March 1, 2022
Below is a brief summary of key aspects of our Policy. More details are available by
clicking through to the specific sections listed below.
- Website Visitors: We log usage data about your visit, including cookies and your IP address
- Visitors who register to purchase our products and services:
- We use STRIPE to collect payment for your purchases which requires providing personal and financial information needed to complete an online purchase such as name and billing address.
- We also collect and use demographic and professional information needed too fulfill your purchase requests, to enhance your user experience, are for our legitimate business interests, and/or are required by law. We do not collect any GDPR Special Categories of Personal Data.
- By registering to purchase from our Website, you agree to our use of your information, including sharing with 3rdparties, as necessary to fulfill your order.
- We may also send emails announcements about new products, services, or features. As required, we will ask for your consent before sending messages through third parties. We also provide the option to opt out of these messages.
- We do not share or sell your personal information with third parties for their direct marketing purposes.
- We receive data to monitor and analyze visits to our website, such as Google Analytics.
- You have specific rights about our handling of your data; See Section IX for details
- All questions about this Policy should be directed to email@example.com.
TABLE OF CONTENTS
- Section I: Important Information & Who We Are
- Section II: The Data We Collect About You
- Section III: How Your Personal Data is Collected
- Section IV: How We Use Your Personal Data
- Section V: Disclosures of Your Personal Data
- Section VI: International Transfers
- Section VII: Data Security
- Section VIII: Data Retention
- Section IX: Your Legal Rights
- Section X: Glossary
SECTION I: IMPORTANT INFORMATION ABOUT WHO WE ARE
10325 Kensington Pkwy, #334
Kensington, MD 20895
Telephone: +1 (718)-532-7632
You may be able to file a complaint about us based on your applicable national or state laws (see Section IX: Your Legal Rights, Part E for more details). We would, however, appreciate the chance to deal with your concerns before you approach your data protection authority, so please contact us first.
It is important that the personal data we hold about you is accurate and current. Our website provides information about how to update your profile information in our system.
SECTION II: THE DATA WE COLLECT ABOUT YOU
- Personal Data. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, institutional affiliation, and job title
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Profile Data includes your username and password, purchases or orders made by you, feedback, your research interests, and professional degrees
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any GDPR-defined Special Categories of Personal Data about you, such as your race or ethnicity, religious or philosophical beliefs, political opinions, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offenses.
- Failure to Provide Personal Data. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us. However, we will notify you if this is the case at the time.
SECTION III: HOW YOUR PERSONAL DATA IS COLLECTED
Data Collection Methods. We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for our products or services;
- Create an account on our website;
- Subscribe to our service or publications;
- Request marketing to be sent to you;
- Respond to a promotion or survey; or
- Give us feedback or contact us.
- Third parties sources. We may receive personal data about you from various third party sources who transfer information about your activity on our website in accordance with their privacy policies. These include:
- Google Analytics: This service tracks and reports on traffic to our website. of Visit the Google website for details about opting-out their tracking activites.
- Google Ads: We may use Googles’s remarketing service to customize and display ads to you on third party websites after you have visited our site. Please see the Google website for details about how to opt-out of this service.
- Email marketing: We may in the future use your information to contact you in the future about new products and services or other relevant information. Prior to conducting this type of marketing, we will modify this Policy to list specific vendors that we will use for this purpose.
SECTION IV: HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where we need to perform the contract we are about to enter into or have entered into with you, where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, or where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we rely on our lawful need to perform or contract, legal obligation and/or legitimate business interest as the legal bases for processing your personal data although we will get your consent, when required, such as before sending third party direct marketing communications to you via email at firstname.lastname@example.org . You have the right to withdraw consent to marketing at any time by contacting us.
- Purposes for which We will Use Your Personal Data. We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set forth in the table below.
|Purpose/Activity||Type of Data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer/subscriber||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you, which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products or services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
- Marketing. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
- Promotional Offers from Us. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (i.e. marketing).
You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
- Third-Party Marketing. As required, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We also provide everyone the option to opt-out of these marketing efforts.
- Opting Out. You can ask us or third parties to stop sending you marketing messages at any time by sending us an email at email@example.com.
When you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, experience or other transactions.
- Change of Purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please know that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
SECTION V: DISCLOSURES OF YOUR PERSONAL DATA
- Internal Third Parties as listed in the Glossary.
- External Third Parties as listed in the Glossary.
- Security of Your Personal Data. We will require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
SECTION VI: INTERNATIONAL TRANSFERS
SECTION VII: DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. However, we cannot gurantee absolute security of your information. In addition, we limit access to your personal data to those employees, agents, contractors or other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
SECTION VIII: DATA RETENTION
- In General. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
- How We Determine the Data Retention Periods. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
- Our Retention Periods in Detail. All data will be kept while You remain an active subscriber with Us and for a period of at least six (6) years thereafter.
- Legal Requirements. By law we have to keep basic information about our customers, including Contact, Identity, Financial and Transaction Data, for six (6) years after they cease being customers for tax and liability purposes.
- Miscellaneous. In some circumstances you can ask us to delete your personal data. See Section IX below for further information. Additionally, in some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
SECTION IX: YOUR LEGAL RIGHTS
- Rights of Data Subjects (You). Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights. You have the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to the processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Withdraw Consent.
If you wish to exercise any of the rights set forth above, please contact us by email at firstname.lastname@example.org.
- No Fee Typically Required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights); provided, however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- What We May Need from You. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- Time Limit to Respond. We aim to respond to all legitimate requests within one (1) month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- Complaints to Your Legal Data Authority. Users of our website and/or customers from European countries that follow GDPR can file complaints about GDPR violations with the their country’s data protections authority. Users from other countries can file complaints based on their country’s applicable laws. California users can file complaints about CCPA violations with the California’s Attorney General’s Office.
SECTION X: GLOSSARY
- LAWFUL BASIS.
- Legitimate interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service or product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of Contractmeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal obligationmeans processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- THIRD PARTIES.
- Internal Third Parties: We do not have any at this time.
- External Third Parties:
- Stripe Business Services
- EdTek Services which manages our courses and associated learning management System
- ArcPro Media which manages our website and our Google analytics analyses
- YOUR LEGAL RIGHTS. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data or Right to be forgotten. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request a transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.