LearnWorlds Privacy Policy

LearnWorlds (“LearnWorlds”, “Us”, “We”, or “Our”) understands the importance of your privacy and that you want to clearly understand how your Personal Data is used. We respect and value the privacy of everyone who visits this website, www.learnworlds.com (“Our Site” or “Site”), the LearnWorlds platform (“Our Platform”) and uses the offered services (“Our Services” or “Services”) and will only collect and use Personal Data in ways that are described here, and in a way that is consistent with our obligations and your rights under all relevant data privacy laws.

Please read this Privacy Policy carefully and ensure that you understand it. Regardless of what type of user you are as described below Online School Administrator/User, End User and/or Site Visitor, this Privacy Policy creates a legal agreement directly between you and Us and explain the rules governing use of the Platform, Service and Site. If you do not agree with and accept this Privacy Policy, do not access or use our Site and/or Platform or any other aspect of Our business. You will be required to read and accept this Privacy Policy when signing up for a trial account to use Our Platform.

We may, from time to time, modify this Privacy Policy. Please check this web-page periodically for updates. We will comply with applicable legal obligations to provide you with relevant notice of material changes to this Privacy Policy. This may be necessary, for example, if the law changes, or if we change our business in a way that affects Personal Data protection. Your continued use of the Site, the Platform and Services after any such update constitutes your acceptance of such changes.

1. Definitions and Interpretation

All terms in capitals not defined herein shall have the meaning assigned to them in Our Terms of Service.

In this Privacy Policy the following terms shall have the following meanings:

2. Information About Us

Our Site and Our Platform are owned and operated and our Services are offered by LearnWorlds (CY) Ltd, a limited company registered in Cyprus under company number HE380294.

Registered address: Gladstonos 120, Foloune Building, 2nd Floor, B1, Limassol, 3032, Cyprus.

VAT number: CY10380294R

Registered with Information Commissioner’s Office with Reference Number: ZA372094.
Email address: gdpr@learnworlds.com
Telephone number: +357 22000504

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal Data is, in simpler terms, any information about you that enables you to be identified. Personal Data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

4. What Does This Privacy Policy Cover?

This Privacy Policy applies only to your use of Our Site, Platform and respective Services. Our Site and Platform may contain links to other websites. Please note that we have no control over how your Personal Data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any Personal Data to them.

The Personal Data we collect depends on the context of your interaction and use of our Site, Services and Platform and the choices you make in relation to your privacy settings. If you have questions about Our business operations in connection with providing Services to an Online School, please contact Us, as described in the How Do I Contact You section (Part 14).

(i) Online School Administrator

If you are or represent a User that utilizes Our Platform to create, edit and host an Online School (“Online School Administrator”), please see below our legal basis and learn how we process your Personal Data.

When a User tries, subscribes or uses Our Platform and Services and obtains support for the above under an agreement with Us, We receive data from the User and collect and generate data based on Our legitimate interest to provide the requested Services (including improving, securing, and updating the Service), conduct our business operations, and communicate with the User, carry out business development and marketing activities and for administrative and auditing purposes.

The Personal Data provided by the User may include:

• Name;
• E-mail;
• Financial information when you make a subscription ((credit card details, account details, payment information);
• Identifiable IT information (IP addresses, usage data, cookies data, online navigation data, browser data);
• Telephone number;
• Business name;
• Payment information.

The Personal Data we collect while they use our Product and Services include:

• Web browser type and version;
• Operating system;
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
• Number of log-ins.

(ii) End User

If you are an End User of an Online School, please see the terms and conditions and privacy policy of that third party, and direct your privacy inquiries, including any requests to exercise your data protection rights, to the Online School’s Administrator. We are not responsible for the privacy or security practices of our Online School Administrators, which may differ from those set forth in this privacy policy. However, we process your Personal Data and act as data processors to the Online School Administrator that is the data controller, with whom you have entered into an agreement with.

The Personal Data provided by the End User may include:

• Name.
• Email Address.
• Other custom form fields and profile information (occupation or other demographic information, address, job title) subject to the Online School Administrator set-up.
• End-user’s personal interests or preferences (including purchase history, marketing preferences and publicly available social media profile information subject to the Online School Administrator set-up.

