Privacy Policy – Catalyfe

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Privacy Policy

1. Who are we? What do we do?
We are Catalyfe: a brand created, owned, managed and operated by Skillex OÜ. We have an internet-based learning platform, mostly focusing on alternate education (“Platform”). Our services (“Services”) are available on the Platform.
Our details are Skillex OÜ, registry code 14459110, Rävala Pst 4, Tallinn, 10145, Estonia e-mail: [email protected]

2. Whose personal data do we process?
We mainly process the personal data of our members and our customers and the representatives of our partners. As we use cookies, we also process the personal data of the visitors of our website skillex.com and catalyfe.com.

3. What personal data do we process?
We try to keep data collection as minimal as possible. However, we may collect and process the following personal data:
(3.1). personal information, such as name, gender, date of birth, nationality, citizenship, city of living, email;
(3.2)  personal information of the representatives of our partners, such as name, job title, position, email, nationality, membership package type, user ID;
(3.3)  document details, such as the name on the document, picture of the document, issuing country, number, expiry date;
(3.4)  photos and videos, that you have uploaded to the Platform;
(3.5)  contact details, such as an address, e-mail address, telephone numbers, IP address;
(3.6)  information regarding the use of our Services, participation and activity on the Platform and in the Skillex community.
Please note that we do not accept members who wish to remain anonymous. Therefore, the use of our Service is subject to the disclosure of personal data to us.

4. From where do we collect the personal data?
We obtain the personal data directly from you when you visit our website, fill in the sign-up form on our website, purchase any course or service from us and contact us (via e-mail or other communication channels). We also obtain your personal data through our service providers.
We obtain personal data of the representatives of our partners from our partners.

5. What are the privacy principles we follow?
We respect your right to the protection of your personal data.
We protect your personal data by using reasonable measures.
We analyse the risks associated with the processing of personal data. We act in order to mitigate the risks.
We comply with privacy laws.
We process your personal data lawfully.
We collect only the personal data we need.
We may transfer your personal data to our partners for marketing, research, development and improvement of our services. We impose clear rules to our partners.
We store your personal data as long as it is needed for the purposes we collected it.
We have internal rules for the processing of personal data. We introduce the rules to our employees and make sure that they understand and comply with the rules.

6. For what purpose do we process your personal data?
We process your personal data for the following purposes:
(6.1) for the preparation and conclusion of your membership agreement, for the performance of the agreement (including the provision of the Service), for the realisation of rights arising from the agreement and for the performance of the obligations arising from the agreement;
(6.2) for the purpose of realisation of rights and fulfilment of obligations arising from legal acts;
(6.3) for processing your enquiries and requests;
(6.4) for analysing the use of our Service, and using research and analysis results for, among other, developing our Services further in order to better correspond to the need of our members;
(6.5) for the transmission of information about our Service.
(6.6) for sending our newsletters and for marketing and developing and promoting our products and Services.

7. What is the basis of processing your personal data?
We process your personal data in accordance with the requirements of the legislation in force in Estonia.
We may process your personal data as a controller (i.e. data of our members) and as a processor (i.e. data of the representatives of our partners).
We mainly process your personal data in order to fulfil the membership obligations concluded with you. We also process your personal data if processing is necessary for the compliance with our legal obligation and if processing is necessary for the purposes of our legitimate interests and on the basis of your consent.

8. What are your rights in relation to your personal data?
You have the following rights:
(8.1) Right of access to personal data – you have the right to know which of your personal data we store and how we process it, including the right to know the purpose of the processing, the persons to whom we disclose your personal data, information about automated decision-making and the right to receive copies of personal data.
(8.2) Right to the rectification of personal data – you have the right to request the rectification of inadequate, incomplete and misleading personal data.
(8.3) Right to withdraw the consent given for the processing of personal data – you have the right to withdraw the consent given to us for the processing of personal data at any time.
(8.4) Right to the erasure of personal data (“right to be forgotten“) – you have the right to request that we erase your personal data (for example, if you take back the consent for the processing of personal data, or if personal data is no longer needed for the purpose for which it was collected). We have the right to refuse the erasure of personal data if the processing of personal data is necessary for the fulfilment of our legal obligation, to exercise the right to freedom of expression and information, for the preparation, presentation and protection of legal claims, or in the public interest.
(8.5) Right to the restriction of processing – In certain cases, you have the right to prohibit or restrict the processing of your personal data for a certain period of time (e.g., if you have filed an objection to personal data processing).
(8.6) Right to object – you have the right to file an objection to the processing of your personal data for marketing purposes or on grounds relating to your personal situation.
(8.7) Right to data portability – In case your personal data processing is based on your consent and personal data is processed automatically, you shall be entitled to receive personal data about you that you submitted to us as the controller, in a structured, commonly used and machine-readable format, and you shall have the right to transmit this personal data to another controller. You also have the right to request that we transfer personal data directly to another controller, where technically feasible.
(8.8) Automated decision-making (including profiling) – provided that we have informed you that we perform automated decision-making (including profiling) that will bring about legal consequences for you or have a significant effect on you, then you may require that an automated decision cannot be made only on the basis of automated processing.

Please read more about your rights from chapter 3 of the GDPR.
If you wish to use any right regarding personal data or ask questions about this Privacy Policy, please submit a corresponding request to us at [email protected] We will respond to your request no later than within one month.

9. What security measures do we apply for the protection of your personal data?
We apply various measures (physical, technical, organisational) to protect your personal data from unauthorised or arbitrary rectification, disclosure, acquisition, destruction, loss or unauthorised access to them.
If you have any information about an actual or suspected breach, please inform us about it immediately at [email protected] We will take all necessary action.

10. Do we disclose your personal data to third persons?
We disclose your personal data to our authorised processors and service providers, as well as to persons who are legally entitled to receive your personal data.
When we conclude an agreement with a processor for the processing of your personal data, we shall ensure the existence of appropriate contractual safeguards to protect your personal data.

11. Geographical area of the processing
We process your personal data within the EEA.
In the event that we need to transmit your personal data outside the EEA, the transmission shall be in accordance with the requirements of the GDPR.

12. Availability of the Privacy Policy
Please review this privacy policy carefully and contact us if you have any comments, questions or concerns. Kindly note that we may modify the policy from time to time. We will notify via our webpage any amendments.

13. Cookies
We use ”cookies” on our website. “Cookies” help us improve our Services and use our services in a more convenient manner, market our Services.
We collect data on how users interact with our website and / or application. In addition, we collect information from your computer or device, such as the IP address, browser you are using, and language settings. We also collect information about how the user uses our web pages and applications for statistical purposes to improve our web pages and applications, and to display custom content for the customer.
If you prefer that your personal data will not be processed on our website, you can activate the private browsing feature of Your web browser. This is your choice.

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