PRIVACY AND COOKIE POLICY

INTRODUCTION

Eduexpert sp. z o.o. (hereinafter: „Eduexpert”) wants to inform you about the ways we process your personal information. In this Privacy & Cookie Policy we explain what personal information we collect, use and disclose.

Personal information means any data relating to an individual who can be identified, directly or indirectly, based on that information. This may include information such as names, contact details, (online) identification data, online identifiers or other characteristics specific to that individual.

This Privacy & Cookie Policy applies when you visit our websites, solutions and other services, including events (as Google, Facebook, or Instagram) that refer or display a link to this Policy (“Services”). This Privacy & Cookie Policy may be supplemented or replaced by additional privacy statements or terms provided to you.

 

ABOUT US

The Controller of all personal data provided is EDUEXPERT SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ with its office in Toruń (address: Kociewska 22A Street, 87-100 Toruń) under REGON: 362646180, NIP: 9562313418.

If you wish to contact us in relation to questions to your personal information we refer you to the "How to contact us” section below.

 

WHAT PERSONAL DATA DO WE COLLECT?

The type of personal information we collect depends on your relationship with us and the Services we deliver to you. To that end, we may collect the following personal information about you:

  1. Name and contact details, such as, first and last name, email address, postal address, telephone number
  2. Work-related information, such as, job title and other employment or education information
  3. Account Credentials, such as, passwords and other security information for authentication and access
  4. Financial Information, such as, bank account, credit and debit card numbers for processing of payments
  5. Usage information, such as, behavioral information about how you navigate within our Services and which elements of our Services you use the most and information regarding the goods and/or services you wish to order, wish list, preferences, interest, etc. Other information shared by you through our websites, apps, web shops and other products.
  6. Computer, device and connection information, such as, IP address, browser type and version and location

 

HOW WE COLLECT PERSONAL INFORMATION?

We and our third-party service providers may collect personal information from the following sources:

  1. Direct Interactions, such as when you register for our Services or make a purchase
  2. Data from Third Parties, such as information on third-party websites or other information you may have made publicly available, or information provided by third party sources, including but not limited to government entities and data resellers
  3. Automated Tracking Technologies, such as information automatically collected about your interaction with our Services and websites using various technologies such as cookies, web logs and beacons and internet tags.

 

HOW WE USE THE PERSONAL INFORMATION?

The personal information collected is used for the purposes for which you have provided it, and might be further used for statutory or other legitimate purposes only. As an example, if you make use of our service contact form on our website, we will use the information you provided in the first place to respond to your service request. We might further use that information to improve the quality of our customer service process.

Lawfulness of the processing is one of the main principles relating to the processing of your personal information - we apply the following legal processing grounds:

  1. processing is necessary for the performance of a contract, or in order to take steps prior to entering into a contract;
  2. processing is necessary for the purposes of our legitimate interests - for example, to improve the quality of our products and Services;
  3. processing is necessary for compliance with a legal obligation to which we are subject, or that is otherwise lawful under the applicable data protection laws;
  4. with your given consent.

Depending on how you interact with us and the Service, we may use your personal information for the following purposes:

  1. Administering our relationship with you and our business, such as providing and managing your access to and use of our Services. This processing is necessary for the performance of a contract;
  2. Improving our Services and developing new products, such as inviting you to participate in surveys or to personalize your experience with our Services. This processing is necessary for the purposes of our legitimate interests;
  3. Marketing, such as providing you with marketing or advertising communications that we think you may be interested in. This processing is with your given consent or for our legitimate interests;
  4. Recruiting, such as assessing job applicants. This processing is in order to take steps prior to entering into a contract or with your given consent;
  5. Providing online communities, such as making chat rooms, forums, message boards, or news groups available to you. This processing is necessary for the performance of a contract or our legitimate interests. Please remember that any information disclosed in these forums is public. We encourage you to exercise caution when disclosing personal information in these forums, as this information is made available to other users. Do not disclose information in these public forums that might be considered confidential or proprietary or that you do not wish to be publicly available or that you are prohibited from disclosing.
  6. Other general business support purposes, including but not limited to, procurement, financial and fiscal management, risk and compliance management, and external reporting. This processing is necessary for compliance with a legal obligation to which we are subject or that is otherwise lawful under applicable data protection laws or for our legitimate interests.

 

SHARING YOUR PERSONAL INFORMATION?

To be able to provide you the best possible Services and further our business operations, we may share certain information internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your personal information externally. Parties we might share data with include:

  1. other Eduexpert’s affiliates or subsidiaries, e.g. for providing underpinning technology to support the Services we are delivering;
  2. our service providers, e.g. for managing or hosting services and/or underpinning technology for the Services we are providing;
  3. our business partners, to the extent you have purchased or expressed interest in a product or service of such a business partner, interacted with them or otherwise authorised the sharing of your personal information with such a business partner;
  4. subscribing, accrediting or professional organisations, e.g. for providing utilisation information to organisations that provide you with access to our Services and/or sharing tracking and redeeming credits for professional accreditation;
  5. organisations involved in business transfers, e.g. to a purchaser or successor entity in the event of a sale or any other corporate transaction involving some or all of our business;
  6. other parties, e.g. as needed for external audits, compliance, risk management, corporate development and/or corporate governance related matters; or
  7. governmental authorities and regulators, as required under the applicable law.

Whenever we share personal information internally or with third parties in other countries, we have appropriate safeguards in place in accordance with the applicable data protection laws, including as applicable the EU standard contractual clauses (SCCs). As required under the applicable law, third parties are required to use appropriate safeguards to protect personal information, and they can only access the personal information that is necessary for performing their specific tasks.

