This privacy policy (hereinafter - the Policy) explains what information we collect about you, how we do it, how we use such information and how we can transfer such information. This Policy applies to any personal data we collect from you in any way, including the following:

• through our websites: psykalen.com, as well as any other websites containing a link to this Policy (hereinafter referred to as the Website);
• through our pages on social networks: Vkontakte, Facebook, Instagram, Odnoklassniki, Youtube and other social networks, including:
	https://vk.com/elenakalen1,
	https://vk.com/lenakalen2,
	https://vk.com/elenakalenvip,
	https://vk.com/intensivkalen,
	https://vk.com/public173593620,
	https://ok.ru/lenakalen,
	https://www.instagram.com/elenakalen/,
	https://vk.com/kelengroup,
	https://youtube.com/ElenaKalen,
	and other pages (hereinafter - Social media pages);
• through our Services: our subscription services, as well as any other services containing link to the Policy.

The Policy also applies to any personal data that you provide to us through e-mail, phone, sms, via social networks (for example, in response to advertisements), in instant messengers, any chat bots, letters, as well as those provided in person. This Policy should be read in conjunction with the following documents:
Public offer - https://psykalen.com/public_offer

WHO ARE WE
When you visit our Website, use our services or interact with us through Social media pages, or otherwise provide information to us, you provide it to Psykalen Limited, a company registered under the laws of the Republic Cyprus with registration number HE 393317. 

Psykalen Limited is the controller of the personal data provided by you, collects and processes personal data about you. When we process personal data, we carry it out in accordance with the requirements of the General
the regulation on the protection of personal data (English Regulation (EU) 2016/679 (General Data Protection Regulation)) and local regulatory legal acts in force on the territories of the countries where we provide services. Other companies, individuals and / or individual entrepreneurs can provide services similar or similar to ours based on licensing agreements. Please read the Policy of such persons carefully and make sure that you know who provides you the service.

WHAT DATA DO WE COLLECT
The type and amount of data we collect about you depends on how we  interact with you. There are three main ways in which we collect data about you:
• directly from you;
• from other sources;
• automatically. 

DATA THAT WE RECEIVE DIRECTLY FROM YOU
When you contact us directly, we receive data from you, for example when you:
• Contact us through the feedback forms on our Website using the Social media pages, as well as sending us an e-mail, a private message in instant messengers and other ways;
• Subscribe to receive our marketing materials;
• Fill out a questionnaire to receive our services;
• Participate in contests conducted by us, take tests;
• Comment on our posts on Social media pages;

DATA WE RECEIVE FROM OTHER SOURCES
Sometimes we also collect data about you from other sources, for example:
• When you pay for our services, the payment system collects some data about you and transfers to us;
• When our partners share your data with us so that we can provide you services or provide the information you need;
• To improve the quality of our services, we use third-party services suppliers. These service providers collect individual information about you automatically and some of this information may be transferred to us. At the moment we are using the following suppliers:
- Facebook (Products Facebook Custom Audience, Facebook Connect);
- Yandex (Product Yandex.Metrics);
- Google (Google Analytics Product);
- Mail.ru (Top Mail product);
and others.
• In other cases, when we receive information about you from third parties.

DATA WE COLLECT AUTOMATICALLY
When you access any of our Websites and view or use our Services, we collect data about how you use the site and your activity on it from use of certain technologies such as cookies and web alerts. Which cookies files we collect, use and process depends on the cookie settings in your browser and cookie settings that you set when you first access our website.

THE REASONS FOR WHICH WE COLLECT YOUR PERSONAL DATA
This section discusses the legal basis for the processing of your personal data. The legal basis we rely on in each case we collect and use your personal data is usually are the following:
• Based on the concluded contract: in order to fulfill and ensure compliance with our offer, as well as any other contracts entered into with you;
• Subject to your consent, which you can revoke at any time;
• As necessary for our (or other) legitimate interests, including our interests in providing a secure Website / services, detecting fraud, tailoring your experience on our Website, to update our Website and develop our business, except when such processing does not violate your legitimate interests, rights or freedoms.

HOW DO WE USE YOUR PERSONAL DATA
Generally, the reasons why we use your personal data can be classified as follows:
• To sell our products and services to you;
• To enable you to pay for our services;
• To personalize our services for you;
• To maintain and improve our services and the infrastructure of our Website;
• In order to inform you about our services, our promotions and provide other additional information. 
Where we plan to process your personal data for any other purposes, we guarantee that we will first notify you of this (and, if necessary, will receive your prior consent).

TO WHOM DO WE SHARE YOUR PERSONAL DATA

COMPANIES - PAYMENT AGENTS
We share your personal data with payment agent companies that help us to accept payment from you for our services using various payment instruments such as bank cards, electronic money and others.

