1. Personally Identifiable Information We Collect, Lawful Basis For Processing Personal Data And How We Use It
If you request to receive company or product information, or reqeuest information about specific Services, or provide comments about Services, you will be asked to provide contact information so that we can complete your request. We use this Site Information to fulfill your request. We may also use this Site Information to send you additional information about our Services or Courses on the Site that you may be interested in.
Some of the Services require that you become a registered user and create a user account. This will require that you provide certain personally identifiable information, that may include (but not be limited to) your (and if you are enrolling as part of our EdStep for Business program) your company’s name, e-mail address, as well as telephone and address information.
You allow us to use this personally identifiable Site Information to register you to use the Services, enroll in Courses, and otherwise provide you with the Services; verify your authority to enter the Site and access the Courses and Services; notify you of updates; improve the content and general administration of the Site and the Services; provide you with notices regarding the Services and other services that you have purchased or may wish to purchase in the future.
You also consent to our providing this personally identifiable information to Instructors as part of the Course Information when you enroll in a Course. Instructors will use this Course Information to provide the Course to you. Instructors may have other users for Course Information. It is your responsibility when you enroll in a Course to confirm what uses the Instructor will make of your personally identifiable Course Information. EdStep does not control these uses by Instructors.
EdStep processes Personal Data both as a Processor and as a Controller, as defined in the GDPR.
2. Other Information We Collect and How We Use It
EdStep may also automatically collect and analyze Site Information about your general usage of the Site, Services and Courses. We might track your usage patterns to see what features of the Site, Services and Courses you commonly use, Site traffic volume, frequency of visits, type and time of transactions, type of browser, browser language, IP address and operating system, and statistical information about how you use the Services and Courses. We only collect, track and analyze such Site Information in an aggregate manner that does not personally identify you. This aggregate data may be used to assist us in operating the Site and the Services and provided to other third parties to enable them to better understand the operation of the Services, and improve their Course offerings, but such information will be in aggregate form only and it will not contain personally identifiable data.
Instructors may collect non-personally identifiable Course Information in connection with your participation in Courses. This Course Information may include, but not be limited to, your interaction with the Instructor and other Users, comments you leave on Course forums, answers or essays you submit to satisfy Course requirements, and so forth. As noted above, it is your responsibility to review the Instructor’s policy in connection with all Course Information and decide whether or not you want to provide such Course Information.
Cookies are very small text files that are stored on your computer when you visit some websites. We use a combination of session cookies and persistent cookies in order to track how you use and experience our website, build anonymous statistical data about how our website is performing, and to power the personalisation of website content to you. You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu.
3. For Which Purposes Do We Share Personal Data
We sometimes contract with other companies to perform functions or services on our behalf, such as software maintenance, data hosting, sending email messages, etc. We necessarily have to share your Personal Data with such third parties as may be required to perform their functions. We take steps to ensure that these parties take protecting your privacy as seriously as we do, including entering into Data Processing Addendum, EU Model Clauses and/or ensuring they have EU-U.S. and Privacy Shield certification.
Third Party Service Providers
We use Sentry’s (https://sentry.io) application monitoring and error tracking platform to help our developers diagnose, fix, and optimize the performance of their code. Processing takes place in the United States. Sentry is also self-certified under the US-EU Privacy Shield program and we have a Data Processing Addendum with EU Standard Contractual Clauses in place with them. For more information on data protection visit Sentry: https://sentry.io/privacy/.
4. Data Retention
We retain Site Information and the personal data we process on behalf of Users for as long as needed to provide the Services. We will retain and use this personal Site Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements with Users, and/or the period required by laws in applicable jurisdictions. Please see the sections above for how Course Information may be used.
5. Updating, Correcting and Deleting Your Information; Opt-out
Access to your personal information
You have the right to view, amend, or delete the personal information that we hold about you. To request access please email firstname.lastname@example.org. We will provide the information free of charge and within one month, except in the event that the request is unfounded, excessive or repetitive, in which case we reserve the right to charge a proportionate administration fee or refuse.
Rectification of personal information
If any of the information we hold on you is inaccurate or incomplete, you make ask us to correct or complete it at any time. That is, if you believe that EdStep has incorrect Site Information or Course Information that was provided as part of the Services, you may use the Services to correct, amend, or delete that information. You may also contact us by e-mailing our customer support at email@example.com. We can only alter Course Information that was initially provided to us; you need to contact the Instructor for other purposes.
Your right of erasure, or to be forgotten
You may request the deletion of your EdStep account and any additional information we hold on you at any time.
Be aware that requesting deletion, is total and irreversible. This means that we will also lose record of you having ever been on our systems, including any previous instructions you have given us to delete your personal information. If you re-join our systems, by voluntarily providing your personal information, you will appear to us as a completely new data subject. This does not affect your other rights in any way.
To request deletion of your personal information, contact firstname.lastname@example.org using the email address we hold for you or otherwise proving your identity.
From time to time, we may send you emails about Course or new or modified Services that we believe might interest you. If you wish to opt-out of receiving these materials, you may follow the unsubscribe procedure provided in the email.
The security of your personal information is important to us. EdStep employs procedural and technological measures to protect your personally identifiable information. These measures are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. We may use software, secure socket layer technology (SSL) encryption, password protection, firewalls, internal restrictions and other security measures to help prevent unauthorized access to your personally identifiable information. However, EdStep cannot guarantee that unauthorized third parties will never be able to defeat these measures or use your personally identifiable information for improper purposes. Therefore, you should be aware that when you voluntarily display or distribute personally identifiable information, that information could be collected and used by others. EdStep is not responsible for the unauthorized use by third parties of information you post or otherwise make available publicly.
7. Links to Other Websites
The Site, Services and in particular the Courses, may provide links to third party web sites or resources not associated with us and over which we do not have control (“External Web Sites”). Such links do not constitute an endorsement by EdStep of the External Web Sites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that EdStep is only providing these links as a convenience, and cannot be responsible for the content of such External Web Sites.
8. Material Changes
9. Contact Us