Privacy Policy

1.1. The owner of nantenamar.com and the controller of personal data is Darina Frein, the author of the NanteNamar teaching. She determines what data is collected, for what purposes and for how long it is retained.

1.2. Payments for services and digital products on the site are accepted by a payment agent acting on behalf of Darina Frein. The agent's registration details are disclosed in the public offer — the Service Agreement published on this site. Payments for purchases in the NanteNamar mobile app for iOS are accepted by Apple through the App Store (clause 1.5).

1.3. Send any question about this Policy and any request concerning your data to info@nantenamar.com — this is the official address for such requests.

1.4. This Policy covers the nantenamar.com website, the my.nantenamar.com learning platform, the NanteNamar mobile app and the official NanteNamar bot on Telegram. It does not cover third-party resources linked from the site (YouTube, Instagram, Facebook and others) — those are governed by the policies of their owners.

1.5. The NanteNamar mobile app gives access to the same account as the learning platform: purchased materials, lessons, the journal and messages open in it. Courses can be bought in the app through App Store in-app purchases: the payment is accepted by Apple under its own rules, and your bank card details and other payment data stay with Apple and are not passed to us (clauses 2.5–2.6). Data you enter in the app is stored on the learning platform and is processed under this Policy in the same way as platform data.

2.2. Please do not include information you would rather not disclose: medical records, other people's data, passwords. None of it is required to deliver the services.

2.4. Cookies and advertising identifiers. Some of them are necessary for the site to work — remembering your chosen language, for example. The rest relate to analytics and advertising and are described in Section 4.

2.5. Order data and payment metadata: the contents of the order, price, currency, date and time, payment status, the technical transaction identifier issued by the acquiring bank, and the email address the fiscal receipt is sent to. For a purchase in the mobile app through the App Store, we receive a transaction record signed by Apple. It includes, among other things: the transaction identifier and the original transaction identifier, the purchased item (the course tariff), the purchase date, the App Store storefront country, the currency and the amount in the storefront currency, the environment (production or test), the date and reason of the purchase's cancellation if Apple refunded the payment, the app download identifier that Apple assigns to the app downloaded with your Apple ID, service attributes of the transaction (for example, the purchase type, how the purchase was obtained, the date the record was signed), and the purchase token — a random identifier that the learning platform issues to your account in order to link the purchase to it. We keep the signed record in full as proof of the purchase. It does not contain your name, email address, Apple ID or payment details.

2.6. The site neither receives nor stores your bank card details. Card data is entered on the secure payment page of the acquiring bank and is processed solely by the bank. We receive only the outcome of the transaction and its technical identifier — the card number cannot be reconstructed from them. A purchase in the mobile app is paid for with the payment method linked to your Apple ID under the App Store rules: card details and other payment data are processed by Apple and are not passed to us.

2.7. Learning progress data: the fact that access to a product was granted, which lessons were opened and when, and completion marks. It is stored on the learning platform and is used, among other things, to verify the refund conditions set out in the offer.

2.8. We do not deliberately collect special categories of data — health, religious beliefs, political opinions or biometrics. If you volunteer such information in a message, it is processed only to the extent needed to answer you and is not used for any other purpose.

2.10. The app does not use advertising identifiers, does not include third-party analytics services and does not track you across other apps or websites.

2.11. Content you create on the learning platform and in the app: profile photo, journal entries and notes, assignment answers and uploaded files, lesson comments, community posts and messages, and support correspondence. It is stored in your account and is used only to run these sections.

3.1. Performance of our contract with you — placing and processing an order, granting access to digital products and the learning platform, delivering services, answering support requests and handling refund requests, as well as verifying App Store purchases, granting access under them and ending that access if Apple refunds the payment. Legal basis: performance of the contract (the public offer) to which you are a party, and steps taken at your request before entering into it.

3.2. Compliance with the law — fiscalisation of the payment transaction and issuing a receipt, accounting and tax records, retention of primary documents, and responses to lawful requests from competent authorities. Legal basis: legal obligation.

3.3. Analytics and advertising — understanding which materials are read, where visitors come from and which ads lead to an order, plus measuring campaign performance and serving ads. Legal basis: your consent. You can manage it through your browser settings and the ad preference settings of the relevant services (Section 4).

3.4. Notifications and informational messages — emails, Telegram messages and mobile app push notifications about your order, product access, new materials and learning events. Order-related messages form part of contract performance; the informational newsletter relies on consent, which you can withdraw in the message itself or by writing to info@nantenamar.com. Push notifications arrive only if you have turned them on yourself: the app asks for permission, and you can switch them off at any time in your phone settings or in the app («Профиль» → «Уведомления», Profile → Notifications).

3.5. Security and protection of rights — preventing fraud and abuse, diagnosing failures, protecting the site against attacks, and establishing or defending legal claims. Legal basis: legitimate interest. For these purposes the data is used to a minimal extent and is not used to profile you as a customer.

3.6. We do not use automated decision-making that produces legal effects for you. Advertising and analytics services group visitors by interests in order to show ads, but access to products, pricing and refund terms do not depend on that.

4.1. The site uses cookies and similar technologies — browser local storage, traffic counters and the Google Ads advertising tag. The full list, the purpose of each group and retention periods are set out in the Cookie Policy on this site.

