Updated: 06 April 2020
The Rose & Victoria Ventures Ltd (“Learntinue”, “we”, “us” “our”) welcomes you to the Learntinue Service. The “Learntinue Service” includes the Learntinue website, application and associated content and services.
It is Learntinue’s policy to respect your privacy regarding any information we may collect while using our software applications and websites, collectively called the Services.
Learntinue operates a suite of web-based applications (customers, content providers and reviewers ) collective called Learntinue applications. All such products, applications, websites are collectively called “Services”.
Data Controller and Data Processor
We process two main types of personal data.
- Customer Data – Personal data that forms part of the data that is provided by our customers for their learning experience, this includes data of additional profiles created by our customers to leverage individualised experience.
- Other Data – Personal data about our customers, visitors and other individuals that are collected and processed directly by us. Examples include your age group, location and usage of our various services.
Our Customers are the controller of Customer Data. Learntinue is the processor of Customer Data and is also the Controller of Other Data.
Domains and Websites for this Policy
For the purposes of this Policy, the term, “Websites”, shall refer collectively to www.learntinue.ai as well as the other pages that Learntinue operates and that link to this Policy.
Information We Collect
As customers, you provide data to us for processing as part of the usage of our Learntinue application.
Customer Data may be processed by us as a result of customer’s use of the Services when our customers, or additional users they have added as profiles under their account. For example, customers who use our Learntinue application may upload Customer Data about themselves and can create profiles for additional members which could be their family members, partners or friends with whom they are sharing our subscription service.
This data includes name, email address, age group and interests. We collect billing details for invoice purposes.
Customers provide data that is necessary to create user accounts and additional profiles as needed.
For the creation of user accounts, customers provide their name, email address and password. For profiles, customers provide name, month and year of birth referred to as age group and academic year. The main user also provides billing details for invoicing purposes.
We also collect data when you use our applications and websites
- Log Data – Our servers automatically collect information when you access or use our applications and services. This data is recorded in log files. Examples of such data include IP Address
- Mobile Application – When you download and use our Services, we automatically collect information on the type of device you use, and operating system version.
- Subscription Data – You provide personal data to us as part of signing up on our websites. We may also collect personal information from you when you use interactive features of the Websites, promotions, requesting customer support, or otherwise communicating with us.
- Contact Us Data – When you enquire about our products and services, we collect and store this data to communicate with you and respond to your enquiry.
Data from Others
Learntinue may receive your data from sources other than from you, such as social networking sites, digital marketing sites and other public websites.
We collect data through cookies
How We Use Your Data
How we use your personal data will depend on which Services you use and how you use those Services.
Other Data is used by us to provide our services, send our newsletters and to communicate with you by responding to your requests, comments and questions.
Lawful bases for processing
We have lawful bases to process your personal data. We also use your consent as bases for lawfully processing your personal data.
We process your personal data only when we have a lawful basis. Presently, we use the Terms & Services agreement (i.e. to deliver the services to our customers) and consent as the lawful basis for processing. For certain processing, such as specific direct marketing, we may also use legitimate interests as provided under the Data Protection Regulations.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where you have consented to a particular processing, you have a right to withdraw the consent at any time.
How we use Customer data
We use your data to authenticate you and authorize access to our services
We only process Customer Data on behalf of our customers and in accordance with their instructions provided in the applicable Services agreement with us. We use the data that we have about you to provide our services and provide support to you. In each case, Learntinue collects such information only in so far as is necessary or appropriate to fulfil the purpose of the interaction with our services.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services and our Services offerings. These communications are considered part of the Services and you may not opt-out of them.
- Customer Support. If you send us a request (for example via a support email or via one of our feedback mechanisms), we respond to your request or to help your issues. We may also gain access to the personal data stored within the Learntinue application as a result of the support.
- For any other purpose as provided for in the Terms & Services Agreement between us and the customer, or as otherwise authorized by the customer;
- In accordance with or as may be required by law.
