PERSONAL DATA PROTECTION POLICY
Protection of your personal data is essential for Innovatrics, s.r.o. With regard to the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons in the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (“GDPR”), Innovatrics adopts this personal data protection policy relating to the website learn.innovatrics.com .
In this document you will learn:
I. Where to contact us for your personal data protection questions
II. How and why we process personal data when you
- visit our website;
- create an account on https://learn.innovatrics.com and use the Content and Services on the website learn.innovatrics.com.
III. How we use cookies
IV. What your rights are as a data subject
Our website and its sub-domains may contain links to third-party websites. These third party websites have their own personal data protection policies and we do not assume any responsibility for these policies. Before submitting any personal data to such third-party websites please make sure that you are thoroughly informed about their policies.
I. THE CONTROLLER AND ITS CONTACT INFORMATION
The Controller is Innovatrics, s.r.o., with its registered seat at: Pri vinohradoch 82, 831 06 Bratislava, Slovak Republic, ID No.: 36 280 712, registered in the Commercial Register of District Court Bratislava I, Section Sro, File No. 39481/B.
If you want to communicate with us about personal data protection issues, please use the following contacts:
- E-mail: [email protected]
- Mail – contact address: Innovatrics, s.r.o., Jarošova 1, 831 03 Bratislava, Slovak Republic.
II. HOW AND WHY WE PROCESS PERSONAL DATA
a) Visitors to our website
We do not process any personal data about visitors to our website that would enable us to individually identify a visitor to our website. Due to necessary technical reasons we automatically receive data from your browser when you visit our website, which theoretically allows for indirect identification of a natural person, specifically browser type and version, operating system used, URL of the previous website visited, IP address (this is deleted soon after you conclude your visit to our website), geographic location, visit length, pages viewed, and website navigation routes, server request time.
However, we do not associate this data with any specific person and we do not need to, nor do we link it with other data and therefore we cannot identify any specific person on that basis. We only collect information in aggregate and statistically analyse it to obtain information about where our website visitors come from, how long they stay or what information they usually search for, and so on, which allows us to manage, support, and improve our services.
Our website also uses cookies. More info on cookies is provided in part III. here below.
b) Users of our Services and Content (including creation of a user account)
The creation of a user account on the website https://learn.innovatrics.com/users/sign_up is necessary in order to view and download the Content from our website and/or using our Services as defined in the Terms of Use, which you can find here. Creation of the user account is voluntary. If you do so, you acknowledge and agree to this Privacy Policy. The provision of personal data is not your obligation, but if we do not have the data, we will not be able to provide and deliver the Content and/or Services to you.
What personal data we process:
For the creation of user account, we need from you the following personal information:
- first name and last name
- contact information – e-mail
- country of your residency
- login name and account password.
If you wish so, we can link your user account with your personal social media account. If you decide so, we will also process this information and please duly note that we will gain access to the information and data, which are published on the relevant social media which you chose. By clicking on the relevant logo of the social media, you agree with such processing and access.
Personal data relating to your user account will be processed for as long as the processing purpose persists. However, if you do not sign up for your account for 3 years, your personal user account information will be deleted.
If you order paid Services or if you make any purchase on our website, the credit card details and other payment information will be used for billing and payment purposes by Innovatrics and by third party payment services provider.
During your activity through your account, we can collect also other information, such as IP address from which you download the Content or access our Services, time when you download the Content or use the Services, the type of Content downloaded and Services used and also other relevant information.
In accordance with applicable data protection legislation, you must provide only true, accurate and actual information. In the case of any doubts on the accuracy of provided information we reserve the right not to create your account and delete all provided information.
We process your personal data for following reasons, purposes and based on the following legal basis:
- Forasmuch as you receive a licence related to the Content or you are given access to our Services, processing of your personal data is necessary for the performance of a contract (Article 6 par. 1 b) of GDPR).
- If you order paid Services or if you make any purchase on our website, the credit card details and other payment information will be used for billing and payment purposes by Innovatrics and by third party payment services provider. Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. The data, which are necessary to stored because it is prescribed by law, will be stored for the time period prescribed by these laws (bookkeeping, tax legislation).
- We can also process your personal data for the purposes of compliance with our legal obligation (e.g. tax laws, accounting laws), or where processing is necessary for the pursuing of our legitimate interests (e.g. if we apply or protect our rights, copyrights, in order to prove our compliance with applicable laws and regulations, in order to protect our confidential information, personal data, in order to ensure the security of our Services, in order to deal with your requests, correspondence, queries you send us through a web form, chat, e-mail etc.). The length of processing then depends on the time during which the said purpose exists. We point out that according to Article 21 of the GDPR you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on the basis of legitimate interest - Article 6(1) (f) of GDPR.
