PRIVACY POLICY
Ruslan Fedorenko
Effective Date: September 1, 2026
Version: 2.2

1. General Provisions

This Privacy Policy (the "Policy") explains how Ruslan Fedorenko (the "Service Provider") collects, uses, stores, and protects the personal information of website visitors and students.
This Policy applies to:

• Individual and group English-language lessons;
• Individual and group CELPIP preparation;
• The Time Machine online course and other digital educational products;
• Website visits, form submissions, payments, and communications with the Service Provider.

The Service Provider operates from Canada and provides educational services to students in various countries around the world.
Personal information is processed in accordance with applicable laws, including Alberta's Personal Information Protection Act (PIPA) and Canada's federal Personal Information Protection and Electronic Documents Act (PIPEDA), where applicable.
The processing of personal information belonging to users in other countries may also be subject to mandatory requirements under their applicable laws, including the European Union's General Data Protection Regulation (GDPR), where it applies to the relevant activities.
This Policy does not limit any rights guaranteed to users under applicable law.
Ruslan Fedorenko is responsible for the handling of personal information. Privacy-related inquiries may be submitted to the contact email address published on the Service Provider's official website.

2. Personal Information We Collect

Depending on the services you use, we may collect:

• Contact information: First and last name, email address, telephone number, and information you voluntarily provide.
• Educational information: English proficiency level, learning objectives, homework assignments, written and spoken responses, practice test results, instructor feedback, and lesson attendance.
• Payment information: Details of purchased services, payment amounts, dates, and statuses, as well as information needed for payment records and refunds.
• Technical information: IP address, browser type, device information, technical cookie identifiers, and other data necessary for website operation and security.
• Analytics information: Pages visited, traffic sources, website interactions, device types, and approximate geographic location.

We use Google Analytics to analyze website traffic. Depending on its configuration and the consent provided by the user, Google Analytics may use cookies and other technical identifiers.
We do not intentionally use Google Analytics to collect names, email addresses, telephone numbers, or the content of students' educational assignments.
Payments may be processed through Stripe. Complete payment-card details entered directly into Stripe's payment interface are processed by Stripe. The Service Provider does not collect or store complete payment-card numbers or CVV security codes.
We do not request sensitive personal information that is unnecessary for educational services or purchases.

3. How We Use Personal Information

We use personal information to:

• Organize and deliver lessons;
• Provide access to purchased courses;
• Review assignments and provide educational feedback;
• Process payments and maintain necessary records;
• Communicate with students and respond to inquiries;
• Improve educational materials and service quality;
• Analyze website traffic and improve website performance;
• Maintain website security;
• Comply with legal obligations.

Google Analytics is used to obtain website traffic statistics, including visitor numbers, popular pages, traffic sources, and general engagement metrics.
We aim to collect only the information reasonably necessary for the purposes identified.
Personal information is processed with appropriate consent or another lawful basis permitted by applicable law.
We will not use personal information for materially different purposes without providing appropriate notice and obtaining additional consent where legally required.

4. Third-Party Services and International Data Transfers

We use third-party services to deliver educational services and operate our website, including:

• Tilda: Website hosting and processing inquiries submitted through online forms.
• Stripe: Payment processing, transactions, and management of agreed installment payment plans.
• Google Analytics: Website traffic analysis and measurement of user interactions with website pages.
• Video conferencing services: Delivery of online lessons.
• Email and communication services: Communication with students and handling inquiries.

Third-party providers may receive and process information necessary to perform their respective services.
Some personal information may be processed or stored outside Canada, including in the United States and other countries, depending on the provider and its infrastructure.
In such cases, information may be subject to the laws of the relevant country, including lawful requests for access by public authorities.
We take reasonable steps to protect personal information when it is transferred to or processed by third-party providers.
Users may contact the Service Provider to request additional information about third-party processing arrangements, their purposes, and the countries where processing takes place.
We do not sell students' personal information to third parties.
Privacy policies of our main service providers:

• Stripe: https://stripe.com/privacy
• Tilda: https://tilda.cc/privacy/
• Google: https://policies.google.com/privacy

5. Cookies and Google Analytics

Our website uses cookies and similar technologies to support certain functions and analyze website traffic.
Essential Cookies
These cookies may be used to:

• Ensure the proper operation of the website;
• Maintain technical settings;
• Support website security;
• Enable website forms and payment functionality;
• Authenticate users where applicable.

