Privacy Policy

1. Who processes the data

The data controller is Vladimir Pypin, an individual entrepreneur registered in Georgia (the “Author”). Details are given at the end of this document.

For any question about personal data, write to hazabenza@gmail.com.

2. What data is collected

From the application form:

• name;
• email;
• Telegram or WhatsApp (if provided);
• country of residence;
• the program you are interested in;
• your answer to “What would you like to learn?” (if provided).

During the training:

• correspondence and scheduling arrangements;
• the individual learning plan;
• payment data: payer name, amount, date and the bank details visible in the transfer;
• certificate data: name, program, scope and dates of study;
• the Author’s working notes during the training.

When you visit the website, the platform hosting it and the services it loads (such as fonts) technically receive your IP address and browser data. The website remembers your chosen language in your browser; this setting is not sent to the Author and is not personal data. No web analytics or advertising tags are currently used. If they are added, this policy will be updated before they are switched on.

3. Sensitive data

The training works with your own life situations, so information about health, family or other areas that the law treats as special categories of data may come up in conversation.

Please do not include such information in the application form. During the training, the Author does not record it in notes and uses it only within the session itself. Special category data is processed only with your written (including electronic) consent.

When talking about third parties (relatives, colleagues, clients), please leave out names and identifying details.

4. Purposes and legal bases

• Replying to your application and holding the introductory interview — basis: your consent and your request for the service.
• Preparing the learning plan, delivering the training and issuing the certificate — basis: concluding and performing the contract.
• Accounting and tax records — basis: the requirements of Georgian law.
• Protecting the Author’s rights in a dispute and keeping data secure — basis: the Author’s legitimate interest.

Newsletters and promotional messages are sent only with your separate explicit consent. You can opt out at any time; processing for this purpose stops no later than 7 working days after you opt out.

Providing data is voluntary, but without a name and contact details the Author cannot reply to your application, and without contract and payment details the training cannot take place.

5. Who receives the data

The Author does not sell personal data or share it for other parties’ marketing. Data may be received by:

• Google (Gmail, Google Drive, Google Sheets, Google Meet) — storing correspondence, applications and learning documents, and video calls;
• the platform that hosts the website and receives applications;
• banks and payment services — for payments and refunds;
• Georgian public authorities — only where the law expressly requires it.

These services process data on the Author’s behalf or as independent controllers under their own privacy policies.

6. Transfers outside Georgia

The servers of Google and the other services listed may be located outside Georgia, including in the United States and the European Union. Not all of these countries have been recognised by the Georgian authority as providing an adequate level of data protection.

Such transfers are therefore based on your explicit written (electronic) consent, given by ticking the box in the application form, in accordance with Articles 37–38 of the Law of Georgia on Personal Data Protection. You understand that data protection safeguards in those countries may differ from those in Georgia.

7. How long data is kept

• Applications that did not lead to training — 12 months from the last contact, then deleted.
• Student data — for the duration of the training and 3 years after it ends, to handle questions and complaints.
• Payment documents — for the period required by Georgian tax and accounting law.
• Records of issued certificates (name, program, scope, dates) — up to 10 years, so that a certificate’s authenticity can be confirmed.

After that, data is deleted or anonymised.

8. Your rights

You have the right to:

• know whether your data is processed, for what purpose and on what basis;
• receive a copy of your data;
• have your data corrected, updated or completed;
• have processing stopped and your data deleted or destroyed;
• have your data blocked;
• receive your data in a portable format;
• withdraw your consent at any time, without affecting the lawfulness of processing before withdrawal.

To exercise your rights, write to hazabenza@gmail.com. The Author will respond within the time limits set by law — generally within 10 working days; blocking requests are handled within 3 working days. The Author may ask you to confirm that the request comes from you.

If you believe your rights have been violated, you may contact the Georgian personal data protection authority (since 2 March 2026 its functions are performed by the State Audit Office of Georgia) or a court.

9. How data is protected

Data is kept in accounts protected by two-factor authentication, and only the Author has access. Sessions are not recorded. If a breach occurs that may cause harm, the Author will notify the authority within 72 hours and inform you without undue delay, as required by law.

10. Age

The programs are for people aged 18 and over. The Author does not knowingly collect data from minors. If you learn that a child has submitted an application, write to the Author and the data will be deleted.

11. Changes

The Author may update this policy. The new version is published on this page with its date. The Author will notify you by email of material changes affecting data you have already provided.

12. Details

• Individual Entrepreneur Vladimir Pypin
• Identification number: 300485295
• Registered in Georgia on 25.09.2026
• Registered address: Georgia, Tbilisi, Gldani district, Rezo Gabashvili street, N1, floor 8, apartment N196, block “B”
• Email: hazabenza@gmail.com