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GORIZONT Privacy Policy

Version: 1.0Effective date: 9 November 2026Website: https://gorizont.ioPersonal data controller: Individual entrepreneur (FOP) Rakivnenko Nazar ViktorovychTax ID (RNOKPP): 3573203056Email: hello@gorizont.io

In brief

This Policy explains what personal data the GORIZONT online school processes, what it is used for, who it is shared with, how long it is kept and what rights Users have.

Key points:

1. Who processes the data. The individual entrepreneur Rakivnenko Nazar Viktorovych, registered in Ukraine and operating under the GORIZONT brand.

2. What data is collected. We receive the data You provide yourself, as well as technical information about the use of the website, the educational platform and related services.

3. What the data is for. To place orders, provide learning, process payments, issue certificates, serve Users, run analytics and marketing, and protect intellectual property.

4. What technologies are used. The GORIZONT website uses Google Analytics, Meta Pixel, user session recording technologies and AI analysis of phone calls.

5. Learning tracking. We record the opening of lessons and other learning actions provided by the Platform. This information may be used to confirm that access was provided and to check the conditions of the voluntary refund guarantee.

6. Payments. Educational products are paid for through WayForPay. We do not ask for full bank card details by message or email.

7. Sharing data. We share the necessary data with providers of technical, payment, analytics, communication and other services on lawful grounds.

8. Advertising. We use advertising analytics, conversion measurement and retargeting in compliance with the law.

9. User rights. You may request information about the processing of your data, its correction or deletion, and exercise other rights provided by law.

10. Minors. Learning is available to minors in compliance with the law and with the necessary consents of legal representatives.

This summary is for information only and does not replace the full text of this Policy.

1. Who we are

1.1. The personal data controller, the person who determines the purposes and means of processing, is the individual entrepreneur Rakivnenko Nazar Viktorovych, tax ID (RNOKPP) 3573203056, registered in Ukraine and operating under the trade name GORIZONT (the “School”, the “Provider”, “We”, “Us”).

1.2. Registered address:
Ukraine, Poltava region, Lubny, Monastyrska St., 71v, 37500.

1.3. Official website and educational platform: https://gorizont.io.

1.4. Contact for personal data matters: hello@gorizont.io.

1.5. GORIZONT provides distance learning in artificial intelligence, neural generation, AI content creation, digital production and related professional skills.

1.6. Personal data is processed in accordance with the laws of Ukraine, including the Law of Ukraine “On Personal Data Protection”.

1.7. If the processing of data of Users from the European Union or other states falls under the relevant foreign legislation, the mandatory requirements of that legislation also apply, including the GDPR where it is applicable.

2. What this Policy covers

2.1. This Policy applies to the processing of personal data through:

2.2. The Policy supplements the GORIZONT Terms of Use and Public Offer Agreement published on the website.

2.3. The terms “Platform”, “Program”, “Student”, “Customer”, “Student area” and other terms may be used in the meaning set out in the public offer.

2.4. The Policy does not replace the documents of third-party services, including WayForPay, Google, Meta, Telegram, video hosting services and providers of AI tools.

2.5. When you interact with such services, data may be processed by the relevant organizations under their own policies and terms.

2.6. This Policy is an information notice about the processing of personal data and does not replace separate consents where the law requires them.

3. What data we collect

3.1. Data provided by the User

A. Applications and registration

We may collect:

B. Student area

If passwords are used, they must be stored using appropriate protection methods and not in plain text.

C. Questionnaires and surveys

D. Educational activity

E. Communication

F. Calls and meetings

We may process:

G. Payment

If the payment provider passes masked card details, they may be used to identify the transaction.

Full bank card details are processed by the relevant payment organizations.

H. Certificates

I. Case studies and reviews

Public use of reviews and materials takes place where the necessary legal grounds exist.

3.2. Data collected automatically

A. Technical information

B. Use of the website

C. Use of the educational platform

D. Security data

E. Cookies and similar technologies

Data obtained through cookies, pixels, local identifiers and other technologies is described in section 7.

3.3. Data from third-party sources

We may receive information from:
1. Google and Meta — advertising leads, campaign statistics, identifiers of advertising interactions and conversion data.
2. WayForPay and participating banks — the status of payments, refunds, installments and disputed transactions.
3. Telegram — the User’s account data available in the course of the interaction.
4. Partner platforms — information about the use of promo codes and referral offers.
5. Analytics and session recording services — data about interactions with the website.
6. Telephony and AI analysis services — call recordings, transcripts and analytical information.

