PRIVACY POLICY

Last Updated: August 28, 2025

1. Who We Are and What This Policy Covers

This Privacy Policy explains how your personal data is collected, used, and protected when you use our website https://face-sculptor.online/ (the "Site") and purchase our online courses (collectively, the "Services").

Your data is managed by two entities acting as Joint Data Controllers under the GDPR. This means we jointly determine the purposes and means of processing your personal data to provide you with our Services.

These entities ("we", "us", or "our") are:

The Program Director (Intellectual Property Owner):Pro Online Academy by Tofik Bayramov, a sole proprietorship registered in Georgia (LEPL National Agency of Public Registry Georgia, Adigeni Region, Village Untsa, Sakhltan) under file number 322759190.

And

The Contractor (Payment & Service Provider):DS Media, a company registered in the Netherlands (KVK Company Number: 91197643) with its registered office at Boompjes 56A, 3011 XB Rotterdam, Netherlands.

We are committed to safeguarding your privacy in accordance with applicable laws, including the General Data Protection Regulation (GDPR). By accessing or using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Definitions

  • Site: The online presence accessible via https://face-sculptor.online/.

  • User: Any natural person accessing or using our Services.

  • Personal Data: Any information relating to an identified or identifiable natural person (e.g., name, email address, IP address).

  • Processing: Any operation performed on personal data, including collection, recording, storage, use, and disclosure.

3. Information We Collect

We collect personal data from you in various ways, including when you use our Site, register for our online courses, or interact with our customer support.

3.1. Data You Provide Directly

  • Registration and Course Enrollment: Name, email address, postal address, telephone number, and payment information.

  • Communications: Any messages or correspondence you send to us via email or through the Site.

3.2. Data Collected Automatically

  • Usage Data: Information on how you navigate and use our Site, including pages viewed and duration of visits.

  • Technical Data: IP address, browser type and version, operating system, and device identifiers.

  • Cookies & Tracking Technologies: We use cookies, including those provided by Google Analytics, to enhance your experience.

4. How We Use Your Personal Data

We process your personal data for the following legitimate purposes:

  • Provision of Services: To register you for courses, manage your account, process transactions (handled by DS Media), and deliver our educational content (handled by Pro Online Academy).

  • Customer Support: To respond to your inquiries, resolve disputes, and provide technical support.

  • Marketing and Communications: To send you newsletters, promotions, and updates. You may opt out at any time.

  • Analytics and Improvement: To monitor and analyze usage trends and improve the functionality of our Site.

  • Compliance and Legal Obligations: To comply with applicable legal obligations (such as tax and financial laws), enforce our policies, and protect our rights.

5. Disclosure of Personal Data (How We Share Your Data)

We do not sell or rent your personal data. We may disclose your information in the following circumstances:

  • Between Joint Controllers: To fulfill our contract with you, your Personal Data is shared between DS Media (for payment processing and support) and Pro Online Academy (for providing access to the course content).

  • Service Providers: To trusted third-party service providers (such as our learning platform, email provider Send Pulse, and Google Analytics) who help us operate our Site. These providers are bound by confidentiality agreements.

  • Legal Compliance: When required by law or in response to a valid legal request (e.g., subpoenas, court orders).

  • Protection of Rights: To protect our rights, property, or the safety of our Users or others.

6. Cookies and Tracking Technologies

Our Site uses cookies and similar technologies (including Google Analytics) to collect information about your browsing activities, analyze traffic, and improve the user experience. Most browsers allow you to control cookies through settings.

7. International Data Transfers (EU to Georgia)

Your data is processed by our entities in both the Netherlands (European Union) and Georgia (Non-EU).

We ensure all data transfers are secure and lawful. The transfer of Personal Data from the EU (via DS Media) to Georgia (to Pro Online Academy) is protected under the European Commission's adequacy decision for Georgia, which confirms that Georgia provides a level of data protection equivalent to that of the GDPR.

8. Data Retention

We will retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable legal and financial/tax obligations.

9. Security of Your Personal Data

We implement a variety of technical and organizational security measures to maintain the safety of your personal data, including encryption, access controls, and secure data storage.

10. Your Rights Under GDPR

As a data subject, you have the following rights regarding your personal data:

  • Right to Access: You may request a copy of the personal data we hold about you.

  • Right to Rectification: You can request that we correct any inaccuracies.

  • Right to Erasure ("Right to be Forgotten"): You may request that your personal data be deleted under certain conditions.

  • Right to Restrict Processing: You can request that we restrict processing.

  • Right to Data Portability: You have the right to receive your data in a machine-readable format.

  • Right to Object: You may object to the processing of your personal data.

To exercise any of these rights, please contact us using the details provided below.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "Last Updated" date.

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please use our primary contact point:

Email: support@face-sculptor.online

You may also contact the Joint Data Controllers directly:

Payment & Service Contractor:DS MediaKVK: 91197643Boompjes 56A, 3011 XB Rotterdam, Netherlands

Program Director & IP Owner:Pro Online Academy by Tofik BayramovReg. No: 322759190Adigeni Region, Village Untsa, Sakhltan, Georgia