Privacy Policy
and Consent to the Processing
of Personal Data

Effective date: April 26, 2026 · Last updated: April 26, 2026

Important: this English page is provided for convenience and information only. The Russian version at privacy.html is the governing version if any wording differs.

1. General Provisions

This policy explains how NEWMAN DEVELOPMENT L.L.C-FZ collects, uses, stores, transfers, and protects personal data related to the websites karytana.pro and newman.school, as well as customers of the company's educational products.

  • Controller: NEWMAN DEVELOPMENT L.L.C-FZ
  • Registered address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates
  • Registration number: 2644733
  • License number: 2644733.01 (Meydan Free Zone)
  • TRN: 105383717300001
  • Privacy contact: privacy@newman.school

The policy is designed with applicable privacy requirements in mind, including UAE PDPL, GDPR, UK data protection law, relevant Ukrainian law, and other applicable jurisdictional rules where appropriate.

2. Consent

Users provide consent to personal data processing by actions such as submitting a form, registering for a course platform, purchasing a product, or pressing buttons such as "Pay," "Apply," or "Buy." Consent is intended to be informed, specific, and voluntary.

By providing consent, the user confirms that they have reviewed the policy, understand the scope and purpose of processing, and understand that cross-border transfers may occur, including outside the EU and UAE.

3. Categories of Data

Depending on the interaction, the company may process identification, contact, payment, learning-process, and technical data.

  • Name, date of birth, country or city of residence, and optionally gender.
  • Email, phone number, Telegram username or identifier, and social profile links if voluntarily provided.
  • Payment information such as amount, currency, date, purpose, transaction identifier, and the last 4 digits of a bank card as supplied by a payment processor.
  • Course chat messages, homework, reflections, questions, comments, and testimonials.
  • IP address, device and browser details, essential cookies, and time of access.

The company does not receive or store full payment card details. Card processing is handled by compliant payment providers.

4. Purposes and Legal Bases

Data is used to deliver educational products and services, manage enrollments and communication, account for payments, provide support, maintain internal records, comply with legal obligations, and keep the website functioning properly.

The company does not use personal data for mass promotional campaigns on the website described in the Russian version of the policy.

5. Sources of Data

Data comes directly from the user, from payment systems to the extent needed for transaction accounting, and automatically from technical website usage. The company does not buy third-party marketing databases.

6. Processors and Third Parties

To provide services, the company may rely on external processors and platforms, including course delivery, CRM, document storage, video hosting, messaging, and banking infrastructure.

  • Course platform services such as antitreningi.ru for content delivery and participant management.
  • CRM services such as keycrm.app for client and sales records.
  • Google tools such as Google Sheets and Google Drive for internal records.
  • Google-hosted video infrastructure for unlisted lesson materials.
  • Telegram for course groups, channels, and support communications.
  • Banking and payment providers in the UAE for secure payment processing.

Data may also be disclosed when required by law or competent authorities.

7. Cross-Border Transfers

Because the service stack spans multiple countries, data may be transferred internationally. The company states that it uses reasonable technical and organizational safeguards for those transfers.

8. Retention

Data is retained only for as long as needed to fulfill the processing purposes, comply with law, resolve disputes, or maintain contractual records. After that period, data is deleted or anonymized where required.

9. User Rights

Depending on the applicable law, users may have the right to access, correct, delete, restrict, object to, or port their personal data, as well as withdraw consent and lodge a complaint with a supervisory authority.

Requests can be sent to privacy@newman.school. The company states that it generally responds within 30 calendar days, with limited extensions where legally permitted.

10. Cookies

The website uses only technically necessary cookies for basic operation, such as session support, display settings, and protection against automated abuse. The Russian version states that analytics, social media pixels, and advertising cookies are not used.

11. Security

The company says it uses reasonable technical and organizational measures, including HTTPS/TLS, access limitation, strong passwords, two-factor authentication where appropriate, software updates, and confidentiality obligations for contractors.

12. Minors

Services are intended for users aged 18 and older. The Russian policy also describes a limited path for certain 16-17-year-old users with written representative consent. The company states it does not intentionally collect personal data from children under 16.

13. User Responsibility

Users are responsible for the accuracy of the data they provide and must not publish third-party personal data in course chats or similar spaces without permission.

14. Policy Changes

The company may update the policy. The current version remains available on the site, and material changes may be communicated to active customers in advance.

15. Governing Law and Disputes

The governing framework described in the Russian policy is the law of the United Arab Emirates and the Emirate of Dubai, together with the applicable rules of Meydan Free Zone, subject to mandatory protections available to users under their own local law where applicable.

16. Contacts

This English page is an informational companion to the official Russian privacy policy published on the website.