PARTNERS OFFERING OUR SERVICES
When, for any reason, we are unable to provide you with services directly, we transfer your data to our partners who provide our services on the basis of licensing and other contracts. We provide such partners only with the information they need for providing services. We encourage you to familiarize yourself with the policies they use processing personal data.

SELLERS AND SERVICE PROVIDERS
We provide information and content to our suppliers who support our business. For example, service providers provide technical infrastructure services, analyzing the use of the website and services, providing customer service, facilitating payments, conducting surveys, providing marketing services or providing identification services fraud.

We may also need to transfer personal data to other parties, such as external contractors and our professional consultants. Usually transmitted to such persons the information is anonymous, but this is not always possible. We conclude contracts with all third parties to whom we transfer personal information to ensure confidentiality of your information and use it only for the purpose of providing you services and in accordance with applicable EU legislation and jurisdictions in which we are working. We may also be required to provide some personal information in accordance with legal requirements. Some of these third-party recipients may be outside the European Economic Area.


HOW LONG DO WE STORE YOUR PERSONAL DATA
We will keep your personal data for as long as we provide you with any services (including any marketing or mailing services). After we will therefore keep your personal information for as long as necessary in order to:
• respond to any questions, complaints or claims made by or on your behalf;
• keep records in accordance with legal requirements.
We will not store your personal information for longer than is necessary for the purposes set forth in this Policy and when it is no longer necessary to maintain your personal information, we will delete or anonymize it. For different types of personal information different storage periods apply. If you need more information, see below section "How to contact us".

TRANSFER OF YOUR DATA FROM THE EUROPEAN ECONOMIC AREA
To provide you with access to and the ability to use the Website and our services, sometimes it is necessary for us to transfer your personal data outside the European economic area (EEA), for example in the following cases:
• yours and ours service providers located outside the EEA;
• if you are outside the EEA.
These transfers are subject to special rules in accordance with European data protection legislation. Before authorizing such a transfer, we conduct assessment to ensure the safety of all transmitted personal data. Usually, we use the standard data protection model clauses that have been approved by the European Commission (as permitted under Article 46 (2) of the General Regulations on the protection of personal data). If you need more information, see "How with us contact" below.

YOUR RIGHTS
In accordance with the General Data Protection Regulation, you receive a number of important rights. Among others, you have the right to access your personal data and the right to request us to correct any errors in the data we hold or delete your personal data subject to certain restrictions. In some cases, you also can request that we restrict the way we process your personal data, object against its processing or to request a copy of your personal data for the purpose of transferring to another place. If we have requested and received your consent to process certain information, you can revoke this consent at any time. However, if we do not have all the data, necessary for the provision of services, fulfillment of the terms of the offer, administration of contracts, orders necessary to provide you services, we may no longer be able to provide to you such services. If you want to exercise any of these rights or need more information about it, see "How to contact us" section below.

HOW DO WE PROTECT YOUR PERSONAL DATA
We have taken adequate security measures to prevent accidental loss or using your personal data in an unauthorized manner. We provide access to your personal data only to those for whom it is really 
necessary and only for the purposes indicated above. Those who process your data will do so only in an authorized manner and will be bound by confidentiality. We constantly test our systems to ensure that the security level fits any risk. All your personal data is encrypted. Our Website uses HTTPS, which means that all data transmitted from your web browser to our servers are also encrypted. Our data servers are located on
the territory of the European Union and for persons located in third countries - on the territory of such
countries. We also have procedures to resolve any suspected security breach data. We will notify you and any relevant regulator of the alleged violation data security, if required by law.

HOW TO COMPLAIN
We hope we can resolve any question or problem you may have about the use of your personal data.  The General Data Protection Regulation also gives you the right to lodge a complaint with supervisory authority, in particular in the European Union country where you work, usually reside or where any alleged violation of data protection laws has occurred. Supervisory authority in Cyprus is the Office of the Commissioner for Personal Data Protection who can be contacted at 
Jasonos Str., 1082, Nicosia, 
Cyprus, 
Postal address
P.O.Box 23378, 1682 Nicosia, Cyprus
Tel: +357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy 
http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/page1i_en/page1i_en?opendocument 
or by phone: +357 22818456.

HOW TO CONTACT US
Please contact us if you have any questions about this Policy or data we hold about you. If you would like to contact us, please: write to us at the following address: 165, Spyrou Araouzou, office 401, 3036, Limassol, Cyprus OR write us an e-mail: sec@elenakalen.com

When sending us a request, please provide us with sufficient information to identify you (for example, your full name and contact details, including your address, email), and also tell us the nature of your request, for example, what right you want use, and also include the information to which your request relates.
Please note that we may ask you to provide proof of identity when considering your request.
Please note that it may take up to 14 days for your request to complete.
We may change this Policy from time to time. When we do this, we will publish changes on the Website. This version of the Policy is effective from 01.01.2021