3.4. Special categories of data

We do not ask without need for information about health, religious beliefs, political views, ethnic origin and other categories of data that require special protection.

Please do not provide such information in learning assignments, chats and requests unless it is needed for a specific lawful purpose.

3.5. Data of third parties

If the User provides materials that contain the personal data of other people, the User must have a lawful basis to use and provide them.

We recommend deleting or anonymizing the personal data of third parties before submitting learning materials.

3.6. Accuracy of data

The User is responsible for keeping the information provided up to date.

If contact details change, the User may contact support to have them corrected.

4. What we use personal data for

4.1. Providing educational services. Registering accounts, providing access, publishing lessons, organizing learning and issuing certificates.

4.2. Processing payments. Confirming orders, working with WayForPay, refunds, installments and meeting tax obligations.

4.3. Serving Users. Answering questions, solving technical problems and handling requests.

4.4. Selling educational programs. Processing applications, advising prospective students and keeping a history of communications.

4.5. Checking the refund conditions. Analyzing opened lessons and payment data to determine compliance with the GORIZONT voluntary guarantee.

4.6. Protecting learning materials. Preventing unauthorized distribution of content, sharing of accounts and other infringements of intellectual property.

4.7. Preventing fraud. Checking suspicious transactions, misuse of promo codes and unlawful actions on the Platform.

4.8. Analytics. Measuring website traffic, User behavior and the effectiveness of educational products.

4.9. Advertising. Analyzing conversions, optimizing advertising campaigns and retargeting where the relevant legal grounds exist.

4.10. Improving service. Analyzing requests, call recordings, the quality of consultations and typical User questions.

4.11. Product development. Analyzing the demand for lessons, learning difficulties and completion statistics.

4.12. Legal protection. Confirming the conclusion of the agreement and the provision of access, handling claims and protecting legitimate interests.

4.13. Compliance with the law. Meeting accounting and tax record-keeping obligations and handling lawful requests of competent authorities.

5. Legal grounds for processing

5.1. Personal data is processed on the grounds provided by the laws of Ukraine and other applicable law.

5.2. The grounds may include:

5.3. Registration, payment and the provision of learning require the processing of basic contact, registration and payment information.

5.4. Data about opened lessons and use of the account is processed to perform the agreement, ensure security and check the conditions of the voluntary refund guarantee.

5.5. Marketing processing that requires separate consent is carried out after such consent is obtained.

5.6. The User may withdraw consent where the processing is based on it.

5.7. Withdrawal of consent does not affect the lawfulness of processing carried out earlier and does not prevent processing on other lawful grounds.

6. Automated processing and artificial intelligence

6.1. GORIZONT uses automation and artificial intelligence technologies to process certain categories of information.

6.2. Such technologies may be used to:

6.3. AI analysis may include creating text summaries of calls, identifying the main topics, determining the results of a consultation and producing recommendations for improving service.

6.4. Automated systems may produce analytical estimates of the interest of prospective customers based on their requests and interactions with the website.

6.5. Automated results may be inaccurate. Where necessary, they are checked by responsible representatives of the School.

6.6. If a decision based solely on automated processing has legal or similarly significant effects for the User, the restrictions and safeguards provided by law apply.

6.7. Data may be passed to providers of AI services to the extent necessary to provide the relevant functionality.

6.8. Using personal data to train third-party AI models is permitted only where there is an appropriate legal basis, the necessary contractual terms and compliance with the requirements of applicable law.

7. Cookies, Google Analytics, Meta Pixel and session recording

7.1. General provisions

The GORIZONT website uses analytics technologies, advertising tracking, recording of user sessions and measurement of marketing effectiveness.

Such technologies include:

7.2. Google Analytics

Google Analytics is used to:

Depending on the settings, Google Analytics may process technical device data, identifiers, and information about events and the User’s actions.

Google may process the data received in accordance with its own terms and privacy policy.

7.3. Meta Pixel

The website has the Meta Pixel installed, which is used to:

The Meta Pixel may process technical identifiers, device data, and information about interaction with the website and advertising referrals.

Where there are lawful grounds and the relevant technical setup, information about applications or purchases may be sent to advertising systems, including in a protected or hashed form.

Hashing does not necessarily make data anonymous.

7.4. Recording of user sessions

GORIZONT uses session recording technologies to study how visitors interact with the website.

