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Privacy Policy

This Policy describes the rules according to which Coursy processes the personal data of any person using coursy.io.

1.          Definitions

In this Policy, the following terms have the following meanings:

Course Results

the data specified in Section 4.1.2

Course Manager

Your employer or any other person or entity with whom Coursy has entered into the License Agreement allowing the Course Manager and You use coursy.io

Coursy

Coursy Technology OÜ, a company established under the laws of Estonia, registry code 14699729, address Järvevana tee 9 Tallinn Harjumaa 11314 Estonia

coursy.io

the online training software “Coursy” available on the coursy.io website

GDPR

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data

License Agreement

a License Agreement between the Licensor and the Course Manager allowing the Course Manager and You use coursy.io

Licensor

Coursy Technology OÜ

Other Data

the data specified in Section 4.1.4

Personal Details

the data specified in Section 4.1.1

Policy

this Privacy Policy

Terms

the Terms and Conditions available on the coursy.io website governing Your use of coursy.io

Usage Data

the data specified in Section 4.1.3

2.          How does Coursy relate to my personal data?

In connection with the Course Manager’s and/or Your use of coursy.io, Your personal data may end up on coursy.io’s servers. Your data may be entered into coursy.io by Yourself, by the Course Manager or generated by Your use of coursy.io. As Your personal data ends up on coursy.io’s servers and coursy.io is run by Coursy, Coursy becomes a processor of Your personal data.

3.          Who is the data controller of my personal data on coursy.io?

3.1.      The data controller of Your personal data on coursy.io is the Course Manager. You may find the contact details of the Course Manager on coursy.io. If You cannot find the contact details of the Course Manager on coursy.io You may ask for them by sending an e-mail at privacy@coursy.io.

3.2.      To the extent, in which Coursy processes Your personal data so as to gain a better understanding of users’ preferences and how users interact with coursy.io, the data controller of Your personal data is Coursy –       Coursy Technology OÜ, a company established under the laws of Estonia, registry code 14699729, address Järvevana tee 9 Tallinn Harjumaa 11314.

4.          Which categories of my personal data are processed on coursy.io?

4.1.      The personal data which may be processed on coursy.io includes the following:

4.1.1.         “Personal Details” – Your personal details, including Your name, date of birth, gender, e‑mail address, phone number, level of education and employment;

4.1.2.         “Course Results” – Your results and other statistics regarding the courses taken on coursy.io;

4.1.3.         “Usage Data” – data about Your use of coursy.io, including Your login and logout times, the browser which You use for visiting coursy.io, the modules used on the browser which You use for visiting coursy.io, the IP address, operating system and other details of the devices from which You access coursy.io;

4.1.4.         “Other Data” – any other data which You, the Course Manager or any other coursy.io user has stored on coursy.io-s servers or otherwise forwarded to Coursy and/or the Licensor, including any feedback and other communication held via coursy.io.

5.          Why does Coursy process my personal data?

5.1.      Coursy processes Your personal data:

5.1.1.         so as to enable You and the Course Manager the use of coursy.io;

5.1.2.         so as to gain a better understanding of users’ preferences and how users interact with coursy.io.

6.          Which of my personal data is processed for which purposes?

6.1.      Coursy processes all of Your personal data so as to enable You and the Course Manager the use of coursy.io.

6.2.      Additionally, Coursy may processes Your Usage Data and Course Results so as to gain a better understanding of users’ preferences and how users interact with coursy.io.

6.3.      Upon processing Your personal data for gaining a better understanding of users’ preferences and how users interact with coursy.io, Coursy does not analyse Your personal data individually. Instead, Your personal data is part of a large mass of data revealing general trends.

7.          What are the grounds on which Coursy processes my personal data?

7.1.      Coursy processes Your personal data on behalf of the Course Manager in accordance with the License Agreement. The grounds on which the Course Manager is entitled to process Your personal data on coursy.io may, among other grounds, derive from Your employment or other relation with the Course Manager under GDPR art 6(1)(b), including Your obligation, as the Course Manager’s employee, to take courses on coursy.io and/or the Course Manager’s legitimate interest, as Your employer, to process Your personal data in connection with the courses on coursy.io in accordance with GDPR art 6(1)(f).

7.2.      To the extent in which Coursy processes Your personal data so as to gain a better understanding of users’ preferences and how users interact with coursy.io, Coursy processes Your personal data on behalf of itself under GDPR art 6(1)(f), as Coursy has sufficient legitimate interests to process such data for such purposes.

8.          Does Coursy need my consent for processing my personal data on coursy.io?

No, Coursy does not need Your consent for processing Your personal data on coursy.io. If Coursy would want to process Your personal data for any new purpose, which would require Your consent, then Coursy will not process Your personal data for such new purpose, before Coursy has received Your consent.

