Protection of Certain Personally-Identifying InformationExoLingo discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on ExoLingo's behalf or to provide services available at ExoLingo's website, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using ExoLingo's website, you consent to the transfer of such information to them. ExoLingo will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, ExoLingo discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when ExoLingo believes in good faith that disclosure is reasonably necessary to protect the property or rights of ExoLingo, third parties or the public at large. If you are a registered user of https://ExoLingo.com and have supplied your email address, ExoLingo may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what's going on with ExoLingo and our products. You can opt out of any and all email activities on the platform as per described by GDPR. We primarily use our blog to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. ExoLingo takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
Aggregated StatisticsExoLingo may collect statistics about the behavior of visitors to its website. ExoLingo may display this information publicly or provide it to others. However, ExoLingo does not disclose your personally-identifying information.
Affiliate DisclosureExoLingo uses affiliate links and does earn a commission from certain links. This does not affect your purchases or the price you may pay.
E-commerceThose who engage in transactions with ExoLingo – by purchasing ExoLingo's services or products, are asked to provide additional information, including as necessary the personal and financial information required to process those transactions. In each case, ExoLingo collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor's interaction with ExoLingo. ExoLingo does not disclose personally-identifying information. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.
Business TransfersIf ExoLingo, or substantially all of its assets, were acquired, or in the unlikely event that ExoLingo goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of ExoLingo may continue to use your personal information as set forth in this policy.
GDPR Privacy NoticeGeneral Data Protection Regulation (GDPR) Article 13 of Regulation EU 2016/679
1. Purpose of this noticeThis Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing. Definitions of certain terms within this notice are explained in the appendix.
2. The Data Controller for personal dataThe Data Controller for the personal data processed by us is the Client Company of ExoLingo (the employer of the natural person whose data is collected, hereafter referred to as the Data Subject). The Data Controller will pass personal data of their users to ExoLingo to manage education on behalf of those users in connection with their business. ExoLingo, as Data Processor acting on the instructions of the Data Controller under a written contract with them, will subsequently use that personal data to facilitate education for the Data Subject. It is this contract which forms the ‘Legal Basis’ for the processing of personal data carried out by ExoLingo in these circumstances. ExoLingo will also become a Data Controller if it collects additional personal data directly from a Data Subject. In these circumstances ExoLingo will be acting under a ‘Legitimate Interest’ to legally process the data for the management of education for the Data Subject and to fulfil the contractual requirements for its Client. ExoLingo also acts as a Data Controller for any personal data held regarding its own employees, and legally processes this data under its Contract of Employment with those Data Subjects.
3. Your RightsAs a Data Subject you have rights under the GDPR. These rights can be seen below. ExoLingo will always fully respect your rights regarding the processing of your personal data, and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.
4. Contact DetailsThe identity and contact details for the Data Protection Officer within ExoLingo is: Andreas Piculell, Chief Engineering Officer ExoLingo (Adresse à ajouter)
5. Data Protection PrinciplesExoLingo has adopted the following principles to govern its collection and processing of Personal Data: Personal Data shall be processed lawfully, fairly, and in a transparent manner. The Personal Data collected will only be those specifically required to fulfil education or other education-related requirements. Such data may be collected directly from the Data Subject or provided to ExoLingo via his /her institution. Such data will only be processed for that purpose. Personal Data shall only be retained for as long as it is required to fulfil contractual requirements, or to provide statistics to our Client Company. Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date. The Data Subject has the right to request from ExoLingo access to and rectification or erasure of their personal data, to object to or request restriction of processing concerning the data, or to the right to data portability. In each case such a request must be put in writing as in Section 3 above. The Data Subject has the right to make a complaint directly to a supervisory authority within their own country. ExoLingo’s Data Protection compliance is supervised by:
CNIL Commission Nationale de l'Informatique et des Libertés 3 Place de Fontenoy TSA 80715 75334 PARIS CEDEX 07 France Tel: +33 (0)220.127.116.11.22 Fax: +33 (0)18.104.22.168.00Personal Data shall only be processed based on the legal basis explained in section 2 above, except where such interests are overridden by the fundamental rights and freedoms of the Data Subject which will always take precedent. If the Data Subject has provided specific additional Consent to the processing, then such consent may be withdrawn at any time (but may then result in an inability to fulfil educational requirements).
6. Transfers to Third PartiesTo fulfil the educational arrangements for a Data Subject it will in most cases be necessary to process personal data via a third party (these will include but are not limited to bug reporting, customer support, and credit card companies). Personal Data shall only be transferred to, or processed by, third party companies where such companies are necessary for the fulfilment of the educational arrangements. Personal Data shall not be transferred to a country or territory outside the European Economic Area (EEA) unless the transfer is made to a country or territory recognised by the EU as having an adequate level of Data Security, or is made with the consent of the Data Subject, or is made to satisfy the Legitimate Interest of ExoLingo in regard to its contractual arrangements with its clients. All internal group transfers of Personal Data shall be subject to written agreements under the Company’s Intra Group Data Transfer Agreement (IGDTA) for internal Data transfers which are based on Standard Contractual Clauses recognised by the European Data Protection Authority. Appendix – Definitions of certain terms referred to above: Personal Data: (Article 4 of the GDPR): ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Processing: (Article 4 of the GDPR): means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction. Legal Basis for Processing: (Article 6 of the GDPR): At least one of these must apply whenever personal data is processed: 1. Consent: the individual has given clear consent for the processing of their personal data for a specific purpose. 2. Contract: the processing is necessary for compliance with a contract. 3. Legal obligation: the processing is necessary to comply with the law (not including contractual obligations). 4. Vital interests: the processing is necessary to protect someone’s life. 5. Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law. 6. Legitimate interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. Data Controller: (Article 4 of the GDPR): this means the person or company that determines the purposes and the means of processing personal data. Data Processor: (Article 4 of the GDPR): means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller. Data Subject Rights: (Chapter 3 of the GDPR) each Data Subject has eight rights. These are: 1. The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to. 2. The right of access; this is your right to see what data is held about you by a Data Controller. 3. The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way. 4. The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed. 5. The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected. 6. The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format. 7. The right to object; the Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing. 8. Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.