Such technologies may record:

The recordings are used to analyze the user experience, find interface problems and improve conversion.

We apply the necessary settings and protective measures to exclude the recording of passwords, full payment details and other information that is not needed for these purposes.

7.5. Advertising retargeting

Where the necessary legal grounds exist, GORIZONT may use information about visits to the website and interaction with educational offers to show ads to users who have previously shown interest in the School.

Retargeting may be carried out through Meta and Google.

7.6. Types of cookies

Strictly necessary cookies are used for authorization, security, keeping sessions and the operation of the Platform.

Functional cookies may store the User’s settings.

Analytics cookies are used to measure traffic, actions and the effectiveness of the website.

Marketing cookies are used for advertising analytics, conversion measurement and retargeting.

7.7. Consent to cookies

Technologies for which the applicable law requires prior consent are used only after such consent is obtained.

The User must be able to accept or reject non-essential categories of cookies separately where the law requires it.

Refusing non-essential cookies must not deprive the User of the basic functions of the website that are not related to the relevant processing.

7.8. Managing cookies

The User may change their consent through the cookie management mechanism provided on the website and may also use the browser settings.

Deleting or blocking strictly necessary cookies may affect the operation of some functions of the Platform.

7.9. Retention periods

The duration of cookies and related identifiers depends on the specific tool and its settings.

The current retention periods must be disclosed in the cookie settings or in the relevant table of the technologies used.

7.10. Third-party providers

Google and Meta may process data under their own rules.

The relevant providers of session recording technologies may also receive data within the configured integration.

8. Who we share data with

8.1. GORIZONT does not sell databases of personal data for money.

8.2. Personal data may be shared where necessary for the lawful purposes described in this Policy.

8.3. Providers of technical services. We may share the necessary information with organizations that provide:

8.4. Payment organizations. WayForPay, banks and other participants in payments may receive data needed to carry out transactions and refunds and to prevent fraud.

8.5. Analytics and advertising platforms. Such recipients include:

8.6. CRM, telephony and communications. Data may be processed by providers of CRM, telephony, email, messengers and communication automation systems.

8.7. AI services. External providers of artificial intelligence and speech recognition tools may be engaged to transcribe and analyze calls. The volume of data passed must match the stated purpose of processing.

8.8. Teachers and contractors. Teachers, technical specialists and other contractors may receive the necessary data within the performance of their duties. Access is granted subject to confidentiality requirements.

8.9. Other students. In the official chats and communities, other participants can see the name, public profile, messages and materials that the User posts in the space available to them.

8.10. Public authorities and courts. Information may be provided to competent authorities where there is a lawful request or another ground provided by law.

8.11. Professional advisers. Data may be passed to accountants, lawyers, auditors and other specialists to the extent necessary for their work.

8.12. Reorganization of the business. In the case of a lawful transfer of the business, individual assets or the educational platform, personal data may be passed to the successor in compliance with the requirements established by law.

8.13. Other cases. Data may be shared with the User’s separate consent or at the User’s request, where necessary.

9. International transfer of data

9.1. GORIZONT is registered in Ukraine.

9.2. Because international technology providers are used, personal data may be processed outside Ukraine.

9.3. In particular, international processing is possible when working with Google, Meta, providers of cloud services and AI tools and other technical contractors.

9.4. The conditions for protecting personal data may differ depending on the country of processing.

9.5. International transfer takes place where the grounds and safeguards provided by applicable law exist.

9.6. If the GDPR applies, the relevant international transfer mechanisms may be used, including standard contractual clauses and other permitted legal instruments.

9.7. International transfer must not be carried out merely on the assumption that visiting the website means universal consent to any cross-border operations.

10. How long we keep data

10.1. Personal data is kept for the period necessary for the relevant purpose of processing, performance of the agreement and compliance with mandatory requirements of law.

10.2. The following retention principles apply to different categories.

Applications without a purchase: until the purpose of processing is achieved, the applicable consent is withdrawn or the lawful ground for keeping the data ceases.

Registration data and learning information: for the period the account and access are active and then for a reasonable period needed to perform legal obligations and protect the rights of the parties.

Payment and accounting documents: for the mandatory periods established by the applicable tax and accounting legislation.

Access logs and lesson-opening logs: for the period needed to provide the learning, check the conditions of the refund guarantee and consider possible legal claims.

Recordings of phone calls and their transcripts: for a period justified by the purposes of quality control and service, then deleted or anonymized unless there is another lawful ground for keeping them.

