Privacy Policy

Effective date: November 1st, 2018

GENERAL TERMS

Geenio Limited, limited liability company having its registered office at Dimitriou Karatasou, 15, Anastasio Building 6th Floor, Flat/Office 601, Strovolos, 2024, Nicosia, Cyprus (“Service Provider” “we”, “us” or “our”) provides services as specified herein, known and marketed under the name of Courselle (“Courselle Service” or “Service”). This Privacy Policy explains how we and some of the companies we work with collect, use, share and protect information in relation to our Services, web site, applications and any software provided on or in connection with our Services, and your choice about the collection and use of your information.

This Privacy Policy applies to all visitors, users and others who access the Services (“Customers”).

Please note that if the Customer is signing up to a free use of any Service Provider’s product(s) then, notwithstanding any other provision to the contrary, the product(s) are provided on “as-is” basis and without any warranty whatsoever. During the free use period the product(s) are used at the Customer’s own risk.

Service Provider is entitled to collect certain information described herein. By using our Services you understand and agree that we are providing a tool for you to store Customer Data, to the Services and to share Customer Data privately or publicly.

Please review this Privacy Policy periodically as we may update it from time to time. Each time you use Courselle Services or provide us with information, you are accepting and agreeing to the provisions of this Privacy Policy effective on the day of use of the Services or providing us with information. By using Courselle Services you are expressly and affirmatively consenting to our use and disclosure of the information that you provide, and consenting to receive emails, as described in this Privacy Policy. Note that you may opt out of Courselle Services related emails as well as that you have the right to object at any time to processing of your information for direct marketing purposes.

DEFINITIONS

“Customer” means all visitors, users and others who access the Services and the contractor of Services under the Services Agreement.

“End User(s)” means the employees, representatives, consultants, contractors or agents of the Customer (and those of any Group Company) who are authorized by the Customer to use the Service and have been supplied usernames and passwords by the Customer or by Service Provider.

“Services” means a tool for creation of interactive training courses with training process management functionalities that are provided by accessing and using the Software via the website or an application (for stationary or mobile devices) as may be more defined in the Purchase Order.

“Software” means entirety of the programs and other operating information used by a computer dedicated for the provision of Services that are programmed, developed and maintained by Service Provider, its affiliates, licensors and/or contractors.

INFORMATION YOU PROVIDE US

As a condition of using Services, you agree to provide Service Provider with your certain information:

• Contact information, including without limitation your full first and last name, postal address, phone number, username, password and email address as well as your computer’s unique Internet Protocol (“IP”) address (if any),

• Financial information (billing details, credit card number, etc.).

• Demographic information (e.g., zip code, postal code, hometown, gender, purchase history information and age as well as IP addresses that are not unique to your computer).

• Customer Data (i.e. Stored Data and Account Data. “Stored Data” means the files, learning, educational, training content and structured data submitted to the Service Provider by Customer or End Users. “Account Data” means the account and contact information submitted to the Service Provider by Customer or End Users) that you create, post, connect, place or share using Courselle Services.

• Communication between you and the Service Provider (e.g., we may send you Services related emails, for example, account verification, changes/updates to features, terms and conditions of the Services, technical and security notices, etc.).

Service Provider shall not collect nor process any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.

CHILDREN’S PRIVACY

Please note that nowhere within our Services do we knowingly collect or solicit contact information, financial or any other information from anyone under the age of 13 or knowingly allow such persons to register for the Services.

Services and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at hello@courselle.com.

If you are 13 or older but under the age of 18, you have to look through this Privacy Policy with your parents or custodians and use our Services only after your parents or custodians express their consent for such use and agreement to this Privacy Policy.

HOW YOUR INFORMATION IS USED

We collect, use, keep or otherwise process your information for the performance of our agreement with you in order to provide, maintain and develop the Services. You shall have the right to request from the Service Provider access to and rectification or erasure of your personal data or restriction of processing of such personal data or to object to processing as well as the right to data portability to the extent and in the manner as provided by laws and the Agreement.

LOG FILE INFORMATION

Log file information is automatically reported by your browser each time you make a request to access a web page or app. It can also be provided when the content of the web page or app is downloaded to your browser or device.

When you use our Services, our servers automatically record certain log file information, including your web request, web page from which you came, IP address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Customers which then help us track which emails are opened and which links are clicked by recipients. The information helps us identify you and to gather demographic information about you, allows for more accurate reporting and improvement of the Services.

CONTACTING YOU FOR OFFERS AND PROMOTIONS:

You agree, in consideration for the use of the Services, to allow to use your contact and demographic information (your “Profile Information”) to email you marketing and promotional materials. Service Provider may also email you marketing and promotional materials that promote third party products. Service Provider will not rent or sell your Profile Information for use by third parties. The materials Service Provider may email you may include without limitation newsletters providing you with additional information on how to use the Services and promotional offers for goods and services from the Service Provider or third parties.

