PRIVACY POLICY

(Personal Data Processing Policy of hand.made.school)

Version: 11 September 2026


1. Who We Are and What This Policy Covers

1.1. This Policy describes what personal data is collected by the website https://hand-made.school (including all language versions, promotional pages and the member area; the "Website"), what it is used for, who it is shared with, and what rights users have.

1.2. Data controller (operator): Individual Entrepreneur hand.made.school, Identification Number 345758192, Georgia, Batumi, Juli Shartava Avenue 32, apartment 87, represented by Dmitrii Sosnovskii (the "Operator", "we").

1.3. Contact for personal data matters: hand.made.school.online@gmail.com.

1.4. This Policy applies to all Website users regardless of their country of residence. Where the law of the user's country grants additional rights (for example, the EU General Data Protection Regulation — GDPR, the Law of Georgia on Personal Data Protection, or Federal Law No. 152-FZ of the Russian Federation), those rights apply in addition to this Policy.

2. What Data We Process

2.1. Data you provide yourself: name; e-mail address; country; when contacting support — the content of your request and the contact you write from (Telegram, WhatsApp, e-mail); when paying — the PayPal transaction ID, amount and date (payment details themselves — card number, account details — are not transferred to us and are processed by PayPal).

2.2. Data collected automatically: IP address, device and browser type, language, pages visited and time of visit, referral source, cookies and similar identifiers; in the member area — login and access activation logs.

2.3. Data you post in the study chat and community (messages, photos of your work) is visible to other chat participants.

2.4. We do not intentionally collect special categories of data (health, beliefs, etc.) or data of persons under 16. If you are under 16, do not use the Website without the consent of a parent or legal guardian.

3. Purposes and Legal Bases

Purpose Data Legal basis
Conclusion and performance of the agreement: order, payment, access activation, member area, mentor support name, e-mail, order and payment data, login logs performance of a contract (Offer at https://hand-made.school/ofert)
Service notifications: order confirmation, access e-mails, one-time login codes, notice of the end of the Membership term and renewal terms, important changes to terms e-mail performance of a contract
Issuing a fiscal document (cash receipt) in accordance with the legislation of the Russian Federation e-mail, payment amount and date compliance with a legal obligation
Responding to support requests contact and content of the request performance of a contract, legitimate interest
Informational and marketing messages about the School's courses, new lessons and promotions e-mail, name consent given when placing the order or submitting a form (https://hand-made.school/person); you can withdraw it at any time via the unsubscribe link in every e-mail
Analytics and Website improvement, advertising on social networks and search engines automatically collected data, cookies cookie consent / legitimate interest — depending on the country
Protection of rights: handling complaints, payment disputes, preventing licence violations all of the above legitimate interest, compliance with a legal obligation

4. Who We Share Data With

4.1. We share data only with those necessary for the operation of the Website and the provision of services:

  • Tilda Publishing — Website hosting, order forms, member area;
  • PayPal — payment processing;
  • Brevo — sending service e-mails and newsletters;
  • Google (Gmail, Google Analytics) — support e-mail and analytics;
  • Meta (Facebook, Instagram) — advertising pixels and ad analytics;
  • Telegram, WhatsApp — support and study chat;
  • YouTube / video hosting — hosting of lessons (when materials are moved in unforeseen circumstances).

4.2. These services process data on our instructions or as independent controllers under their own policies. Some of them are located outside Georgia and the EU (including in the USA and Russia). Transfers are made on the basis of a contract, standard contractual clauses or other safeguards provided by applicable law, or on the basis of your consent.

4.3. We do not sell personal data and do not share it with third parties for their own marketing.

4.4. Data may be disclosed upon a lawful request from public authorities or a court.

5. Special Provisions for Citizens of the Russian Federation

5.1. For the purposes of the legislation of the Russian Federation, the data required to issue a cash receipt (e-mail address, payment amount and date) is processed by Individual Entrepreneur Dmitrii Sosnovskii (INN 500912406805, OGRNIP 324508100564570) pursuant to the requirements of the legislation on cash register equipment. All other processing is carried out by the Operator specified in clause 1.2.

5.2. Where Federal Law No. 152-FZ applies to the processing of personal data of a citizen of the Russian Federation, such processing is carried out in compliance with its mandatory requirements.

6. Cookies

6.1. The Website uses cookies: necessary (Website operation, member-area login, language preference), analytical (Google Analytics and similar) and advertising (Meta Pixel and similar).

6.2. Necessary cookies are always set. Analytical and advertising cookies are set with your consent where required by law. You can disable cookies in your browser settings; disabling necessary cookies may prevent member-area login.

7. Retention Periods

7.1. E-mail address and information about the access purchased — for as long as the perpetual access to the materials is maintained, or until the account is deleted at your request.

7.2. Payment and accounting data (transaction ID, amount, date, data for the cash receipt) — for the periods established by tax and accounting legislation (as a rule, 5 years from the payment date), after which it is deleted.

7.3. Member-area login and access activation logs — 3 years from the date of the event.

7.4. Newsletter data — until you unsubscribe.

7.5. Support request data — 3 years from the date of the last request.

7.6. Automatically collected data — according to the settings of the respective services, as a rule no longer than 26 months.

8. Your Rights

8.1. You have the right to: obtain information about your data and a copy of it; correct inaccurate data; request deletion of data that is no longer needed for the purposes of processing and for which there is no legal ground for retention; restrict processing; object to processing based on legitimate interest; withdraw consent (unsubscribe via the link in an e-mail or by writing to us); receive your data in a machine-readable format; lodge a complaint with the data protection supervisory authority of your country.

8.2. To exercise your rights, write to hand.made.school.online@gmail.com from the e-mail address used for your order. We respond within the period required by applicable law: where Georgian or Russian personal data legislation applies — as a rule within 10 working days; where the GDPR applies — within one month; subject to extensions permitted by law. Deletion of data required for performance of the agreement or for statutory retention is possible only after the respective periods expire.

9. Security

9.1. Access to the member area is by a one-time code sent to your e-mail address; no passwords are stored. Data transmission on the Website is protected by encryption (HTTPS). Only the Operator and staff who need the data for their work have access to it.

9.2. You must keep access to your e-mail account secure, as it is used for login.

10. Changes to This Policy

10.1. We may update this Policy. The new version is published on the Website with the version date. In the event of material changes, we notify users by e-mail.

11. Language Versions

11.1. This Policy is published in English, which is the binding version. A Russian translation is available on request. In the event of discrepancies, the English version prevails to the extent permitted by applicable law.

12. Operator's Details

Individual Entrepreneur hand.made.school Identification Number: 345758192 Address: Georgia, Batumi, Juli Shartava Avenue 32, apartment 87 Represented by: Dmitrii Sosnovskii E-mail: hand.made.school.online@gmail.com Telegram: https://t.me/hand_made_school WhatsApp: https://wa.me/995593233592