The Personal Data we collect while they use our Product and Services may include:

• Identifiable IT information (IP addresses, usage data, cookies data, online navigation data, browser data).
• Number of log-ins.
• Webpages visited.
• Activity on the said Online School.

If you use an Online School Account you can:

• Control and administer your Account, including controlling privacy-related settings.
• Access and process your Personal Data, including the interaction data and the contents of your communications and files associated with your account in the Online School.
• Access and process your End User’s Personal Data as provided by them to offer the agreed services.

When you use an Online School, LearnWorlds processing of your Personal Data in connection with that Online School is governed by an agreement between LearnWorlds and the respective User, who administrates the Online School. LearnWorlds processes your Personal Data to provide its Services to your Online School Administrator and you.

For LearnWorlds Platform and Services provided by an Online School Administrator to minors, LearnWorlds will:

not collect or use such Personal Data beyond that needed for authorized operational purposes and to provide the relevant Services;

not sell or rent such Personal Data;

not use or share such Personal Data for advertising or similar commercial purposes, such as behavioral targeting of advertisements to minors;

not build a personal profile of a minor, other than for supporting authorized educational or school purposes or as authorized by the parent or guardian; and

require that our Online School Administrators with whom minors’ Personal Data is shared to deliver the Service, if any, are obligated to implement these same commitments for such Personal Data.

(iii) Site Visitors

When you visit our Site the following information may be collected: your IP address, which browser version you use, time of your visit, how you use Our website and information about your device (e.g. geographical location, operating system, host name of accessing computer). For details, please read our cookie policy.

The above mentioned data does not contain additional Personal Data, and cannot be assigned to specific persons.

You may choose to voluntarily submit your Personal Data by filling in the form(s) on our website (e.g. registration for a 30-day free trial). Such information shall consist of your email address.

(iv) Job applicants

When you apply for a position by either populating the application form, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf, we will use such data to evaluate you for the open position that you have applied for or any position that we consider you suitable for at the time you submit your resume or at any later date.

The Personal Data processed includes:

• Your contact information, such as name, email address, mailing address, phone number;
• any other information you volunteer, including during any interview or your interactions with us and contained in the resume that you submit to us;
• Personal Data of yours obtained from any third parties we work with in relation to our recruitment activities, including without limitation (and subject to local laws), recruitment agencies and your referees; and
• details of your education, qualifications and employment history, any other Personal Data which is contained in any reference about you that we receive.

For any query in relation to our use of your Personal Data or exercising your rights as outlined above, please contact us using the details provided in Part 14. Further information about your rights can also be obtained from the information commissioner’s office or your local citizens advice bureau. If you have any cause for complaint about our use of your Personal Data, you have the right to lodge a complaint with the information commissioner’s office.

5. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using Personal Data. This may be because the Personal Data is necessary for providing our Services to you, because you have consented to our use of your Personal Data, or because it is in our legitimate business interests to use it. Your Personal Data may be used for one of the following purposes subject to your relevant consent or request:

• Providing and managing your Account on Our Platform;
• Providing and managing your access to Our Site, Platform and relevant Services;
• Operating our Site, Platform and provide Services;
• Personalising and tailoring your experience on Our Site and Platform;
• Supplying Our Platform for your usage and Services to you. Your personal details are required in order for Us to enter into an agreement with you.
• Personalising and tailoring Our Platform and Services for you upon your request.
• Communicating with you in order to offer our Services. This may include responding to emails, support tickets or calls from you.
• Supplying you with information by email that you have opted-in to (you may
  unsubscribe or opt-out at any time by submitting a ticket to our Help Center (https://support.learnworlds.com) or sending an email to gdpr@learnworlds.com).
• Analysing your use of Our Site and Platform and gathering feedback to enable us to continually improve Our Site, Platform, Services and your overall user experience.
• Monitor, detect, prevent, cease prohibited or illegal activities and enforce our terms of service and all other policies.