USE OF PROFILE INFORMATION AND CUSTOMER DATA:

The Customer shall own all rights, title, entire responsibility and interest in and to all of the Customer Data and shall have sole and entire responsibility for the legality, reliability, integrity, accuracy and quality of the Customer Data. Service Provider shall not be liable or responsible for the content, any loss, destruction, alteration or disclosure of Customer Data. If Service Provider processes any personal data comprised in the Customer Data on the Customer’s behalf when performing its obligations under the Agreement, the parties record their intention that the Customer shall be the data controller and Service Provider shall be a data processor and in any such case:

• the Customer acknowledges and agrees that the personal data may be transferred or stored outside the country where the Service Provider, Customer and the End Users are located (including without limitation outside the United States or European Union) in order to carry out the Services and Service Provider’s other obligations under the Contract;

• the Customer shall ensure that the Customer is entitled to transfer the relevant personal data to Service Provider so that Service Provider may lawfully use, process and transfer the personal data in accordance with terms of this Agreement on the Customer’s behalf;

• the Customer shall ensure that the relevant third parties have been informed of, and have given their consent to, such use, processing, and transfer as required by all applicable data protection legislation;

• Service Provider shall process the personal data only in accordance with the laws, terms of this Agreement and any lawful instructions reasonably given by the Customer from time to time;

• each party shall take appropriate technical and organizational measures against unauthorized or unlawful processing of the personal data or its accidental loss, destruction or damage; and

• Service Provider shall be authorized to transmit, disclose or otherwise transfer the Customer Data to the Service Provider’s affiliates and/ or licensees or a third party to the extent it is necessary to provide, maintain and develop Services. Service Provider may use your Profile Information and Customer Data to perform business analyses or to tailor Courselle Services and communications to Customer interests. We may share anonymous, aggregated Profile Information, Customer Data with advertisers and other third parties so that they can tailor their advertisements and communications to the appropriate audience. Any time that we are not disallowed under this Privacy Policy to share your contact information or financial information, we may also share your demographic information and Customer Data along with it.

DEVICE IDENTIFIERS

When you use a mobile device like a phone or tablet to access Services, we may access, collect, monitor, store on your device and/or remotely store one or more “Device Identifiers”. Device Identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. Device Identifiers may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Services.

Device Identifiers may deliver information to us or to a third party partner about how you browse and use the Services and may help us or others provide reports or personalized content and ads. Some features of the Services may not function properly if use or availability of Device Identifiers is impaired or disabled.

METADATA

Metadata is usually technical data that is associated with Customer Data. For example, Metadata can describe how, when and by whom a piece of Customer Data was collected and how that content is formatted.

Users can add or may have Metadata added to their Customer Data including a hashtag, geotag, comments or other data. This makes your Customer Data more searchable by others and more interactive. If you geotag your photo or tag your photo using other’s APIs then, your latitude and longitude will be stored with the photo and searchable if your photo is made public by you.

USE OF COOKIES AND OTHER TRACKING DATA
COOKIES AND SIMILAR TECHNOLOGIES:

A “cookie” is a small file that we may save on your computer’s hard drive that contains non-personal information. These cookies help to give you faster access to pages you have already visited. We may use cookies and similar technologies like pixels, web beacons and local storage to collect information about how you use Services and provide features to you. Cookies also allow you to customize your pages, and optimize your experience using Services. We may also use cookies to help us figure out how many people are using Services, which Services they may be using, and how long they use them. This information helps us figure out which features are highly successful and which might need improvement. You can disable cookies on your computer by indicating this in the preferences or options menus in your browser. Most browsers accept cookies automatically, but allow you to disable them. Disabling cookies may prevent you from properly using Services.

SESSION IDS:

“Session IDs” allow us to identify a particular user across multiple web page requests. This Session ID is maintained within your cookie file, where possible. If cookies are not enabled, or if your internet browser program does not support cookies then we may place the Session ID in the requested web page. This allows you to avoid having to continually re-enter certain information such as account name and password for every web page request. This Session ID expires whenever you close your internet browser.

TRACKING AND REPORTING:

Some of our web pages may also contain special electronic images (called a “single-pixel gif” or “gifs”) that allow us to gather only non-personally identifiable traffic statistics and other aggregate information about visitors to our sites. (through itself or third parties) may use technology to collect and accumulate anonymous data that helps us understand and analyze the experience of people visiting our web pages and, along with other information you provide, customize your future visits, use of Services and improve our web pages and Services. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assist us improving the Services. For example, we may capture data on the type of browser used, type of operating system used, cookie preferences (whether you have them turned on or off), and search engine keywords (what keywords did you use to get to our site). We may also record the number of visits and paths taken using Services. None of this information is personally identifiable and we only distribute this information to internal staff at Service Provider.

