January 10, 2026


Privacy Policy

TERMS AND DEFINITIONS


We kindly ask you to carefully review this Policy, as it will help you understand the scope of its application and make an informed decision regarding the provision of your Personal Data. In case of disagreement with these terms, the Client should refrain from using the services provided by the Operator. It is recommended to periodically review this page for updated information on the Operator’s Policy.

"Platform" — the aggregate of functional capabilities of the "Getcourse" software system used by the Operator to provide access to the Website content.
"Operator / Data Controller (EU/EEA)" — Svetlana Manakova OÜ, Registry Code: 17371657, Harju maakond, Tallinn, Kesklinna linnaosa, Tuukri tn 19-202, 10120, Estonia.
"Operator / Data Controller (Other regions)" — Individual Entrepreneur Svetlana Igorievna Manakova, Identification Number 100330704, Georgia, 0108, City Tbilisi, 3 Lesia Ukrainka St.
"Client" / "User" — an individual who has accepted the terms of the Offer Agreement to gain free or paid access to the Site and Platform of the Operator.
"Site" — an automated information system on the Internet accessible through the following domain address: https://radiomanakova.net.
"Product" — digital content placed on the Platform, access to which is provided by the Site and Platform for the purpose of educating the Client/User.
"Personal Data" — information about Users that can be used directly or indirectly to establish their identity (name, address, phone number, date of birth, email, etc.). Data that cannot be used to identify the User, such as anonymized, de-identified, technical data, and other information, do not fall under Personal Data.
"Processing of Personal Data" — Любой процесс, который включает в себя персональные данные Пользователя.
"Privacy Policy" (abbreviated as "Policy") — a document regulating the policy of collecting, processing, and storing Personal Data by the Operator, available at: https://radiomanakova.net/privacy_policy
"GDPR" — Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).

1. INTRODUCTION. ABOUT THE PERSONAL DATA PROCESSING POLICY
1.1. This Privacy Policy is issued and applied by the Operator in accordance with the GDPR for users in the EU/EEA, as well as in accordance with applicable data protection laws of other states for users in other regions.
1.2. This Policy establishes the procedure and conditions regarding the collection, processing, and storage of Personal Data, setting forth provisions aimed at compliance with international legislation.
1.3. Clients give their consent to the processing of Personal Data in accordance with this Policy when registering a Personal account on the Operator’s Site, as well as by filling out forms on the Site and through payment for access to the content and online courses.

2. BASIC PROVISIONS
2.1. Purpose of Personal Data Processing: The purpose of processing Personal Data is to provide services by the Operator upon the request of the data subject (Client).
2.2. The Operator processes Personal Data for the following purposes:
  • Provision of services according to the contract (Offer Agreement) concluded between the Operator and the Client.
  • Establishment of feedback with the Client, including notifications regarding services, processing requests, and applications.
2.3. Processing Principles:
  • Legality, fairness, and transparency in the Operator’s activities.
  • Accuracy and sufficiency of Personal Data for processing purposes.
  • Processing only those data that meet the stated purposes.
  • Storage of Personal Data in a form that allows identifying the data subject for no longer than required by the purposes of processing.
  • Ensuring the recording, systematization, and storage of data using secure databases.
3. TECHNICAL INFORMATION AND CATEGORIES OF DATA
3.1. The Operator processes the following Personal Data:
  • Name, surname, and patronymic (if applicable).
  • Phone number and Email address.
  • Account and personal cabinet data for communication within the Site and Platform.
  • Image (photograph) placed by the User in their account.
  • Other information provided by the User in the process of obtaining services.
3.2. Technical Information: The Operator collects technical information that does not constitute Personal Data, such as:
  • IP address, device type, and browser information.
  • Activity on the Site (visited pages, date/time of transitions).
  • Automatically transmitted data in an anonymized form.
3.3. Cookies: The Operator uses cookies for technical and functional purposes to simplify the use of the Site. Cookies are small text files stored on your device. You can disable cookies in your browser settings, though this may limit some Site functions.

4. METHODS AND CONDITIONS OF PROCESSING
4.1. Processing Methods: Personal Data is processed using automation tools and, where necessary, without automation, in accordance with applicable laws and the GDPR.
4.2. Security Measures: The Operator applies legal, organizational, and technical measures to ensure the security of Personal Data.
4.3. Platform: The Operator provides services using the GetCourse platform. The Site uses the HTTPS protocol to enhance security and protect information.
4.4. Non-Disclosure: The Operator does not disclose Personal Data to third parties without the consent of the data subject, except for cases provided by law or as necessary to provide the services (e.g., payment processing via Stripe).
4.5. Third-Party Processors: To provide services, the Operator engages the following processors:
  • GetCourse Kazakhstan LLP (Platform infrastructure). BIN: 220 340 029 013. Kazakhstan, Almaty city, Bostandyk district, Nursultan Nazarbayev Avenue, house 189/2, sq. 1, postal code 50 013
  • Selectel (Hosting and server services).
  • Stripe (Payment processing and fraud prevention).

5. ENSURING THE SECURITY OF PERSONAL DATA
5.1. The Operator takes necessary organizational and technical measures to protect Personal Data from unauthorized access, destruction, alteration, or copying.
5.2. Data Protection Measures include:
  • Appointment of a person responsible for data protection.
  • Organization of limited access for employees to Personal Data.
  • Internal control and regular security audits.
5.3. Rights of Data Subjects: Users have the right to access, rectify, or delete their Personal Data, as well as the right to withdraw consent at any time by contacting: direct@radiomanakova.com.

6. RESPONSIBILITY OF THE PARTIES
6.1. In the event of the Operator’s failure to fulfill its obligations, the Operator is responsible for losses incurred by the Client due to unauthorized use of Personal Data, in accordance with applicable legislation.
6.2. The Operator is not responsible if confidential information became public domain before its disclosure or was disclosed with the consent of the Client.

7. CONTACT INFORMATION

EU/EEA Region (Merchant of Record):
Svetlana Manakova OÜ
Registry Code: 17371657
Address: Harju maakond, Tallinn, Kesklinna linnaosa, Tuukri tn 19-202, 10120, Estonia
E-mail: direct@radiomanakova.com

Other Regions:
Individual Entrepreneur Svetlana Manakova
Identification Number: 100330704
Address: Georgia, 0108, City Tbilisi, 3 Lesia Ukrainka St.
E-mail: direct@radiomanakova.com
8. ADDITIONAL TERMS
8.1. The Operator has the right to make changes to this Policy without the consent of the Client.
8.2. The new Policy comes into effect from the moment it is posted on the Website.
8.3. The current version of this Policy is always available at: https://radiomanakova.net/privacy_policy