 

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Your personal information will be processed to the extent necessary for the performance of our obligations, and for the time necessary to achieve the purposes for which the information is collected, in accordance with our data retention policies and the applicable data protection laws. When we no longer need your personal information, we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it.

We inform you that:

 

  1. in case Eduexpert processes personal data on the basis of consent, the processing period lasts until the user withdraws this consent;
  2. where Eduexpert processes personal data on the basis of a legitimate interest of the Data Controller, the period of processing shall last until the aforementioned interest ceases to exist (e.g. the statute of limitations for civil law claims) or until the data subject objects to further such processing - in situations where such an objection is available under the law;
  3. where Eduexpert processes personal data because it is necessary to do so due to applicable laws, the periods of processing for such purposes shall be determined by such laws;
  4. in the absence of specific legal or contractual requirements, the basic data retention period for records and other documentary evidence produced during contract performance is a maximum of 10 years.

 

HOW WE PROTECT YOUR PERSONAL INFORMATION?

We have put in place an internal framework of policies and minimum standards across all our businesses to keep your data safe. In addition, we limit access to personal information by our employees, business partners, service providers and third-party service providers to a ‘need-to-know’ basis. More specifically and in accordance with the law, we take appropriate technical and organisational measures (policies and procedures, IT security and others) to ensure the confidentiality and integrity of your personal information and the way it is processed.

WHAT ARE YOUR RIGHTS?

We will honour your rights under the applicable laws.  To the extent provided under your local data protection laws, including the European data protection laws, your rights include the following:

  1. Right of access (‘an overview of your personal information’): the right to get an overview of your personal information that we process.
  2. Right to rectification (“correct your personal information”): if your personal information is inaccurate or incomplete, the right to ask us to rectify or complete your personal information.
  3. Right to erasure (“right to be forgotten”): the right to request that we delete your personal information to the extent permitted by the applicable law. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if the processing is necessary for the performance of a contract. In some cases, your personal information is necessary in order to provide the Services and if you do not provide such information to us then you may be precluded from accessing and using the Services or using certain Services features.
  4. Right to data portability (“transfer your personal information”): the right to ask us to transfer your personal information directly to you. This applies to certain personal information if processed by automated means and with your consent or based on a contract you have with us. On your request, and where technically feasible, we will transfer your personal information to another party of your choice.
  5. Right to restrict processing: the right to request that we restrict or stop the processing of your personal information held by us for a certain period of time, or for an indefinite period. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
  6. Right to object: the right to object to the processing of your personal information. The reasons for an objection should relate to your particular situation and be related to processing based on the legitimate interest condition. We will then no longer process the personal information, unless we can demonstrate compelling reasons otherwise. In certain circumstances, you have the unconditional right to object; for instance, in the context of direct marketing activities.
  7. Withdrawal of Consent:the right to withdraw your consent to the processing of your personal information at any time; for instance, after you consented to us keeping you informed about our Services, you have the right to withdraw this consent at any time.

To exercise your rights and/or for any other questions about the handling of your personal information, we refer you to the “How you can contact us” section below.

If you feel we are unresponsive or disagree with our data privacy practices, you can also file a complaint with your national Data Protection Authority.

THE USE OF COOKIES

We use cookies to optimize our websites and analyse website traffic. On occasion, if we have obtained your informed consent in advance, we may use third party cookies, notably social media plugins, to enable you to share ideas and information related to us instantly and for our own marketing purposes.

Cookies or similar techniques (referred to collectively as “Cookies”) are small text files or pixels, which might be stored on your computer or mobile device. Cookies may be necessary to facilitate website browsing and making it more user-friendly. Third party Cookies may collect information to analyse personal browsing behavior.

We may use Cookies belonging to one of the four categories listed below. Our website cookie banner facilitates you to manage your preferences for the non-mandatory cookie categories. The banner will also provide an overview of all cookies used under the categories.  

Necessary Cookies - these mandatory Cookies are needed for our websites to function properly.

Functional Cookies - these Cookies add additional functionality to our websites.

Performance Cookies - these Cookies support analytic services that help us to improve our website’s functionality and user experience.

Interest Cookies - these Cookies can be applied to collect insights, to issue personalized content and advertising on our own and other websites.

LINKS TO OTHER WEBSITES

Our websites may contain links to other Eduexpert’s or third-party websites, which may have privacy notices that differ from ours. We are not responsible for the collection, processing or disclosure of personal information collected through other websites.

We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website is subject to that website’s own policies. Please review the privacy notices posted on other websites that you may access through our website.

Eduexpert may provide you with additional or different privacy notices, in specific instances, on how your personal information is collected and used for a specific Service.

HOW CAN YOU CONTACT US?

In the event that you have any questions, objections or concerns about the content of this Privacy Policy or the way we process personal data, as well as complaints regarding these issues (although we hope it will not be necessary to file such complaints), please send an email with details of your complaint to Eduexpert sp. z o.o.: […]

Any complaints received will be reviewed and we will respond to them.

 Naturally, we do not limit contact with us and allow you to contact us directly at the headquarters of Eduexpert, as well as by letter or telephone contact. We provide the contact details below for this purpose:

[…]

Persons whose personal data is processed by Eduexpert also have the right to file a complaint to the supervisory authority, which is the President of the Office for Personal Data Protection.

In response to your request, we may ask you to confirm your identity, if applicable, and to provide information that will help us better understand your request. If we do not grant your request, we will provide a reason for our decision.

UPDATES OF THE POLICY

From time to time we may update this Privacy & Cookie Policy or any other specific privacy statement. When making changes to this Privacy & Cookie Policy, we will add a new date to this Privacy Statement.

This version is effective per 10.08.2023

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