6. Data management

Providing you with control over the use of your personal data especially collection, retention, correction, deletion and and usage of your data is the main objective of the GDPR.

• Opt-Out by Default
  • Site Visitors of the LearnWorlds website residing within the EU are opted out of marketing communications by default.
• Browser Cookie Control
  • You can find in our cookies policy how we use Cookies, namely small text files a website uses to recognize repeat users and their preferences, facilitate the user’s access and use of the Site and remember their. To prevent the use of Cookies for any other purpose, including but not limited to remarketing, other than the necessary, you may opt out by visiting the preferences section as displayed by clicking the relevant button on our banner.

7. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

1. a)The right to be informed about our collection and use of your Personal Data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in “How Do I Contact You?”.
2. b)The right to access the Personal Data we hold about you. Part 13 will tell you how to do this.
3. c)The right to have your Personal Data rectified if any of your Personal Data held by us is inaccurate or incomplete. Please contact us using the details in “How Do I Contact You?” to find out more.
4. d)The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in “How Do I Contact You?” to find out more, response timeframe is within a month.
5. e)The right to restrict (i.e. prevent) the processing of your personal data.
6. f)The right to object to us using your personal data for a particular purpose or purposes.
7. g)The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. h)Rights relating to automated decision-making and profiling. We do not use your Personal Data in this way.

With your permission and/or where permitted by law, we may also use your Personal Data for marketing purposes, which may include contacting you by email or telephone or text message with information, news, and offers on Our Platform and Services. You will not be sent any unlawful marketing content or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties whose digital tools we use on Our Site and Platform may use third-party Cookies, as detailed in our cookie policy. Please note that we do not control the activities of such third parties, nor the data they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

8. How Can I Control My Personal Data?

In addition to your rights under the GDPR, set out in Part 7, when you submit Personal Data via Our Site and Platform, you may be given options to restrict our use of your Personal Data. In particular, we provide you with strong controls on our use of your Personal Data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails, at the point of providing your details, or and by managing your Account).

9. How Long Will You Keep My Personal Data?

We will not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Your Personal Data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• For as long as you keep a paid or trial Account with Our Platform.
• For as long as you remain subscribed (have positively opted-in) in our emailing list and wish to receive news and offers from us.
• If none of the above is, then we will keep your data for a maximum period of two years following your initial communication or signup/Personal Data submission.
• For proper compliance with our legal, accounting and tax obligations.

10. How and Where Do You Store or Transfer My Personal Data?

All Personal Data that you provide in order to receive the Services and use the Platform and any Online School is stored on secure Google Cloud servers located in Europe and in the U.S.A. We also share your data with external third parties, as detailed below, and some are based outside of the EEA. The following safeguards are applied to such transfers:

We will only transfer your Personal Data to countries that the European Commission has deemed to provide an adequate level of Personal Data protection.

Additionally, we use specific agreements and standard contractual clauses with external third parties that are approved by the European Commission for the transfer of Personal Data to third countries. These specific agreements and standard contractual clauses ensure the same levels of Personal Data protection that would apply under the GDPR.

Please contact us using the details below in Part 14 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

The European Commission adopted its adequacy decision for the EU-U.S. Data Privacy Framework and ruled that US ensures an adequate level of protection for processing of personal data comparable to that of the European Union.This means European entities are able to transfer data to self-certified businesses in the US without having to put in place additional data protection safeguards. Following the above, please note that all of our subprocessors are included in the Data Privacy Framework list.

Apart from these developments, LearnWorlds continues to apply standard contractual clauses (SCCs). Additionally, we’ve specifically assessed the risks raised by the Court of Justice of the European Union and determined that those risks are highly unlikely for LearnWorlds as theoretical applications of Executive Order 12333 and the U.S. Foreign Intelligence Surveillance Act are unlikely to impact LearnWorlds in any way since the services we offer are not in the following sectors (e.g., telecommunication providers, ISPs, military etc) therefore the data we process should be of no interest to the U.S. intelligence community. So far no surveillance request has been received, and if we receive such a request, we shall notify the impacted parties unless prohibited by applicable law.

