ESCOOLA Privacy Policy

ESCOOLA respects your privacy and is committed to protecting Data. This Privacy Policy will inform you as to how we look after Data when you visit and use our Platform (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

GLOSSARY

You OR Your: shall refer to the users of our Platform.

Platform: shall refer to ESCOOLA Application and/or Website whereby its Services shall be used.

Data: the information that we collect from you while using the Platform.

Services: means ESCOOLA services provided through Escoola’s platform.

Account: shall refer to the User account on the Platform.

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how ESCOOLA collects and processes Data through your use of our Platform, including any Data you may provide through this Platform when you register and/or use our Services, as well as sign up to our Platform.

It is important that you read this Privacy Policy along with our Terms and Conditions when we are collecting or processing Data about you so that you are fully aware of how and why we are using this Data. This Privacy Policy supplements other notices and Privacy Policies and is not intended to override them.

CONTROLLER

ESCOOLA is the controller and is responsible for Data (referred to as 'ESCOOLA', 'we', 'us' or 'our' in this Privacy Policy). ESCOOLA is the controller and responsible for this Platform. If you have any questions about this Privacy Policy, please contact us using the details set out below.

CONTACT DETAILS

If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us through the email address:

E-mail address: [email protected]

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US

We keep our Privacy Policy under regular review. It is important that the Data we hold about you is accurate and current. Please keep us informed if Data changes during your relationship with us.

THIRD PARTY LINKS

This Platform may include links to third-party Platforms and plug-ins. Clicking on those links or enabling those connections may allow third parties to collect or share Data about you. We do not control these third-party Platforms and we are not responsible for their privacy statements. We recommend you read the Privacy Policy of every Platform you visit.

DATA THAT WE COLLECT

Data means any information about an individual from which that person can be identified. It does not include Data where the identity has been removed (anonymous Data). We may collect, use, store and transfer different kinds of Data about you, which include, but not limited to the following:

We also collect, use and share aggregated Data such as statistical or demographic Data for any purpose. Aggregated Data could be derived from Data but is not considered Data in law as this Data will not directly or indirectly reveal your identity. For example, we may aggregate your usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect aggregated Data with Data so that it can directly or indirectly identify you, we treat the combined Data as Data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE DATA

Where we need to collect Data by law, by using our Platform, and you fail to provide the required Data, we may not be able to perform our Services. We will notify you if this is the case at the time.

HOW IS DATA COLLECTED

We use different methods to collect Data from and about you through:

HOW WE USE DATA

To the extent possible, we want to provide you with relevant content and a tailored experience when you use our Services, and we use Data about you to do that. We will only use Data when the law allows us to. Most commonly, we will use Data in the following circumstances:

Generally, we do not rely on consent as a legal basis for processing Data although we will get your consent before sending third party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE DATA

A) Performance of our Services: We process Data because it is necessary for the performance of our Services through our Platform. In this respect, we use Data for the following:

In this respect, we may share Data with or transfer it to the following:

B) Legitimate interests: We also process Data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of a third party. In this respect, we use Data for the administration and management of our business, marketing purposes, archiving or statistical analysis.

C) Legal Compliance: We also process Data for our compliance with a legal obligation which we are under. In this respect, we will use Data for the following:

D) MARKETING: We will send you marketing communications about Services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters, notifications for discounts and deals, or functions that we believe might be of interest to you or in order to update you with information which we believe may be relevant to you. We will communicate this to you in a number of ways including by telephone, SMS, e-mail or other digital channels as appropriate.

E) COMMUNICATION:

F) PROMOTIONAL OFFERS FROM US: We may use Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which merchants, products, Services, discounts and deals may be relevant to you. You will receive marketing communications from us in case of using our Platform, and you have not opted out of receiving these marketing communications.

G) Third-party marketing:

H) COOKIES: You can set your browser to refuse all or some browser cookies, or to alert you when the Platform set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly.

I) CHANGE OF PURPOSE: We will only use Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contacts us on the e-mail address [email protected]. If we need to use Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

J) Opting out: We are committed to protecting your data. Opting out of marketing communications will not affect your account and account data.

DISCLOSURE OF DATA

We may share Data with the parties set out in the section on how we collect data in relation to the specified purposes for which we will use the Data above. We may share Data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use Data in the same way as set out in this Privacy Policy.

CHILDREN DATA

Children are defined as, individuals who are under the age of 18, or who have reached the age of privacy consent specified in your jurisdiction, or who have reached the age of legal capacity to enter into a contract according to the laws applicable in their country of residence if the data is processed on the basis of a contract. We will only collect or process information about children as required to provide the best level of service. We may need to collect personal information about children as part of our Service if the personal information is required. A child’s registration and payment processing on our Platform constitutes implied parental or guardian consent. If we learn that we have processed a child’s personal information without valid parental or guardian consent, we will delete the personal information.

DATA SECURITY

We have put in place appropriate security measures to prevent Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to Data to those employees, contractors, third party service providers and other parties who have a valid need to know. They will only process Data in accordance with our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How long will we use Data? We will only retain Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for Data, we consider the amount, nature and sensitivity of the Data, the potential risk of harm from unauthorized use or disclosure of Data, the purposes for which we process Data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, or other requirements. When it is no longer necessary to retain Data, we will delete it.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access Data (or to exercise any of your other rights). This is a security measure to ensure that Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information to improve our Services.

HOW WE DEAL WITH THE ‘’RIGHT TO ELEMENATE YOUR DATA’’?

You have the right to request the erasure of Data that we hold about you in certain circumstances, for example, if it were not acquired for, or has ceased to be necessary for, a lawful purpose. This is known as the right to be forgotten. Where you request that we erase your Data, we will usually only do so where the Data has ceased to be publicly available or where we no longer use it.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best Service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process Data or for our legitimate interests. We prioritize your privacy and well-being. We will not use your data for activities that could harm you or violate your rights. Our commitment to ethical data practices ensures that your personal information is protected and used responsibly (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing Data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties: Professional advisers acting as processors or joint controllers including lawyers, bankers and auditors as the case may be, who provide consultancy, banking, legal and accounting services.

YOUR LEGAL RIGHTS