BANNER ADS:

Services may include the use of ad banner partners for the serving and/or targeting of ads, promotions, and other marketing messages. These ads may be provided, in some cases, by a third-party ad service provider. The ad service provider may place or utilize their own unique cookie on your browser, and may use non-personally identifiable information about your visit to our sites, such as the number of times you have viewed an ad. Service Provider is not responsible for the collection of these cookies and is not responsible for the actions of the ad service providers. Service Provider does not sponsor or guarantee any products or services advertised by third-parties on its site. Ad service providers may use information (not including your name, address, email address or telephone number) about your use of Services in order to provide advertisements about goods and services that may be of interest to you.

DIRECT LINKING URLS OR HOTLINKING:

In order to provide more relevant advertising and monitor user bandwidth usage, Service Provider may gather data from the referrer logs that identify where and how frequently images being hosted by Service Provider are being displayed by third-parties.

INFORMATION FROM THIRD-PARTIES

Service Provider may place links to other products operated by other parties and from time to time may include information and links to third-party products in our promotional email. Some of these other products contain our brand names and trademarks and other intellectual property that we own; others do not. When you click on these links and visit these other products, regardless of whether or not they contain our brand names, trademarks and other intellectual property, you need to be aware that we do not control these other products or their business practices, and that this Privacy Policy does not apply to these other products. Consequently, the operators of these other products may collect different kinds and extent of information about you, and may use and disclose that information in different ways and in extent than we would if it were collected through Services. We encourage you to review their privacy policies and remind you that we will not be responsible for their actions.

SERVER LOCATIONS

You understand and agree that Service Provider stores and processes your information on servers that may reside outside the country where the Service Provider, Customer and the End Users are located in, and by providing any data to Service Provider, you consent to the transfer of such information to these servers including those servers that may reside outside the United States or European Europe. Information may also be stored locally on the devices you use to access the Services.

DISCLOSURE TO GOVERNMENTAL ENTITIES AND RESPONDING TO LEGAL REQUESTS

Service Provider may disclose specific Information when we determine that such disclosure is necessary to comply with any applicable law or any judicial or governmental order, to cooperate with or seek assistance from law enforcement or to protect the interests or safety of Service Provider or other users of Services. This may include responding to legal requests from jurisdiction outside the country where the Service Provider, Customer and the End Users are located in, including but not limited to outside the United States or European Europe. Also, your information may be passed on to a third party in the event of a merger, acquisition, consolidation, divestiture, bankruptcy, dissolution or a liquidation of the Service Provider, Services or our assets. We may also access, preserve and share information when we determine that such disclosure is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended reasonable period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

OTHER USE OF YOUR INFORMATION

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive from you to: help you efficiently access your information after you sign in; remember information so you will not have to re-enter it during your visit or the next time you visit Services; provide personalized content and information to you and others, which could include online ads or other forms of marketing; provide, improve, test and monitor the effectiveness of our Services; develop and test new products and features; monitor metrics such as total number of visitors, traffic, demographic patterns; diagnose or fix technology problems; automatically update Service Provider’s application on your device, special offers or other events or activities on the Courselle Services.

We will not rent or sell your information to third parties outside the Service Provider (or the group of companies of which Service Provider is a part) without your consent, except as noted in this Privacy Policy.

However we may transfer your information to a third country, including without limitation outside the United States or European Union, for the performance of our agreement with you in order to provide, maintain and develop the Services and by using the Services you explicitly consent to such transfer.

SHARING OF YOUR INFORMATION

We may share Customer Data and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that Service Provider is part of, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve Services (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences).

We also may share your information as well as information from tools like cookies, log files, and Device Identifiers and location data, with third-party organizations that help us provide the Service to you. Such our third-party service providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.

We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

Any Customer Data that you make public is searchable by other Users and subject to use under our Application Program Interface (“API”).

If you remove information that you posted, placed or otherwise shared to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users or third parties using our API have copied or saved that information.

YOUR SOLE RESPONSIBILITY OF THE CONTENT OF INFORMATION

You are solely responsible for the information and content of it you create, post, place or otherwise share using Services. Service Provider has no obligation to check or verify your information.

You must not defame, stalk, bully, abuse, harass, threaten, impersonate or intimidate people or entities and you must not post private or confidential information via the Services.

You must not create or submit unwanted email, comments, likes or other forms of commercial or harassing communications (“spam”) to any Customer.

