Last Updated: 5th of June, 2023
- Fairness and transparency
- Purpose limitation
- Data minimization
- Storage limitation
- Integrity and confidentiality (security)
- What is Personal Information?
“Personally Identifiable Information” (the “Personal Information”) refers to details collected through the Internet about an individual consumer, including an individual’s first and last name, a physical street address, an email address, a telephone number, or any other information that permits a specific individual to be contacted physically or online.
- Who Controls Your Personal Information?
- Collection of Your Personal Information
We may collect personal information from you when you visit our website, fill out a form, or in any other way provide us with personally identifiable information.
We may collect the following information:
- First Name,
- Last Name,
- Email address
- And any other information you voluntarily choose to submit.
We recommend and encourage you to carefully consider the data you disclose to us or any third-party service provider we use. Please don’t share sensitive information (such as credit card details, national identity numbers, religious denominations, health details, etc.) and/or when shared, please consider disclosing such information carefully.
- Information Collected Automatically
When you visit our Site, our servers may automatically record information that your device sends whenever you visit the Site (“Log Data”). This Log Data may include information such as the computer’s/Device’s Internet Protocol (the “IP”) address, browser type, access times and dates, and other statistics. Log Data does not directly identify you but can be combined with other data pieces to reveal your identity. We don’t use Log Data in this way. We only use this information to monitor and analyze the Site and increase our Site’s functionality and user-friendliness and better tailor the Site to our Users’ needs through aggregating, analyzing and evaluating such information.
Each time you open the Site, we collect information about how and when you use it (such as the time and dates, searches in the Site features and results you select, pages visited, Site crashes and other system activity). We use this information to improve the Site.
- Information Use and Processing
- Contact you;
- Offer our services, products and/or new features of the website;
- Conduct research for User experience enhancement purposes;
- Personalize the Site and/or products for you;
- Protect our legal rights and enforce our policies. Respond to your inquiries and communicate with you.
We may additionally use your Information in other ways naturally related to the circumstances during which you provided the information.
We will only process your personal information where we have legitimate legal grounds for doing so. The legal basis to process your personal information includes processing that is necessary for our legitimate interests, which are to:
- Research, develop, fix, and make available new features for the Site and/or our products.
- Confirm your eligibility to use our Site.
- Provide technical support to users and make sure that the Site is secure.
- Verify Users’ identities to restrict unauthorized and fraudulent use of our services and/or products.
- Prevent breaches of our terms and policies or restrict harmful or illegal activity.
We might process data based on your permission (for instance, where you provide us with marketing consent), which can be withdrawn at any time by contacting us at the email address: email@example.com
We work effortlessly to enhance the Site and add functionality, which we think will make it safer and more useful. New features may involve similar uses of your data to those determined above.
We regularly review data processing practices and will keep you updated if we decide to change anything.
We may send you information we think you may find useful, and you can opt-out of receiving further notifications or emails if you wish and please contact us regarding this matter at the following email: firstname.lastname@example.org
- How Do We Share Information?
We may engage third-party companies and individuals to perform services on our behalf, including without limitation, to facilitate our Site, perform Site-related and other services (e.g., without limitation, maintenance services, database management, analytics, communication with users, employment and improvement of the Site’s features). These third parties may have access to your Personal Information. We do not authorize these third parties to use your information for any purpose other than to provide the above services.
We may also disclose information about you that we have collected via the Site to the government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), to protect the property and rights of the Company or any third parties, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be or to pose a risk of being illegal or unethical.
Where there is an investigation into alleged criminal behavior or to protect the vital interests of the Company or any other individual, we will cooperate with law enforcement inquiries. This may include preserving or disclosing any of your information, if we believe in good faith that it is necessary to comply with laws or regulations, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, request, etc.
- Third Parties
We may share the information that we collect with third parties such as promotional and marketing partners, current and future affiliated companies, business partners and others whose products or services we think may interest you.
We engage trusted third-party service providers to provide services to us, such as hosting and maintenance of our servers and the website, database storage and management, e-mail management, storage marketing, employment management, customer relationship management, etc. We will likely share your Personal Information with these third parties to enable them to perform these services for Us and for You.
- Children’s Information
We do not knowingly collect Personal Information from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with such information without their consent, he or she should contact us at email@example.com and upon receiving such an email we will remove the data.
COPPA (Children Online Privacy Protection Act). When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission of the United States, a consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under 13.
- Information Security
We maintain administrative, technical, and physical safeguards for the Site designed to protect against the loss, misuse, or unauthorized access, disclosure, alteration, or destruction of the Personal Information we collect through the Site. However, we cannot guarantee that any information collected is perfectly secure. While we perform reasonable due diligence in selecting third-party providers associated with processing and data handling.
Regardless of where you are located, the Company collects information, and processes and stores that information in databases stored on servers located in different countries and regions such as the United States of America (USA), and the European Union (EU).
