Privacy Policy

Preamble

Welcome to educato, a service provided by Educato Inc. ("us", "we", "our"). Our website, https://educato.ai, and our mobile applications (collectively referred to as the "Services") are designed to enhance your learning experience. This Privacy Policy outlines how we collect, use, and disclose information (hereinafter also abbreviated as "data") about our users ("you", "your") in connection with the Service, and the choices you have regarding your information. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "Online Services").

The terms used are not gender-specific.

Last Update: September 17, 2024

Table of contents

Controller

Educato Inc.
2261 Market St
STE 22351
San Francisco, CA 94114
United States

Authorised Representatives:
Codrut Lemeni
Pierre-Louis Monnot
Felix Gabler

Email Address:  privacy@educato.ai

Imprint:  https://educato.ai/imprint
Terms of Service:  https://educato.ai/terms

Overview of processing operations

This section provides a summary of the types of data we process, the purposes for which they are processed, and the concerned data subjects.

Categories of Processed Data

  • Inventory Data: Such as names and addresses (primarily for registered users).
  • Contact Data: Including email addresses and, if applicable, telephone numbers.
  • Meta/Communication Data: Device information, IP addresses (anonymized where possible).
  • Usage Data: Information on how our services, like websites or apps, are accessed and used, including interaction with content and access times.
  • Payment Data: Details required for processing payments, including billing addresses and payment information, especially for subscribed users.
  • Contract Data: Information related to agreements between you and us, including user terms, subscriptions, and service use.

Categories of Data Subjects

  • Prospective Customers: Individuals interested in our service.
  • Customers: Users who have subscribed to or purchased our services.
  • Users: Individuals who interact with our services, including website visitors and app users.
  • Communication Partners: Recipients of communications, emails, or other interactions related to our service, who may not necessarily be users or customers.

Purposes of Processing

  • Provision of Our Online Services: Including website and app functionality, authentication, and user support.
  • User Communication: Handling contact requests, user feedback, and communication with users.
  • Content Delivery Network (CDN): Utilizing CDNs to efficiently deliver content, reduce loading times, and enhance user experience across our website and applications.
  • Analytics and Improvement: Using tools like PostHog for web analytics, usage analysis, and service improvement.
  • Security Measures: Ensuring the integrity and security of our services.
  • Personalization: Profiling and personalization to enhance user experience, such as suggesting relevant learning content.
  • Payment Processing: Managing subscriptions and payments through Stripe.
  • Automatic Account Deletion: Removing inactive accounts to optimize service performance and manage data effectively.

This section outlines the legal grounds under the General Data Protection Regulation (GDPR) that underpin our processing of personal data. It's important to note that, in addition to GDPR, specific national data protection laws in your or our country of residence or domicile may also apply.

  • Consent (Article 6 (1) (a) GDPR): You have given explicit consent to the processing of your personal data for one or more specific purposes. This may include services that require your consent, such as receiving newsletters or personalized advertisements.
  • Performance of a Contract and Pre-contractual Inquiries (Article 6 (1) (b) GDPR):: Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract. This includes providing our services that you use or registering you as a user.
  • Compliance with a Legal Obligation (Article 6 (1) (c) GDPR): Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Protection of vital interests (Article 6 (1) (d) GDPR): Processing is necessary for compliance with a legal obligation to which we are subject. This may involve legal requirements to retain data for compliance with tax laws or other regulations.
  • Protection of Vital Interests (Article 6 (1) (d) GDPR): Processing is necessary to protect the vital interests of you or another natural person. This could apply in emergency situations where processing personal data is crucial for the protection of life or health.
  • Legitimate Interests (Article 6 (1) (f) GDPR): Processing is necessary for the purposes of legitimate interests pursued by us or a third party, provided that these interests are not overridden by your interests or fundamental rights and freedoms. This includes processing for data management, service optimization, and enhancing user privacy, such as the automatic deletion of inactive accounts. Accounts inactive for over one year may be automatically deleted to manage our user base efficiently and maintain the security of our services.

National Data Protection Regulations in Romania: Complementing the GDPR, Romanian data protection is governed by Law 190/2018, which implements GDPR measures and provides specific national provisions on personal data processing. Additionally, the EU e-Privacy Directive has been incorporated into Romanian law via Law 506/2004, focusing on personal data processing in the electronic communications sector. For e-commerce privacy matters, Law 365/2002, transposing the EU E-commerce Directive, applies. These regulations, alongside guidelines from the National Supervisory Authority for Personal Data Processing (ANSPDCP), establish a comprehensive data protection framework in Romania, addressing aspects such as DPIAs, certification bodies, complaint management, and breach notifications.