You are solely responsible for your interaction with End Users of the Services. Service Provider is not responsible or liable for the conduct of any User.

You must not use Services in any way that causes, or may cause, damage to the Services or impairment of the availability or accessibility of the Services; or in any way which is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity.

You must not use Services to copy, store, host, transmit, send, use, publish or distribute any material which consists of (or is linked to) any spyware, malware, worms, computer virus or other malicious computer software.

You must not conduct any systematic or automated data collection activities (including, limitation, scraping, data mining, data extraction and data harvesting) on or in relation to Services without Service Provider’s express written consent.

You hereby indemnify Service Provider and undertake to keep Service Provider indemnified against any losses, damages, costs, liabilities and expenses (including, without limitation, legal expenses and any amounts paid by Service Provider to a third party in settlement of a claim or dispute on the advice of our legal advisers) incurred or suffered by Service Provider arising out of any breach by you of any provision of this Privacy Policy, or arising out of any claim that you have breached any provision of this Privacy Policy.

RIGHT TO BE FORGOTTEN

You shall have the right to be forgotten – an option to be taken off any mailing lists at any time and to have your account permanently deleted. Before permanently deleting your account, you may want to download a copy of your information from the Service Provider. Make sure you made a copy of your information before submission of your request to us of being forgotten. Once your account has been deleted it might not be recovered except as otherwise provided in this Privacy Policy.

RETENTION

Service Provider will retain information you store on our Services for as long as we need it to provide you the Services. If you delete your account, Service Provider, its Affiliates, or its Service Providers may retain information (including your profile information) and Customer Data for a commercially reasonable time for backup, archival, and/or audit purposes and/or as necessary to comply with legal obligations, and/or to protect our, your or public interests and/or for other lawful use.

CHANGE OF CONTROL

If we sell or otherwise transfer part or the whole of Service Provider, Services or our assets to another person (e.g., in the course of a transaction like a merger, acquisition, consolidation, divestiture, bankruptcy, dissolution, liquidation), your information such as name and email address, Customer Data and any other information collected through the Service may be among the items sold or transferred. You will continue to own your Customer Data. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.

SECURITY PRECAUTIONS

Notwithstanding anything in this Privacy Policy, if there is a Security Emergency then Service Provider may automatically suspend use of the Services. Service Provider will make commercially reasonable efforts to narrowly tailor the suspension as needed to prevent or terminate the Security Emergency. “Security Emergency” means: (i) use of the Services that do or could disrupt the Services, other customers’ use of the Services, or the infrastructure used to provide the Services and (ii) unauthorized third-party access to the Services.

Service Provider has security measures in place to help protect against the loss, misuse and alteration of the information under our control. We use secure socket layer (SSL) technology to help protect the security of commerce transactions. We encrypt your contact information and financial information as it travels over the Internet and we store your financial information on our servers in encrypted form. Your information may be transferred to and maintained in whole or in part outside of the state, province, country or other governmental jurisdiction in which you reside, and may be stored on equipment or in facilities leased or licensed from third-parties. Please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. However, Service Provider cannot ensure the security of any information you transmit to us or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. As a result, while we strive to protect your personal information and make commercially reasonable efforts to do so, Service Provider cannot ensure or warrant the security of any information you transmit to us, which you therefore do at your own risk. Once we receive your transmission, however, we make commercially reasonable efforts to ensure its security on our systems. This Privacy Policy does not apply to any information, including images, that you submit for use in publicly available areas. Aside from contact information, we ask that you do not submit any personal information (such as financial information) for display in public areas, as other people who use Services will see it. If you submit such information for display in public areas, Service Provider cannot prevent it from being used in a manner that violates the law, your personal privacy or your safety. By submitting any personal information, including your contact information) for display in public areas, you assume the risks and sole liability arising as a result of such information being displayed. Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and Service Provider, at all times. Your privacy settings may also be affected by changes the social media services you connect to us make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.

We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your Customer Data. If you are using a third-party website or service and you allow them to access your Customer Data you do so at your own risk.

CHANGES TO THE PRIVACY POLICY

This policy may be revised or updated over time as new features are added to our Services or as we incorporate suggestions from our users, those changes will be posted on Service Provider’s website. Please review this Privacy Policy periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of Services after any modification to this Privacy Policy will constitute your acceptance of such modification.

HOW TO CONTACT US

If you have any questions or complaints regarding this Privacy Policy or information that you have submitted to us you can contact us at hello@courselle.com or by mail at Geenio Limited, Dimitriou Karatasou, 15, Anastasio Building 6th Floor, Flat/Office 601, Strovolos, 2024, Nicosia, Cyprus.