Any payment transactions will be encrypted using SSL technology; All payment data is stored by our payment processors and is never stored on our servers. Where we have given you (or where you have chosen) a password that enables you to access your account and the Product, you are responsible for keeping this password confidential. We recommend that you not share your password and that you change it frequently.

Data Security: Here at LearnWorlds we take data security and privacy very seriously and we continuously look for opportunities to make improvements. Here are the measures we employ for securely storing the data you entrusted to us: https://www.learnworlds.com/data-security.

11. Do You Share My Personal Data?

1. a)Subsidiaries: We may sometimes share your personal and usage data with our subsidiaries in light of offering our Services and Platform to You.
2. b)Payment, marketing and delivery vendors and partners: We may sometimes enter into agreements with the following third parties to be able to offer certain features of Our Site, the Platform and Services under our capacity as data controllers. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your Personal Data that we hold.

• Chargebee.com (subscription management and invoicing)
• Braintreepayments.com (online credit card payments)
• PayPal.com (online payments)
• FreshDesk (Customer help center and support tickets)
• Agile CRM (CRM, form handling, appointment scheduling and user analytics)
• FirstPromoter (registration and tracking of affiliates)
• Google Analytics (website user analytics)
• Google Cloud (data transfer and storage)
• MixPanel (website user analytics)
• Segment (website user analytics)
• HotJar (website user analytics)
• Google AdWords (targeting and tracking of ad campaigns)
• Facebook (targeting and tracking of ad campaigns)
• useFOMO (display of user notifications)
• LeadPages (displaying pop-ups and registration forms)
• Wistia (showing user videos and tracking analytics)

1. c)Assignment and succession: In case of transferring in part or in whole our business and/or assets to another company, we may transfer as well your personal and usage data. We will make sure to notify You in case of such transfer and you will have available all of your rights under the GDPR.
2. d)Authorized resellers: If you enter into any subscription plan, including trial, to access our Services and Platform, we may share your personal data with an authorized reseller directly so that they can provide you with timely, helpful information about our Platform and the Services and faciliate your onboarding. Our resellers are contractually obligated to treat personal and usage data only as described in the respective partnership agreement, preventing them from sharing your personal data with any other third parties or using them in any other way than as agreed in the partnership agreement. For more information regarding any of our authorized resellers, please read the Contact Us section below.
3. e)Additional Disclosures. We may disclose your personal data where (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request, (b) to enforce our agreements, policies, and Terms of Use, (c) to protect the security of our Platform and Services, (d) to protect us, our customers, or the public from harm or illegal activities, or (e) to respond to claims that any content violates the right of third parties.

We may also share aggregated and de-identified information that does not directly identify you with third parties.

If any of your Personal Data is required by a third party, as described above, we will take steps to ensure that your Personal Data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.

If any Personal Data is transferred outside of the EEA, we will take suitable steps in order to ensure that your Personal Data is treated just as safely and securely as it would be within the EU and under the GDPR, as explained above.

12. Can I Withhold Information?

You may access certain areas of Our Site without providing any Personal Data at all. However, to use all features and functions available on Our Site and Platform you may be required to submit or allow for the collection of certain data for us to be able to offer our relevant Services. You may restrict our use of cookies. For more information, please review our cookie policy.

13. How Can I Access My Personal Data?

If you want to know what Personal Data We have about you, you can ask us for details of that Personal Data and for a copy of it (where any such Personal Data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14. To make this as easy as possible for you, a subject access request form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything We need to know to respond to your request as quickly as possible. Please contact us at gdpr@learnworlds.com and request this form.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request the soonest possible, and in any case, not more than one month of receiving it. Normally, We aim to provide a complete response, including a copy of your Personal Data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of our progress.

14. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Ms. Julie Tsavdari):

Email address: gdpr@learnworlds.com.
Telephone number: +44 11 6464 9900.
Postal Address: LearnWorlds (CY) Ltd, Gladstonos 120, Foloune Building, 2nd Floor, B1, 3032, Limassol, Cyprus.