Version 13.04.2019 – 1
Article 1 : What is a Personal data ?
1.1 Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Article 2 : What about Personal Identification Information?
2.1 In order to provide you with optimized learning services and products, we may collect personal identification information in a variety of ways, including, but not limited to, when you visit our Websites, create a new account, place an order, and in connection with other activities, services, features or resources we make available for our users. We collect personal identification information only if you voluntarily submit such information (e.g. when you confirm a purchase, or create an account). Below the list of personal identification information and data processed by GOBAKO:
|Contact Information (for example an email address)||You might provide us with your contact information, whether through use of our services, learning platform GOSTELO, a form on our website, an interaction with our sales or customer support team, or a response to one of our own surveys.|
|Registration and onboarding information||You need a GOBAKO account before you can use our Products and learning Services. When you register for an account, we collect your first and last name, username, password and email address. In some casis such as for student and teacher onboarding, we might collect also your phone number, postal address and CV/Resume.|
|Billing information||If you make a payment to GOBAKO, we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number). If you provide a billing address, we will regard that as the location of the account holder to determine which GOBAKO entity with whom you contract and the sales tax, if applicable, to be applied to your purchase.|
|Account settings||You can set various preferences and personal details on pages like your account settings page. For example, your default language, time zone and communication preferences.|
|Survey/form/homework/application data||We store your survey/form/application/homework data (e.g. questions and responses) for you and provide analysis tools for you to use with respect to this data. We also store your enrolment history and grades for each course you successfuly complete.|
|Profile information||When you sign up for our services you are free to provide us with information about yourself and to give us more detailed insights into who you are. This usually helps our teachers to create personalized learning activities that will be more interesting for you.|
|Log Data||Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.|
2.2 We are committed to ensuring that the information which is collected and used is appropriate and fulfill a specific purpose. GOBAKO is a company which values its users’ data protection and privacy rights and has no interest in collecting data beyond what is needed to make the services work for its users and its community. You can always refuse to supply personally identification information, except that it may prevent you from engaging in certain activities, create an account or access our learning Platform.
Article 3 : What about Non-personal Identification Information ?
3.1 In order to improve your browsing experience in our Webiste and Platform, we may collect non-personal identification information about you whenever you interact with our Websites. Below the list of non personal identification information and data processed by GOBAKO:
|Usage information (anonymous data).||We collect usage information about you whenever you interact with our websites and services. This includes which webpages you visit, what you click on, when you perform those actions, what language preference you have, what you buy and so on.|
|Device and browser data (anonymous data).||We collect information from the device and application you use to access our services. Device data mainly means your IP address, operating system version, device type, device ID/MAC address, system and performance information, and browser type.|
|Referral information (anonymous data).||If you arrive at our Website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.|
Article 4 : Web Browser Cookies
Article 5 : How Are Used The Collected Information ?
5.1 We may collect and use your personal and non personal identification information for the following purposes:
- To personalize your experience. All information you provide help us support your needs more efficiently (e.g. our teachers might adapt the content of their course based on your inputs and personal information, hobbies, interests and make your learning experience on our Website more interesting for you).
- To improve our products and learning services. We may use collected information to understand how our users as a group use the services and resources provided on our Website.
- To improve our Websites and our learning Platform. We may use your feedbacks to improve our learning products and services and the way they are presented on our Websites (e.g. frequency of error page, purchase failure, unvisited page etc…).
Article 6 : Will GOBAKO share personal data with anyone else?
6.1 We may pass your personal data to third-party contracted to work with us. All third parties or externals we work with are obliged to keep your personal data securely, to be GDPR compliant, and to use them only to deliver the service they provide. When they no longer need your data to fulfil this service, they will dispose of the details in alignment with our procedures. Below the list of third-party we are working with:
|Your teachers||Thanks to your profile and data you provide, they can contact you, create personalized learning course adapted to your needs and objectives, follow your progress, correct your homeworks etc…|
|Freshdesk||Our customer support desk tool. All details from onboarding forms, contact forms are stored and managed in this platform in a seperate and dedicated instance for GOBAKO.|
|Mailchimp||Our marketing automation platform and an email marketing service. If you opt for our newsletter, your name and e-mail is processed and managed in this platform.|
Article 7 : What are Your rights with respect to personal data ?
7.1 Some of you (in particular, European users) have certain legal rights regarding the protection of personal data. Indeed, the rights you are entitled to as part of GDPR regulation are listed below:
- Right to know: you have the right why your personal data is needed, what will happen to it, and how long it will be retained for.
- Right of access: you have the right to access your personal data that is known to us.
- Right to rectification: you have the right to supplement, correct, have deleted or blocked your personal data. If you gave your consent to process your personal data, you have the right to revoke that consent and to have your personal data deleted.
- Right to transfer: you have the right to request all your personal data kept from one company and transfer it in its entirety to another company.
- Right to object: you may object to the processing of your personal data (e.g. direct marketing).
- Right to erasure: you have the right to have your personal data erased. This is also known as the “right to be forgotten”. This right is not absolute and only applies in certain circumstances.
- Right to restrict the processing: you have the right to request us to restrict the processing of your personal data in certain circumstances. This means that you can limit the way we use your data. This is an alternative to requesting the erasure of their data.
Article 8 : How to exercise my GDPR rights ?
8.1 If you want to exercise one of your rights, you should use the contact form on the home page of our Website using the category “I want to exercise my GDPR rights”. We will respond to your request within a reasonable time (and in all cases within 30 days of receiving a request).
8.2 In the event you wish to make a complaint about how your personal data is being processed by GOBAKO Learning Center, or how any complaint has been handled by our teams, you have the right to lodge a complaint directly with the supervisory authority (the Data Protection Authority).
Article 10 : Acceptance Of These Terms
10.1 By using this Website or our Platform GOSTELO, creating an account, placing a purchase, you unreservedly accept all the terms of this policy. In case of any disagreement of any part of this policy, you are not allowed to use any of our Products or learning Services (e.g. learning course, conference or Webinar).
Article 11 : Contacting Us
(Version 1.5 – 04.2019)