Data Processing Addendum

1. Who we are and our roles

tolverica.com (LLC) is the service provider responsible for providing course and lead-related services. Depending on the specific processing, tolverica.com acts as a controller (when it determines the purposes and means of processing) and/or as a processor (when it processes personal data on behalf of another entity that is the controller).

Business details (UA): tolverica.com, LLC; 15 Khreshchatyk St, Kyiv, 01001, Ukraine; contact@tolverica.com; +380 633 071 2760; EDRPOU registration code: 26425736; legal representative: Sara Klein, Managing Director.

2. Types of personal data

We may process the following categories of personal data when you request course information, register for a course, or submit a contact/lead form:

• Contact details: name, email address, phone number (where provided/required).
• Request details: information you enter in the form (e.g., course selection, questions).
• Communication and support history.
• Technical and usage data related to form submissions and website interaction (e.g., IP address, browser/device identifiers, timestamps), to maintain service availability and security.

3. Purposes of processing

• To respond to and manage lead/contact inquiries and provide requested course information.
• To administer course registration and, where applicable, conclude and perform distance arrangements.
• To provide customer support and handle service-related requests.
• To ensure security, fraud prevention, and compliance with applicable legal obligations.

4. Legal basis for processing (UA)

Where required, processing is carried out on lawful grounds under the relevant Ukrainian data protection and consumer/e-commerce rules, including:

• Law on Personal Data: Закон України "Про захист персональних даних" від 01.06.2010 № 2297-VI.
• Consumer protection and distance arrangements: Закон України "Про захист прав споживачів" від 12.05.1991 № 1023-XII (including mandatory consumer information for distance arrangements before the consumer commits).
• Electronic commerce: Закон України "Про електронну комерцію" від 03.09.2015 № 675-VIII, where online agreements or distance transactions are concluded.
• Ukrainian state language: Закон України "Про забезпечення функціонування української мови як державної" від 25.04.2019 № 2704-VIII (for mandatory language requirements related to providing information in Ukraine).

If processing requires consent under applicable law, we present the relevant consent choices at the time of collection, consistent with the Law on Personal Data.

5. Disclosure to subprocessors and safeguards

We may share personal data with subprocessors that provide services necessary to deliver courses and manage leads (for example, hosting, email/communications, analytics, customer support tools, and other operational services). Where we use subprocessors, we apply contractual and organizational measures designed to protect personal data, including confidentiality obligations and security controls appropriate to the risks.

We do not sell personal data. We share personal data only to the extent necessary for the purposes described in this Addendum and in accordance with applicable law.

6. International transfers

If personal data is processed or stored outside Ukraine as part of using subcontractors or technical infrastructure, we ensure that such transfer is lawful and supported by appropriate safeguards under applicable Ukrainian requirements.

7. Data retention

We retain personal data only for as long as necessary for the purposes described above, including to provide services, handle inquiries, resolve issues, maintain security, and comply with legal obligations. Retention periods may vary by processing purpose and system requirements.

8. Security measures

We implement reasonable technical and organizational security measures to protect personal data against unauthorized access, loss, destruction, alteration, and disclosure, taking into account the nature of the data and the risks associated with processing.

9. Your rights

If you are a data subject, you may have rights under Ukrainian law regarding access to your personal data, correction, deletion/termination of processing in cases provided by law, and other rights established by the Law on Personal Data. To exercise your rights, contact us using the details below.

10. Contact

For questions about personal data processing, subprocessors, or your rights, contact:

tolverica.com (LLC)
15 Khreshchatyk St, Kyiv, 01001, Ukraine
contact@tolverica.com
+380 633 071 2760