PERSONAL DATA PROCESSING POLICY
of PsyClass FZE

Effective Date: 15.11.2025
Operator: PsyClass FZE
Address: Co-Working SmartDesk/408-26, Dubai, United Arab Emirates
Email: lifepractic@gmail.com
IBAN: AE090860000009550746105
SWIFT/BIC: WIOBAEADXXX

1. General Provisions
1.1. This Personal Data Processing Policy (“Policy”) explains how PsyClass FZE (“Operator”, “we”, “us”)
collects, uses, stores, protects and processes personal data of individuals (“User”, “Data Subject”) when
they access the Operator’s websites:
● https://psy-class.org/
● https://psy-class.com/
● https://psy-class.net/
● https://psy-class.net/
● and other domains using psy-class.org or psy-class.com.
1.2. Use of the Websites and entering into any contractual or pre-contractual relationship with the Operator
constitutes the User’s full and unconditional acceptance of this Policy. If the User disagrees, they must
immediately stop using the Websites.
1.3. This Policy is international. It applies regardless of the User’s citizenship, country of residence, or
location when accessing the Websites.
1.4. The Operator complies with general international data protection standards, including:
● globally accepted commercial practice;
● principles of transparency and fairness;
● general principles of GDPR (where applicable);
● principles of minimal and purpose-limited data collection.
1.5. This Policy regulates personal data processing in any form — online or offline, active or passive,
automated or manual.

2. Categories of Personal Data Processed
2.1. Data provided directly by the User:
● name and surname;
● email address;
● phone number;
● occupation, specialization, professional interests;
● information about training and education;
● payment-related data (order number, purchase details);
● voluntary application data (refund application, request forms).
2.2. Automatically collected data:
● IP address;
● device data, operating system;
● browser type and version;
● cookies and similar technologies;
● geolocation (approximate, where available);
● referring URLs;
● interaction logs and Website usage statistics;
● session data (clicks, navigation, time spent).
2.3. Data from third-party service providers:
Certain services may be provided using external platforms (e.g., GetCourse). These platforms may
independently collect and process additional data under their own privacy policies.
2.4. The Operator does not intentionally collect data of minors and recommends Website use only for
persons aged 18+.

3. Purposes of Processing Personal Data
Personal data is processed strictly for defined, legitimate purposes, including:
3.1. Contractual purposes:
● user identification;
● service provision, payment processing, access management;
● account creation and maintenance;
● communication regarding purchased services.
3.2. Operational purposes:
● improving the quality, structure and usability of the Websites;
● developing new products and services;
● internal analytics, statistics, and performance optimization.
3.3. Security purposes:
● detecting, preventing and mitigating fraudulent activities;
● ensuring compliance with legal obligations and applicable regulations;
● protecting the rights and interests of the Operator and other Users.
3.4. Communication purposes:
● sending service notifications;
● sending marketing or informational messages (with User consent);
● responding to inquiries and support requests.
3.5. Legal purposes:
● compliance with applicable laws;
● dispute resolution and enforcement of legal rights.

4. Use of Third-Party Platforms and Hosting Providers
4.1. International Use of GetCourse (neutral legal formulation)
The Operator uses third-party technical tools for providing and hosting digital content, including the
cloud-based learning platform GetCourse.
GetCourse is an international technology provider whose infrastructure may operate across different
jurisdictions. The Operator does not control the geographical location of GetCourse servers and does not
independently manage data processing performed by GetCourse.
Any processing performed by GetCourse is governed by its own privacy policy and compliance
framework.
4.2. Other third-party providers
The Operator may also use services for:
● email distribution;
● payment processing;
● cloud storage;
● analytics (e.g., Google Analytics);
● authentication services.
All third parties act under confidentiality obligations and process data only to the extent necessary to
provide technical functionality.

5. Legal Basis for Processing
Depending on the situation, the Operator processes personal data on one or more of the following bases:
● Consent of the User (Art. 5 GDPR principles);
● Performance of a contract or pre-contract actions;
● Legitimate interest (analytics, security, fraud prevention);
● Compliance with a legal obligation;
● Protection of rights and interests of the Operator or third parties.
Consent is considered granted when:
● ticking a checkbox;
● submitting a form;
● making a purchase;
● continuing use of the Website.

6. Transfer of Personal Data to Third Parties
Personal data may be transferred to third parties only in the following cases:
6.1. The User has provided consent.
6.2. Transfer is necessary to provide the Services (e.g., access through GetCourse, payment providers).
6.3. Transfer is necessary to protect the Operator’s rights in case of breach.
6.4. Transfer is required by applicable law or court order.
The Operator does not sell, rent, publicly disclose or exchange personal data with third parties.

7. Cross-Border Data Transfers
7.1. Personal data may be transferred internationally to jurisdictions with different levels of data protection.
7.2. Transfers are performed only when necessary for service delivery or operational reasons.
7.3. Regardless of the jurisdiction involved, the Operator ensures that adequate data protection measures
are applied, including contractual safeguards.

8. Data Retention
8.1. Personal data is retained only for as long as necessary for the purposes described in this Policy.
8.2. General retention periods:
● data related to service delivery — until the end of the contractual relationship;
● financial and transactional data — for the legally required retention period;
● account information — while the account remains active;
● marketing data — until consent is withdrawn.
8.3. After the retention period expires, data is securely deleted or anonymized.

9. User Rights
Subject to applicable law, Users may exercise the following rights:
● right to access their data;
● right to correction and update;
● right to withdraw consent;
● right to restriction of processing;
● right to object;
● right to deletion (“right to be forgotten” — where applicable);
● right to data portability (where applicable);
● right to lodge complaints.
Requests should be submitted to lifepractic@gmail.com.

10. Data Protection Measures
The Operator applies modern legal, technical and organizational safeguards to protect personal data,
including:
● encrypted communication channels;
● access controls and authentication;
● secure storage systems;
● monitoring for unauthorized access;
● periodic audits and internal control procedures;
● confidentiality agreements with staff and contractors.

11. Termination of Processing and Deletion of Data
Personal data must be deleted or anonymized when:
● the User withdraws consent;
● processing is no longer necessary;
● retention periods expire;
● the User requests deletion (subject to legal limitations).

12. Dispute Resolution
12.1. The User must first submit a written claim to the Operator.
12.2. The Operator responds within 30 days.
12.3. If no agreement is reached, disputes shall be resolved:
under the laws of the United Arab Emirates (Emirate of Dubai)
in the competent courts or arbitration procedures of Dubai.
This section aligns with your Public Offer Agreement (DIAC arbitration).

13. Amendments to the Policy
13.1. The Operator may update this Policy at any time.
13.2. The updated version becomes effective upon publication.
13.3. Continued use of the Website constitutes acceptance of the updated Policy.

14. Operator Details
PsyClass FZE
IBAN: AE090860000009550746105
SWIFT/BIC: WIOBAEADXXX
Business address: Co-Working SmartDesk/408-26, Dubai, UAE
Email: info@psyclassexperts.net