- We may use your e-mail to provide you – from time to time – with information about our news, biometrics, Services or new Content on website. We consider, that sending such information and notification by e-mail to the e-mail address registered on our website is our legitimate interest as per Article 6 (1) (f) of the GDPR. However, you always have the right to object at any time to the processing of your personal data for the purposes of direct marketing (regarding the application of this right, please refer to section IV hereof). Unsubscribing from our news will be available to you in any electronic communication or directly by clicking on a special link in each newsletter received. If you do not file an objection or unsubscribe from the newsletter, we may process the e-mail address for the aforementioned purposes for as long as your account on the website exists.
Processors and third parties
We may employ other companies and people to perform tasks on our behalf and we may need to share your information with them to provide Content or Services to you. Examples include web hosting provider and third party payment services provider.
Our Content and Services are hosted by Thinkific Labs Inc. (“Thinkific”), a Canadian corporation with offices at 369 Terminal Ave, Vancouver, British Columbia, V6A 4C4. They provide us with the online course creation platform that allow us to offer and sell our Content/Services to you. Your data will be stored through Thinkific’s data storage, databases and the general Thinkific application, on a secure server behind a firewall. For the provision of the services, this data may be transferred to other regions, including to Canada and the United States. Such transfers will be completed in compliance with relevant data protection legislation. For more insight, we refer also to Thinkific’s Terms of Service here https://www.thinkific.com/resources/terms-of-service/ and Privacy Statement here https://www.thinkific.com/resources/privacy-policy/ .
We use a third party payment processor such as Stripe or Paypal. We recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.
We may also release personal information when it is imposed by law or by official authority, to enforce or apply our Privacy Policy, Terms of Use, licences and other agreements, or protect the rights, property, or safety of Innovatrics, our employees, our users, or others. We never rent nor sell your personal information to third persons.
We do not use automated decision-making nor profiling.
Security
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
You must keep your personal login information confidential; you are solely responsible for all activities resulting from the use of your password and conducted through your account. Innovatrics is not liable for any harm caused by or related to the theft, misappropriation, disclosure, or unauthorized use of your personal login information.
III. COOKIES
Our website uses cookies (= information that our website’s server transfers to your computer). This information can be used to track your session on our website. Cookies may also be used to customize our website content for you as an individual. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer.
We use cookies to recognize your device and provide you with a personalized experience.
We also use cookies to attribute visits to our websites to third-party sources and to serve targeted ads from Google, Facebook, Instagram and other third-party vendors.
Our third-party advertisers use cookies to track your prior visits to our websites and elsewhere on the Internet in order to serve you targeted ads. For more information please visit https://www.networkadvertising.org/understanding-online-advertising.
Opting out: You can opt out of targeted ads served via specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page.
We may also use automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
How to block cookies. Most internet browsers allow cookies automatically. However, you can object to the use of cookies by restricting or blocking cookies yourself by changing your browser settings. You can also always delete the cookies that have already been saved in your browser. You can change your decision to block or restrict cookies yourself at any time.
For detailed information on how to manage or opt out of cookies on different types of web browsers, visit www.aboutcookies.org.
IV. YOUR RIGHTS
As a data subject under the GDPR, you have the right (i) based on a written (including electronic) request to access your personal data (in particular, to require confirmation of whether or not the data is being processed, the category of data being processed, the purpose of the processing, the source of the data, and the duration of retention); (ii) to repair the incorrect or supplement the incomplete data; (iii) to restrict the processing of data under Art. 18 of the GDPR (e.g., if the data is incorrect or processed illegally); (iv) to obtain personal data related to you and which you have provided to the Controller in a structured, commonly used and machine readable format, and the right to transfer such data to another controller under the conditions specified in Art. 20 of the GDPR; (v) to object in the cases referred to in Art. 21 of the GDPR - you can send the objection in writing to our address provided above ; (vi) to the erasure of data the purpose of the processing of which has ended or in the cases listed in Art. 17 of the GDPR.
If you believe that your rights are being violated in the processing of personal data or that there is a violation of the Personal Data Protection Act or the GDPR, you may file a motion to initiate personal data protection proceedings at the Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava 27, Slovak Republic; www.dataprotection.gov.sk.
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We may change or modify this PERSONAL DATA PROTECTION POLICY at any time, in particular with regard to legislative changes in the area of personal data protection which may be adopted in the future. If we do so, we will inform you accordingly.
April 2020