Security Precautions

We are committed to protecting the personal data of our users. We implement suitable technical and organizational measures in line with legal requirements, considering the latest technology, implementation costs, and the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of risks to the rights and freedoms of individuals. Our security measures are designed to maintain the confidentiality, integrity, and availability of data. This includes:

  • Access Control: We restrict physical and electronic access to data to authorized personnel only, ensuring that personal data is not accessed, disclosed, altered, or destroyed without authorization.
  • Data Management: We enforce policies for data input, transmission, storage, and deletion, ensuring data is handled securely throughout its lifecycle.
  • Data Separation: Data is processed in a manner that ensures it is kept separate, preventing it from being processed for unauthorized purposes.
  • Incident Response: We have established protocols to rapidly respond to potential data security threats, ensuring the ongoing safety of personal data.
  • Privacy by Design and Default: We integrate data protection principles into the development and selection of our hardware, software, and service providers, adhering to the principles of privacy by design and by default.
  • SSL Encryption (HTTPS): We employ SSL encryption to protect data transmitted through our Online Services. This is evident from the "https://" prefix in the address bar of your browser, signifying that the connection between your device and our services is encrypted and secure.

Transmission and Disclosure of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, payment institutions within the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such a case, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.

Data Processing in Third Countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third party services or disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

Subject to express consent or transfer required by contract or law, we process or have processed the data only in third countries with a recognised level of data protection, which includes US processors certified under the "Privacy Shield" or on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Article 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Use of Cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after his visit within an online service. The information stored can include, for example, the language settings on a website, the login status, a shopping basket or the location where a video was viewed. The term "cookies" also includes other technologies that fulfil the same functions as cookies (e.g. if user information is stored using pseudonymous online identifiers, also referred to as "user IDs").

The following types and functions of cookies are distinguished:

  • Temporary/Session Cookies: These are deleted after you close your browser. They're used to maintain your session and remember your actions during a single visit.
  • Permanent Cookies: These remain on your device even after you close your browser, allowing us to remember your preferences and settings for subsequent visits.
  • First-Party-Cookies: First-Party-Cookies are set by ourselves to ensure the functionality and security of our service.
  • Third-Party-Cookies: Placed by service providers and partners, such as analytics tools like PostHog, to provide additional functionality or to help us understand service usage patterns.
  • Necessary/Essential Cookies: Essential for the operation of our service, enabling basic functions like page navigation and access to secure areas.
  • Statistics, Marketing, and Personalization Cookies: Used to gather analytics, enhance marketing efforts, and provide personalized content based on your interests and interactions with our service.

Information on Legal Basis:The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this applies and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in a business operation of our online service and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

General Information on Withdrawal of Consent and Objection (Opt-Out): Respective of whether processing is based on consent or legal permission, you have the option at any time to object to the processing of your data using cookie technologies or to revoke consent (collectively referred to as "opt-out"). You can initially explain your objection using the settings of your browser, e.g. by deactivating the use of cookies (which may also restrict the functionality of our Online Services). An objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com. In addition, you can receive further information on objections in the context of the information on the used service providers and cookies.

Processing Cookie Data on the Basis of Consent: We prioritize your privacy and control over your personal data. We request your consent for the use of cookies, except for those strictly necessary for the operation of our Online Services, before processing any data related to cookie usage. Your consent is freely given and can be revoked at any time, ensuring you have full control over your personal data.

  • Processed Data Types: Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data Subjects: Users (e.g. website visitors, users of Online Services).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Commercial Services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries.

We process this data in order to fulfil our contractual obligations, safeguard our rights and for the purposes of the administrative tasks associated with this data and the business-related organisation. We will only pass on the data of the contractual partners within the scope of the applicable law to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g. telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further processing, e.g. for marketing purposes, as part of this privacy policy.

Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.

We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving (e.g., as a rule 10 years for tax purposes). In the case of data disclosed to us by the contractual partner within the context of an assignment, we delete the data in accordance with the specifications of the assignment, in general after the end of the assignment.

If we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

Customer Account: Contractual partners can create a customer or user account. If the registration of a customer account is required, contractual partners will be informed of this as well as of the details required for registration. The customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent registration and use of the customer account, we may store the IP addresses of the contractual partners along with the access times, in order to be able to prove the registration and prevent any misuse of the customer account.

If customers have terminated their customer account, their data will be deleted with regard to the customer account, subject to their retention is required for legal reasons. It is the responsibility of the customer to secure their data upon termination of the customer account.

Mobile Application: We process the data of the users of our services, registered and any test users (hereinafter uniformly referred to as "users") in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our services and to develop them further. The required details are identified as such within the scope of the conclusion of a contract for the use of the services, the conclusion of an order, an order or a comparable contract and may include the details required for the provision of services and any invoicing as well as contact information in order to be able to hold any consultations. If our apps are purchased from platforms of other app suppliers (e.g. Apple's App Store or Google Play), the terms and conditions and data protection notices of the respective platforms apply in the relationship between the users and the app suppliers.