How we use Other data
We may send you service related messages or marketing / promotional materials. You may choose to restrict the collection or use of your personal information
We will update you with improvements in our services, new features and from time to time also carry out direct marketing of our products and services. Direct marketing is carried out only if you consent to receiving such communications from us or we have a legitimate purpose for doing so.
Users under 16 years of age
Our main profile user has to be an adult over 16 years of age, the adult profile member can create multiple profiles linked to his account which could be of any age group.
Our main profile user is solely responsible for usage of the system by him or any profile member linked to his profile.
We only collect age group, academic year, nickname and provide a choice of profile avatars to chose from for each additional profile.
Data Retention Policy
Customer Data – We retain your information for as long as you have an active Services account. We may also retain your personal information for an extended period under applicable statutory laws.
Learntinue will retain Customer Data in accordance with customer’s instructions, including any applicable terms in the customer agreement and as required by applicable law. When you decide to close your account, we delete all personal information about you within a specific period.
You can request to access, update or correct your personal information. You also have the right to object to direct marketing.
You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation (“GDPR”), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.
Your Rights to Control Data
Whenever you use our services, we aim to provide you easy means to access, modify, delete, object to or restrict use of your personal information
We strive to give you ways to access, update/modify your data quickly or to delete it unless we have to keep that information for legal purposes. Some rights can be accessed from within the Learntinue application. For visitors, these rights can be exercised by contacting us with your specific request.
- Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
- Delete Data: You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to provide Services to you).
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g. if we have no legal right to keep using it) or to limit our use of it (e.g. if your personal data is inaccurate or unlawfully held).
- Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
We keep some personal data even after account closure
Once you choose to close your account, we generally delete your personal information within 30 days of closure of your account. Some information that is necessary for statutory obligations such as records of payment processing, invoicing data will be retained as necessary.
Your information shared with others
Recipients of your data
Your data will be shared with other recipients in order to provide you with services.
While we aim to limit the sharing of your data, at times, it is necessary to share your data with certain service providers. Examples of when and for what purpose your data is shared include data center / hosting services, email marketing services, etc.
The following categories of recipient will most likely receive your data in order for us to provide services to you
- AWS as third Party Data Center Services
- Outlook and Google connectors are used to push/pull data from your email applications
- Other modules of Learntinue applications to which you may or may not have subscribed to
- MS Office (specifically) Outlook 365 for email communications
- Our content providers regarding content usage statistics and to be able to source the right type of content
To Comply with Laws. – If we receive a request for information, we may disclose if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
Cross-Border Data Transfers
Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region
Since we are an international company, your data will be processed in the region of our choice e.g. the EU region or US region. Your data will be processed within Third-Party Data Centers in that specific region. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such transfer.
Security Measures to Protect your Data
We have implemented security controls to prevent breaches and unauthorised access to your data.
We maintain reasonable and appropriate security measures to protect Customer Data and Other Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Examples of security measures include physical access controls, HTTPS, restricted access to data, monitoring for threats and vulnerabilities etc.
We also subject our services to internationally recognised certification and attestation standards. Details about our security measures are available on our website.
Protection of personal information
Our Sites and Services uses commercial efforts to maintain safeguards for protection of your Personal Information
Learntinue takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
If you have questions or complaints regarding this Policy, you may contact us through email at email@example.com or through the “Contact Us” section on our website www.learntinue.ai
If you are a resident of the European Economic Area and we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you have additional rights. If you are not satisfied with the resolution, you can also lodge a complaint with the Supervisory Authority in the country of your residence.
This software is a collective work consisting of the following major Open Source components: Apache software, MySQL server, PHP, SugarCRM, ADOdb, Smarty, PHPMailer, phpSysinfo, MagpieRSS, vTiger and others, each licensed under a separate Open Source License. Learntinue is not affiliated with nor endorsed by any of the above providers.