Recordings of user sessions: within the periods set by the settings of the system used and needed for analytics.

Marketing data: until consent is withdrawn or another lawful ground for the relevant processing ceases.

Requests and complaints: for the period needed to consider the request and protect the rights of the parties.

10.3. If data is needed for a legal dispute, the investigation of a violation or the performance of a lawful demand, the retention period may be extended within the limits permitted by law.

10.4. When the necessary period ends, the data is deleted, anonymized or otherwise lawfully removed from active processing.

10.5. Information that must be kept by law may not be deleted immediately at the User’s request.

11. Your rights

11.1. The User has the rights provided by the applicable personal data protection legislation.

11.2. In particular, within the limits established by law, the User has the right to:

11.3. To exercise their rights, the User sends a request to hello@gorizont.io.

11.4. To prevent unlawful disclosure of data, the Provider may request reasonable confirmation of the applicant’s identity.

11.5. Requests are considered within the periods established by applicable law.

11.6. Deleting an account or ending the learning does not always mean immediate deletion of all data. Some information may be kept to perform legal obligations and protect rights.

11.7. The User may opt out of marketing mailings using the relevant link in the message or by contacting support.

11.8. If the GDPR applies to the relevant processing, the data subject may have additional rights, including the right to data portability, restriction of processing, objection to direct marketing and protection against certain solely automated decisions.

11.9. Users located in Ukraine may contact the Ukrainian Parliament Commissioner for Human Rights.

11.10. Users to whom the GDPR applies may also contact the competent data protection supervisory authority.

12. Security of personal data

12.1. GORIZONT applies organizational and technical measures aimed at protecting personal data against unauthorized access, unlawful processing, loss and disclosure.

12.2. Such measures should include, where appropriate:

12.3. Access to personal data is granted only to persons who need it to perform their duties.

12.4. Employees and contractors who have access to data must comply with confidentiality requirements.

12.5. Despite the protective measures applied, absolute security of the transmission and storage of data cannot be guaranteed.

12.6. The User must take reasonable measures to protect their own account.

12.7. If the User discovers unauthorized access to their account, the User may contact hello@gorizont.io.

12.8. In the event of a security incident, GORIZONT takes measures to investigate it and remedy its consequences and makes the necessary notifications in the cases provided by law.

13. Data of minors

13.1. GORIZONT allows minors to take part in educational programs in compliance with applicable law.

13.2. If the consent of a parent or another legal representative is required to purchase a product or to process a minor’s personal data, such consent must be obtained before the relevant action.

13.3. The School may request the necessary confirmation of the legal representative’s authority.

13.4. We aim to limit the processing of minors’ data to the information needed to provide the learning.

13.5. Minors’ data must not be used for behavioral advertising or advertising profiling in breach of applicable legal restrictions.

13.6. A parent or legal representative may contact hello@gorizont.io about the processing of a minor’s data.

13.7. If the unlawful collection of a minor’s data is discovered, the Provider takes the measures provided by law.

14. Changes to the Policy

14.1. GORIZONT may update this Policy when the law, the technologies used or the personal data processing procedures change.

14.2. The updated version is published on the official website with an indication of the effective date.

14.3. We may additionally notify of material changes affecting the processing of the data of current students by email or through the student area.

14.4. If new purposes of processing require separate consent, such consent is requested before the relevant processing begins.

14.5. Continuing to use the website does not in itself replace consent where the law requires it to be obtained separately.

14.6. Previous versions of the Policy may be kept to confirm the terms that applied and provided where there are appropriate grounds.

15. Language of the Policy

15.1. This version was drawn up in Russian.

15.2. To comply with the requirements of the laws of Ukraine, GORIZONT may publish a Ukrainian version of the Policy.

15.3. If there are discrepancies between the language versions, they are resolved taking into account the mandatory requirements of applicable law and the content of the notice provided to the relevant User.

15.4. Additional language versions may be published for the convenience of an international audience.

16. Contact information

Personal data controller:
Individual entrepreneur (FOP) Rakivnenko Nazar Viktorovych
Tax ID (RNOKPP): 3573203056
Address: Ukraine, Poltava region, Lubny, Monastyrska St., 71v, 37500
Educational project: GORIZONT
Website: https://gorizont.io
Email for requests on personal data, support and legal matters: hello@gorizont.io
Version date: 9 November 2026

© 2026 GORIZONT · hello@gorizont.io