss, misuse, alteration, or disclosure. No method of transmission over the internet is 100% secure, but we aim to reduce risks.

9) Ukrainian language requirement

Because services are offered in Ukraine, required consumer-facing information is available in the Ukrainian state language where applicable, in accordance with the Law of Ukraine “On Ensuring the Functioning of the Ukrainian Language as the State Language”.

(This page is provided in English as requested; additional Ukrainian information may be provided on-site.)