- Processing of Personal Data,
- General Rules,
- Data Confidentiality,
- Data Subject's Rights.
Personal Data We Process
Personal data refers to any information relating to an identified or identifiable natural person ("Personal Data").
We may collect data or ask you to provide certain data when you visit and use our websites, products and services. The sources from which we collect Personal Data include:
- Data collected directly from you or your device relating to an identified or identifiable natural person ("Data Subject"), and may include direct identifiers such as name, address, email address, age, phone number, school where your child studying and/or indirect identifiers such as login account number, login password, marketing preferences, country, version of browser, diagnostic information about the PC or mobile such as video adapter and video driver, time zone, your English level, IP address.
We do not process any special categories of personal data.
If we link other data relating to you with your Personal Data, we will treat that linked data as Personal Data; and
We may also collect Personal Data from trusted third-party sources such as distributors, our partners, resellers, app stores, contact centers, and engage third parties such as marketing, survey, analytics.
Account Data includes information needed to set up and customize an account, such as your email address and username, name, and information connected with our services. For some of our products and services creating an account is necessary. See below an example of Account Data and what we use it for:
What we use it for Email address
To send you communications regarding your course and support Username
To manage your account and facilitate your login into the service phone number
For our customer care specialists in order to call, send messages (via Whatsapp) for asking additional information (preferable lessons time, public school where the child is studying, address of living, etc), informing on new services.
Product and Service Data includes information about the Programming School`s product and service usage and events relating to use of our product and service by you such an audio recordings of phone calls and conversation with customer (students and representatives), usage statistics, IP address.
Why We Process Your Personal Data
We use your Personal Data for the following purposes and on the following grounds:
On the basis of fulfilling our contract with you or entering into a contract with you on your request, in order to:
- Process purchase of our products or services from us, our partners or our trusted third- party service providers' online stores;
- Provision the access and performance of the product or service;
- Keep our products or services up-to-date, safe and free of errors, including implementation of new features;
- Verify your identity and entitlement to paid products or services, when you contact us for support or access our services;
- Process your purchase transactions;
- Update you on the status of your orders;
- Understand your educational progress;
- Manage your subscriptions and user accounts; and
- Provide you with technical and customer support.
On the basis of your consent, in order:
- To offer Programming School`s products and services that best match your needs;
- To provide the relevant content and advertisement;
- Subscribe you to a newsletter;
We will always ask for your consent before any processing that requires it;
You may withdraw your consent at any time by simply informing us that you wish to do so using [email protected]
On the basis of legal obligations, we process your Personal Data when it is necessary for compliance with a legal tax, accounting, anti-money laundering, legal order, or other obligation to which we are subject.
On the basis of our legitimate interest we will use your Personal Data to:
- Communicate about possible security, privacy and performance improvements and products that supplement or improve our purchased products and to optimize the content and delivery of this type of communication;
- Evaluate and improve the performance and quality of our products, services and websites, develop new products and services, and to understand usage trends, and analyze user acquisitions, conversions, your academic progress and campaigns;
- Allow interoperability within our applications;
- Secure our systems and applications;
- Allow effective performance of our business by ensuring necessary internal administrative and commercial processes (e.g. finances, controlling, business intelligence, legal & compliance, information security etc.); and
- Establish, exercise or defend our legal rights.
- For the above mentioned processing operations, we have balanced your interests against our interests. In any case, you have the right to object, on grounds relating to our particular situation, to those processing operations.
Product, Service and business improvement
We have a legitimate interest to use necessary Personal Data to understand user conversions, acquisitions and campaign performance through various distribution channels, and users' interactions with our products and services because these analytics help us improve functionality, effectiveness, security and reliability of our products, services and business activities and develop new products and services. This processing includes using third-party tools.
How We Process Your Personal Data
We continuously monitor for, minimize, disconnect and remove all direct identifiers during the normal performance of the products and services.
No Automated Decision-Making, Including Profiling
We do not take any decisions involving the use of algorithms or profiling that significantly affects you.
How We Disclose Your Personal Data
If you opt to pay for use of our services, we will use a third-party payment processor to take payment from you. These third parties are properly regulated and authorized to handle your payment information and are prohibited from using your Personal Data for any other purposes other than arranging these services for us. However, they are independent controllers of your data with their own responsibility.