We place great importance on the security of all information associated with our users and store such information securely with SSL (Secured Socket Layer) mechanism. Remember that the submission of information over the internet and mobile networks is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet or mobile networks and any such submission is at your own risk.
- How Long We Keep Your Information
By providing you with products and/or services, we might create records that contain your information. We manage our records to help us to serve our users in an efficient way and to comply with legal and regulatory requirements.
How long we keep records depends on the type of record, the nature of the activity, product or service and the applicable legal and regulatory requirements. How long we retain your information may change based on business or legal and regulatory requirements. If you are our Site user, we keep most of your data as long as you’re using the Site and for six years after that to comply with the law and/or if we face a legal challenge. In some circumstances, we may keep data longer if we need to due to our legitimate interest and/or if the law requires.
Unless a longer retention period is required or permitted by law, we will only hold your Personal Information on our systems for the period necessary to fulfill the purposes outlined in this Policy, or until you request that the information be deleted in accordance with your right of erasure.
Even if we delete your Personal Information, we reserve the right to maintain a copy for legal, tax or regulatory purposes, but in such an event, we will do so only as long as necessary to fulfill those purposes. Please contact us via firstname.lastname@example.org for more information.
Information that you submit via the Site is sent to and stored on secure servers located in the USA and the EU. Information submitted by you may be transferred by us to the third parties in the circumstances, which may be situated outside these jurisdictions.
We keep your personal information as long as we need it for legitimate purposes and as permitted by applicable law. We delete or pseudonymize (remove information that identifies you) your information upon deletion of your Personal Information (following the safety retention window) unless:
- We must keep it to comply with applicable law (for instance: the “traffic data” retention period is 1 year)
- There is an issue, claim or dispute requiring us to keep the relevant information until it is resolved.
- Legal Rights
When you are using our Site, you have the following rights:
Access: You have a legal right to request access to a copy of the personal information we have collected. For such information, contact us at email@example.com
Deletion: We store your personal information for as long as necessary to provide our services and products. You have the right to request the deletion of your Personal Information if you believe we no longer need it for the purposes for which it was provided. Note, that we might keep a record of your request to ensure compliance with legal obligations. To request deletion of your Data, contact us at firstname.lastname@example.org
Right of rectification: if the data held is inaccurate, you have the right to have it corrected. For such requests, contact us at email@example.com
Marketing opt-out: You have the right at any time to prevent the use of your Personal Information for direct marketing purposes. If you no longer want to receive marketing messages, please let us know by writing to us at firstname.lastname@example.org
Right to object to us processing information: You have a right to object to us processing any personal data that we process where we are relying on legitimate interests as the legal basis of our processing. If you request to exercise your right to object, if we have legitimate grounds to carry on processing your data, we will be able to continue to do so. Otherwise, we will cease processing your data. For such requests, contact us at email@example.com
Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider. For such requests, contact us at firstname.lastname@example.org
Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision that has legal or significant effects on the individual. In these circumstances, your rights include the right to ensure that there is human intervention in the decision-making process. We do not use automated decision-making.
According to CalOPPA, we agree to the following:
- Users can visit our site anonymously.
- Users can change their personal information by emailing us.
“Do Not Track” Requests & Behavioural Tracking
Please be advised that currently, we do not respond to “Do Not Track” requests. You should be aware that we allow third-party behavioural tracking on our Site.
Fair Information Practices
The Fair Information Practice Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
- We will notify the users via email within seven (7) business days.
- We also agree with the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data controllers, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions.
- Process orders and send information and updates pertaining to orders.
- We may also send you additional information related to your product and/or service.
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CAN-SPAM we agree to the following:
- NOT use false, or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly. Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email, and we will promptly remove you from all correspondence.
The General Data Protection Regulation of the EU and the UK (collectively the “GDPR”) gives the residents of the EU/UK certain rights when their personal data is being collected and processed. At Ehoudiniacademy, we are committed to complying with the GDPR.
(a) Legal Bases of Processing
We rely on the following legal bases under the GDPR to collect and process your personal information:
- Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which we are subject.
(b) Data Subjects Rights
(c) International Transfer of Data
If you are a resident of the EU/UK, you should be aware that when you access our Site and use our Service your personal information might be transferred to countries located outside the EU/UK.
(d) Exercising Your Data Protection Rights
You may exercise your rights of access, rectification, cancellation, erasure, and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests, such as by asking you questions about your use of the Service and/or Site. If you make a request, we will try our best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA region.
- Updating Your Information
If you would like to update your Personally Identifiable Information, please contact us by emailing us at email@example.com
Also, you can request at any time to permanently delete your Personal Information. Upon receiving your request, we will take reasonable steps to make sure it is no longer stored in our database. For up to 30 days, it is still possible to restore your Personal Information if it was accidentally or wrongfully deleted. After 30 days, we begin the process of deleting Personal Information from our systems permanently.
- How to Get in Touch with Us?