9.          Does the Course Manager need my consent for processing my personal data on coursy.io?

The Course Manager may need Your consent for processing Your personal data on coursy.io, depending on the specific circumstances, including the personal data which the Course Manager collects and processes on coursy.io, the operations which the Course Manager conducts with Your personal data on coursy.io and Your relationship with the Course Manager.

10.       Am I obliged to provide Coursy my personal data under applicable law?

No, You are not obliged to provide Coursy Your personal data under applicable law. However, You may be obliged to provide Coursy Your personal data in accordance with any employment or other agreement between You and the Course Manager.

11.       Can I use coursy.io without providing Coursy my personal data?

No, You cannot use coursy.io without providing Coursy Your personal data. Using coursy.io requires processing Your personal data.

12.       Does Coursy use my personal data for profiling or any other automated decision making?

No, Coursy does not use Your personal data for profiling or any other automated individual decision‑making.

13.       Who else, besides Coursy may access my personal data?

The Course Manager has access to almost all of Your personal data stored on coursy.io. Coursy may share Your personal data with any entities belonging to the same group as Coursy. Such entities may process Your personal data only for the purposes set out in this Policy and otherwise in accordance with this Policy.

14.       Where does Coursy store my personal data?

Coursy stores Your personal data on servers within the European Economic Area. Coursy shall not process Your personal data outside European Economic Area.

15.       How long does Coursy store my personal data?

Coursy stores Your personal data for such period as agreed with the Course Manager. After the expiry of such period, Coursy will delete Your personal data or anonymize Your personal data in such way that they can no longer be related to you.

16.       What are my rights in connection with my personal data?

16.1.   In connection with processing Your personal data on coursy.io, You have the rights of a data subject stipulated in the GDPR, including the right to information, the right to access, the right to rectification, the right to erasure, the right to restriction, the right to data portability and the right to object.

16.2.   As the controller of Your personal data processed on coursy.io is the Course Manager, You can exercise Your rights stipulated under the GDPR by forwarding Your request to the Course Manager.

16.3.   To the extent in which You wish to exercise Your rights in connection with Coursy processing Your personal data for the purpose of gaining a better understanding of users’ preferences and how users interact with coursy.io, You may forward Your requests to Coursy at privacy@coursy.io

17.       How may this Policy be amended?

Coursy may amend this Policy from time to time.

18.       Where can I find the valid version of this Policy?

The valid version of this Policy is available on the coursy.io website at any given time.

19.       Where can I file inquiries, request and complaints in connection with processing my personal data?

19.1.   In case You have inquiries, requests or complaints regarding the processing of Your personal data, You may forward them to the Course Manager.

19.2.   To the extent in which Your inquiries, requests or complaints concern processing Your personal data by Coursy for the purpose of gaining a better understanding of users’ preferences and how users interact with coursy.io, You may forward them to Coursy at privacy@coursy.io

19.3.   In case You have complaints regarding the processing of Your personal data, You may file them with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or the Data Protection Authority of the state in which You have permanent residence.

20.       Where can I reach Coursy’s data protection officer?

You may contact Coursy’s data protection officer at privacy@coursy.io.

21.       Does coursy.io use cookies?

Yes, the coursy.io website uses cookies.

22.       What are cookies?

A cookie is a small text file, which is placed automatically on Your device by Your Internet browser. Cookies are used to collect information about Your use of a website in order to personalise Your experience of using that website. For example, cookies may help a website remember certain preferences You have selected on the website, such as Your language preferences.

23.       What types of cookies does coursy.io use?

23.1.   The coursy.io website may use:

23.1.1.      session cookies (cookies which expire once You close Your web browser) to provide You with a more personal and interactive experience on coursy.io;

23.1.2.      persistent cookies (cookies which stay on Your computer or mobile device until You delete them) also to provide You with a more personal and interactive experience on coursy.io;

23.1.3.      first-party cookies (cookies which are served to Your computer or mobile device by Coursy) to recognise Your computer or mobile device when You revisit coursy.io;

23.1.4.      third-party cookies (cookies which are served by other service providers on coursy.io) to be used by other service providers to recognise Your computer or mobile device when You visit other websites.

23.2.   In addition to cookies, coursy.io may use pixel tags (or web beacons) for the purpose of monitoring the use of coursy.io (without processing any personally identifiable information).

24.       How can I disable cookies?

You may disable cookies being stored on Your device by changing Your browser settings. However, as a result, coursy.io may not function properly and/or some features may not be available to You.

25.       Where can I file inquiries regarding the use of cookies on coursy.io?

If You have any questions regarding the use of cookies on coursy.io, then You may forward them to Coursy at privacy@coursy.io.