These are our long-term payment processors:
USA Paypal https://www.paypal.com/en/webapps/mpp/ua/privacy-full
US, Ireland Google Play Store (for mobile apps) https://policies.google.com/privacy
US, Ireland Apple Store (for mobile apps) https://www.apple.com/legal/privacy/
Such service providers may include in particular contact centers, professional consultants (including for defense or exercise of our rights), and marketing/survey/analytics.
Cookies are small text files that can be used by websites to make a user's experience more efficient. You can find more about cookies here.
How You Can Disable Cookies
What are cookies and How We use them
We use different types of "cookies":
- user input cookies;
- authentication cookies;
- cookies storing your preferences and settings;
- performance cookies;
- third party advertising cookies;
- first party analytics cookies;
- social network tracking cookies.
Analytics Tool Providers
We use analytical tools, including third-party analytical tools, which allow us to, among other things, identify potential performance issues with our products and services, improve their stability and function, understand how you use our products and services, and website, so that we can optimize and improve your user experience, as well as evaluate and improve our services.
While we generally prefer using our own analytical tools, we sometimes need to partner with other parties, which have developed and provide us with their own tools and expertise. Below, we list these partners and tools and their privacy policies.
In certain instances, it may be necessary for us to disclose your Personal Data to public authorities or as otherwise required by applicable law. No Personal Data will be disclosed to any public authority except in response to:
- A subpoena, warrant or other process issued by a court or other public authority of competent jurisdiction;
- A legal process having the same consequence as a court-issued request for data, in that if we were to refuse to provide such data, it would be in breach of local law, and it or its officers, executives or employees would be subject to liability for failing to honor such legal process;
- Where such disclosure is necessary for us to enforce its legal rights pursuant to applicable law; or
- A request for data with the purpose of identifying and/or preventing credit card fraud.
Cross-Border Transfers of Personal Data among Programming School and to Third-Party Vendors
We are a global business that provides its products and services all around the world.
At the same time, when we transfer Personal Data outside of the EEA, we always make sure to put in place appropriate and suitable safeguards, such as standardized contracts approved by the European Commission, and to ensure that your data remains safe and secure at all times and that your rights are protected.
How We Protect Your Personal Data
We maintain administrative, technical, and physical safeguards for the protection of your Personal Data.
Access to the Personal Data of our users is limited to authorized personnel who have a legitimate need to know based on their job descriptions. In the case of third-party contractors who process personal information on our behalf, similar requirements are imposed. These third parties are contractually bound by confidentiality clauses, even when they leave.
We store your personal information in our database using the protections described above using appropriate technical measures.
Proportionality and Minimization
We strive to collect no more Personal Data from you than is required by the purpose for which we collect it. This, in turn, helps reduce the total risk of harm should data loss or a breach in security occur: the less data we collect, the smaller the overall risk.
We have products and services designed specifically to assist you as a parent by providing child online education features. In such cases, we will only collect and process Personal Data related to any child under 16 years of age, which you choose to disclose to us or otherwise instruct us to collect and process.
Our storage and retention of your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. 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 requirements.
In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
We will hold your Personal Data on our systems for the following periods:
- For Billing Data, for as long as we have a legal obligation or for our legitimate interests in establishing legal rights;
- For Account Data, for as long as you maintain your account;
- For Product and Services Data, only as long as necessary for the purposes of a particular product or service. We use rolling deletion periods which means we regularly delete collected data in the given periods starting from the collection of that respective data.
We store your data on secure servers in the European Economic Area (EEA).
In all cases, we follow generally accepted standards and security measures to protect the personal data submitted to us, both during transmission and once we receive it.
Also, we inform that you have certain rights regarding the personal data we store:
- right to request access to your personal data from Programming School,
- right to rectification of your personal data if inaccurate (You also have the right to have incomplete personal data amended),
- right to request erasure of your personal data,
- right to request restriction processing of your personal data,
- right to object to processing as well as
- right to data portability. Right to complain. You have the right to contact the data protection authority of your country in order to lodge a complaint against our data protection and privacy practices.
The right to deactivate cookies. If you wish to restrict or block all the cookies which are set by our websites, please use the tool available on the particular website (if applicable), or refer to the Help function within your browser to learn how to manage your settings within your browser.
If you wish to exercise these rights, you may at any time directly contact us [email protected]
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you consider that the processing of personal data relating to you infringes applicable data protection law, you have the right to lodge a complaint with the competent supervisory authority at any time. Which supervisory authority has competence for your complaint can depend on the country where you reside.