Analytics Cookies
Our website uses Google Analytics, which may use analytics cookies and similar technologies to collect website traffic statistics.
These technologies may help identify which pages visitors access, how they arrive at the website, and how they interact with its content.
Analytics cookies are used in accordance with the website's configuration and applicable legal requirements regarding user consent.
Where consent is legally required, analytics tracking must begin only after the necessary consent has been obtained.
Our website does not use Meta Pixel.
Managing Cookies
Users can restrict or delete cookies through their browser settings.
Where cookie consent management controls are available on the website, users may use them to adjust their preferences.
Disabling essential cookies may affect certain website functions.
If new analytics or advertising technologies are introduced, this Policy will be updated, and any required user consent will be obtained in accordance with applicable law.

6. Lesson Recordings and Educational Materials

Group lessons may be recorded at a student's request submitted before the relevant lesson begins.
Recordings are made subject to appropriate participant notification and any consent required under applicable law.
Recordings may contain participants' voices, images, names, and contributions.
The Service Provider may store lesson recordings as video files and make them available to the students for whom they are intended.
There is currently no fixed automatic deletion period for recordings. They are retained only for as long as reasonably necessary for educational purposes, fulfilling agreed arrangements, or other lawful needs.
Students must not sell, publish, or share recordings with third parties without the necessary permissions.
Homework assignments, written work, spoken responses, and practice test results are used for instruction, assessment, and monitoring learning progress.
Students retain their rights to their original work.
Students' names, photographs, voices, testimonials, or results are used in promotional materials only with appropriate consent.

7. Data Retention and Security

Under Tilda's standard settings, inquiries submitted through website forms are stored in its submissions section for one month, after which they are removed from that section.
If information is forwarded to other connected services, their retention periods may differ.
Other personal information is retained only for as long as reasonably necessary to deliver services, respond to inquiries, maintain records, or comply with legal obligations.
Payment and tax records may be retained for longer periods as required by Canadian law.
Analytics data retention periods depend on Google Analytics settings and applicable Google policies.
We take reasonable technical and organizational measures to protect information from unauthorized access, loss, alteration, or disclosure.
When personal information is no longer required, we take steps to securely delete, destroy, or anonymize it, subject to applicable legal requirements.
No method of transmitting or storing information over the internet can guarantee absolute security.
In the event of a personal information security breach, we will take appropriate action and notify affected individuals or authorities where required by law.

8. User Rights and Electronic Communications

Depending on applicable law, you may have the right to:

• Request access to your personal information;
• Request correction of inaccurate or incomplete information;
• Obtain information about how your data is used or disclosed;
• Withdraw consent where permitted by law;
• Request deletion of information where legally applicable;
• Submit a complaint regarding the handling of personal information.

Requests may be sent to the Service Provider's contact email address.
We review requests within the time limits required by applicable law. We may need to verify your identity before fulfilling certain requests.
Withdrawing consent for data processing may affect our ability to provide services that require the relevant information.
We may send communications relating to purchased services, including payment confirmations, lesson reminders, schedule changes, and course access information.
Promotional electronic communications are sent in accordance with applicable law, including Canada's Anti-Spam Legislation (CASL).
Where consent is required for marketing communications, we obtain it appropriately.
Users may unsubscribe from promotional messages using an available unsubscribe mechanism or by contacting the Service Provider.
Unsubscribing from marketing communications does not prevent users from receiving necessary information about purchased services.

9. Changes to This Policy and Contact Information

We may update this Policy to reflect changes in educational services, technology, third-party providers, data processing practices, or applicable law.
The current version will be published on the website with its effective date.
If changes materially affect the processing of personal information, we will provide appropriate notice and obtain additional consent where required by law.

Person Responsible for Privacy:
Ruslan Fedorenko
Alberta, Canada
Email: info@ruslan-englishteacher.com.

For questions about this Policy, access to personal information, corrections, or complaints, please contact the Service Provider directly.
Users also retain the right to contact the appropriate privacy authorities, including the Office of the Information and Privacy Commissioner of Alberta, where permitted by applicable law.
This Policy does not limit any mandatory rights provided under the laws of a country or region that apply to the relevant processing of personal information.