4.2. Analytics and advertising requests are sent by your browser directly to Google servers. This means Google receives your IP address along with the event — as an independent company, under its own policy. Browser extensions and network filters block requests to these services, and in that case we simply receive no statistics.

4.3. You can manage analytics and advertising cookies through your browser (deleting and blocking cookies, tracker-blocking modes), through blocker extensions, and through the ad-preference settings of your Google account. Declining these cookies does not prevent you from using the site, reading the materials or placing an order.

5.1. We do not sell personal data and do not pass it to third parties for their own marketing. Data reaches only the service providers without which the site, payments, learning and support would not function — and only to the extent their task requires.

5.3. Providers that process data on our behalf do so under their published data processing terms: they are not entitled to use the data for their own purposes.

5.4. Data may be disclosed at the binding request of a competent public authority, or in the course of defending rights in court — strictly to the extent required.

5.5. If the project is reorganised or transferred to another person, the data may pass to the successor. The terms of processing cannot become less protective than those described here, and we will announce such a transfer on the site in advance.

6.1. Some of the providers listed in Section 5 are located outside Ukraine — in the European Union and the United States — and the hosting server network is distributed across several countries. By using their services we transfer data internationally.

6.2. Such transfers take place under the data processing terms included in our agreements with those providers — including the standard contractual clauses approved by the European Commission — and only to the extent required to deliver the respective service.

6.3. We choose providers that publish their data protection terms and confirm compliance with the applicable protection frameworks. We may change a provider at any time; the list in Section 5 will then be updated and the edition date changed.

7.1. Order data, payment records and fiscal receipts — for the period set by tax and accounting law for primary documents, and in any case no less than three years from the date of the transaction. Records of App Store purchases (clause 2.5) are kept for the same period as order data. When your account is deleted, they remain linked to the order data, including the buyer's email address; the direct link to your account is removed from them, and the purchase token is erased from the account (see the "Account deletion" page). The record signed by Apple is kept unchanged, including the purchase token.

7.2. Your learning platform account and progress data — for as long as your access to the purchased products lasts. Where access is perpetual, the data is kept until you ask us to delete the account. How to do that and what happens after the request is described on the "Account deletion" page.

7.3. Requests submitted through the site forms and support correspondence — up to 24 months from your last message, unless a longer period is required to resolve a dispute.

7.4. Web server logs — for the period the hosting provider retains technical logs, as a rule no longer than 30 days.

7.5. Analytics and advertising identifiers — for the lifetime of the corresponding cookies; the maximum periods are listed in the Cookie Policy.

7.6. Once the period expires, data is deleted or anonymised. Information needed to defend legal claims may be retained until the limitation period expires.

7.7. A push token stops being used as soon as you turn notifications off, ask us to delete your account, or the app is removed from the device. The record of it is kept with the account and is deleted when the account is deleted.

8.2. To exercise any of these rights, write to info@nantenamar.com. We reply within 30 calendar days of receiving the request. If the request is complex, or there are several of them, the period may be extended — we will tell you separately and explain why.

8.3. To avoid handing your data to someone else, we may ask you to confirm that the request comes from you — for instance, to send it from the email address used for the order.

8.4. Erasure is not always possible in full: records of completed payments and fiscal documents must be retained by law. In that case we delete everything not covered by that obligation and explain what remains and why.

8.5. Exercising your data rights is free of charge. A fee or a refusal is possible only for manifestly unfounded or repetitive requests — and always with an explanation.

8.6. You can delete your account yourself — in the mobile app («Профиль» → «Вход и безопасность» → «Удалить аккаунт», Profile → Sign-in and security → Delete account) or on the learning platform (Profile → Sign-in and security), or by writing to info@nantenamar.com. When the request is made in the app or on the platform, all sign-in sessions end at once and a confirmation email is sent to the account address; deletion is completed no later than 30 days from the date of the request. Order data, payment records and fiscal receipts are kept for the period stated in clause 7.1. The full procedure is on the "Account deletion" page.

9.1. Connections to the site, the learning platform, the mobile app and all service systems are encrypted (HTTPS/TLS).

9.2. Bank card details never reach the site, the learning platform or the mobile app: on the site they are accepted and processed by the acquiring bank on its own secure page, and for purchases in the app — by Apple.

9.3. Access to order data and accounts is limited to Darina Frein and the project's technical administrator, to the extent their work requires. Access to service systems is protected by individual credentials.

9.4. No system is absolutely secure. Should a security breach occur that is likely to create a risk to your rights, we will notify the affected users and the competent authority in the manner and within the deadlines prescribed by law.

10.1. The site, the services and the digital products are addressed to adults. We do not knowingly collect data of persons under 16 and do not offer our products to them.

10.2. If it turns out that a child's data has reached us without the consent of a parent or guardian, we will delete it. Please report this to info@nantenamar.com.

11.1. This Policy may change — for example, when a new service is connected or the set of collected data changes. The current edition is always available at this address, with its date.

11.2. Material changes are published at least one day before they take effect. If a change requires your consent, we will ask for it separately rather than assume it by default.

12.1. The controller of personal data is Darina Frein.

12.2. The address for any request concerning personal data, including the rights in Section 8: info@nantenamar.com.

12.3. Questions about orders, payment, access and refunds are governed by the Service Agreement published on this site; contact details and a request form are in the Contacts section.