Residents of the Russian Federation
We collect and process Personal Data on the territory of the Russian Federation in strict compliance with the applicable laws of the Russian Federation.
We collect and process Personal Data (including sharing it with third parties) only upon the consent of the respective individuals, unless otherwise is provided for by the laws of the Russian Federation. You will be asked to grant your consent by ticking the respective box / or clicking "I accept" button or through similar mechanism prior to having access to the site, and/or when submitting or sharing the Personal Data we may request. We collect and use your Personal Data only in the context of the purposes indicated in the consent to processing of Personal Data.
We (directly or through third-party contractors specifically authorized by us) collect, record, systematize, accumulate, store, actualize (update and amend), extract Personal Data of the Russian Federation citizens with the use of databases located on the territory of the Russian Federation, except as otherwise permitted by Russian data protection legislation. We may process Personal Data of Russian citizens using databases located outside of the Russian Federation subject to compliance with Russian data protection legislation.
We undertake all the actions necessary to ensure security of your Personal Data.
You are legally entitled to receive information related to processing your Personal Data. To exercise this right, you have to submit a request to contacts indicated below in the Contact Us section.
You have the right to revoke the consent at any time by sending us an e-mail at contacts indicated below in the Contact Us section. Once we receive the revocation notice from you, we will stop processing and destroy your Personal Data, except as necessary to provision the contract or service to you. However, please note once you have revoked your consent, we may not be able to provide to you the products and services you request, and may not be able to ensure proper work of our products.
We do not transfer your Personal Data to the countries that under Russian law are not deemed to provide adequate protection to the individuals' rights in the area of data privacy.
We do not offer, sell or otherwise make available our products or services that have access to, collect and process (or allow us to do the same) Personal Data of third parties in the Russian Federation without the consent of such third parties.
If any provisions of this Policy contradict the provisions of this section, the provisions of this section shall prevail.
California Privacy Rights
This section applies to California (USA) residents:
Categories of collected personal information
You can see all categories of collected personal information listed in the section Personal Data We Process.
Sources from which the personal information is collected
You can find information about the sources of data in the section Personal Data We Process.
Business or commercial purpose for collecting or selling personal information
You can find all purposes of processing your personal information listed in the section Why We Process Your Personal Data.
Categories of third parties with whom the business shares personal information
You can find all categories of recipients of personal information listed in the section How We Disclose Your Personal Data. Programming School does not and will not sell (as such term is defined in the California Consumer Privacy Act) your personal information we collect without providing a right to opt out or your direct permission. See more about your right to opt out of sale below.
You have the right to:
- know what personal information is being collected about you;
- know whether your personal information is sold or disclosed and to whom;
- say no to the sale of personal information (right to opt out);
- request deletion of your personal information; information will be deleted if no exception applies (including our right to defend our lawful interests);
- access your personal information; specific information shall be provided in a portable and, to the extent technically feasible, in a readily useable format but not more than twice in a 12-month period;
- equal service and price, even if you exercise your privacy rights (right to non-discrimination).
Under California Civil Code § 1798.83, we are required to disclose to consumers the following information upon written request: (1) the categories of personal information that we have disclosed to third parties within the prior year, if that information was subsequently used for marketing purposes; and (2) the names and addresses of all such third parties to whom such personal information was disclosed.
third-party advertising cookies stated in section Cookie.
Right To Opt Out Of Sale
If your personal information is subject for sale you have the right to opt out from that sale.
You will be asked for consent before your personal information will be sold to third party.
We respect your decision to opt out for at least 12 months before asking you again to authorize the sale of your personal information.
You can submit your requests using contacts indicated below in the Contact Us section. If you are a California resident under the age of 18, you may be permitted to request the removal of certain content that you have posted on our websites. We will verify your request by matching your email address and, if necessary, other information you provide in your request against the email address and other information we have in our system. You can also designate an authorized agent to exercise these rights on your behalf. We may require that you provide the authorized agent with written permission to act on your behalf and that the authorized agent verify their identity directly with us.
To exercise any of your rights, or if you have any other questions or complaints about our use of your Personal Data and its privacy, write our Privacy Team through the most convenient channel below:
We are registered as SIT Programming School AG, Vordergasse 59, 8200 Schaffhausen, Switzerland. You can always reach us by email at [email protected]
If you prefer, you can send paper mail to SIT Programming School AG, Vordergasse 59, 8200 Schaffhausen, Switzerland.