  • Processed Data Types: Inventory Data (e.g. names, addresses), Contact Data (e.g. e-mail, telephone numbers), Payment Data (e.g. bank details, invoices, payment history), Contract Data (e.g. contract object, duration, customer category), Usage Data (e.g. websites visited, interest in content, access times), Meta/Communication Data (e.g. device information, IP addresses).
  • Special Categories of Data: Health Data (Article 9 (1) GDPR), Data related to sexual preferences, sex life, and/or sexual orientation (Article 9 (1) GDPR), Rreligious or philosophical beliefs (Article 9 (1) GDPR), Data revealing racial or ethnic origin, Biometric data (Article 9 (1) GDPR), Genetic data (Article 9 (1) GDPR), Political opinions.
  • Data subjects: Prospective Customers, Customers.
  • Purposes of Processing: Contractual services and support, contact requests and communication, Office and organisational procedures, Managing and responding to inquiries, Security measures, Conversion Tracking, Interest-based and behavioral marketing, Profiling (Creating user profiles).
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Provision of Online Services and Web Hosting

In order to provide our Online Services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers they manage) the Online Services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.

The data processed within the framework of the provision of the hosting services may include all information relating to the users of our Online Services that is collected in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of Online Services to browsers, and all entries made within our Online Services or from websites.

E-Mail Sending and Hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The above data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and reception on our server.

Collection of Access Data and Log Files: We, ourselves or our web hosting provider, collect data on the basis of each access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a general rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers .

Content-Delivery-Network: We use a so-called "Content Delivery Network" (CDN). A CDN is a service with whose help contents of our Online Services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.

  • Processed Data Types: Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data Subjects: Users (e.g. website visitors, users of Online Services).
  • Purposes of Processing: Provision of our Online Services and usability, Content Delivery Network (CDN).
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

Registration and Login

Users can create a user account. Within the scope of registration, the required mandatory information is communicated to the users and processed for the purposes of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purposes of using the user account and its purpose.

Users may be informed by e-mail of information relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

Within the scope of using our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

  • Processed Data Types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Meta/communication data (e.g. device information, IP addresses).
  • Data Subjects: Users (e.g. website visitors, users of Online Services).
  • Purposes of Processing: Contractual services and support, Security measures, Managing and responding to inquiries.
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Single Sign-On Authentication

"Single Sign-On" or "Single Sign-On Authentication or Logon" are procedures that allow users to log in to our Online Services using a user account with a provider of Single Sign-On services (e.g. a social network). The prerequisite for Single Sign-On Authentication is that users are registered with the respective Single Sign-On provider and enter the required access data in the online form provided for this purpose, or are already logged in with the Single Sign-On provider and confirm the Single Sign-On login via the button.

Authentication takes place directly with the respective single sign-on provider. Within the scope of such authentication, we receive a user ID with the information that the user is logged in with the respective single sign-on provider under this user ID and an ID that cannot be used for other purposes (so-called "user handle"). Whether we receive further data depends solely on the single sign-on procedure used, the data releases selected as part of authentication and also which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user's choice, there can be different data, usually the e-mail address and the user name. The password entered by the single sign-on provider as part of the single sign-on procedure is neither visible to us nor is it stored by us.

Users are requested to note that their data stored with us can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actual. If, for example, the e-mail addresses of users change, users must change these manually in their user account with us.

We can use single sign-on authentication, provided that it has been agreed with users in the context of pre-fulfillment or fulfilment of the contract, in the context of consent processing and otherwise use it on the basis of our legitimate interests and the interests of users in an effective and secure authentication system.

Should users decide to no longer want to use the link of their user account with the Single Sign-On provider for the Single Sign-On procedure, they must remove this link within their user account with the Single Sign-On provider. If users wish to delete their data from us, they must cancel their registration with us.

  • Processed Data Types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Usage data (e.g. websites visited, interest in content, access times), Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
  • Data Subjects: Users (e.g. website visitors, users of Online Services).
  • Purposes of Processing: Provision of contractual services and customer support, Security measures, Authentication processes.
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

Special Notes on Applications (Apps)

We process the data of the users of our application to the extent necessary to provide the users with the application and its functionalities, to monitor its security and to develop it further. Furthermore, we may contact users in compliance with the statutory provisions if communication is necessary for the purposes of administration or use of the application. In addition, we refer to the data protection information in this privacy policy with regard to the processing of user data.

Legal Basis: The processing of data necessary for the provision of the functionalities of the application serves to fulfil contractual obligations. This also applies if the provision of the functions requires user authorisation (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimising the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly requested to give their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.

Commercial Use: We process the data of the users of our application, registered and any test users (hereinafter uniformly referred to as "users") in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our application and to develop it further. The required details are identified as such within the scope of the conclusion of a contract for the use of the application, the conclusion of an order, an order or a comparable contract and may include the details required for the provision of services and any invoicing as well as contact information in order to be able to hold any consultations.

Storage of the Universally Unique Identifier (UUID): The application stores a so-called Universally Unique Identifier (UUID) for the purpose of analysing the use and functionality of the application and storing the user's settings. This identifier is generated when the application is installed, remains stored between the start of the application and its updates and is deleted when users remove the application from their device.

  • Processed Data Types: Inventory data (e.g. names, addresses), Meta/communication data (e.g. device information, IP addresses).
  • Data Subjects: Users (e.g. website visitors, users of Online Services).
  • Purposes of Processing: Contractual services and support.
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Payment Procedure

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively referred to as "payment service providers"). The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers. The terms and conditions and data protection information of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of revocation, information and other data subject rights.

  • Processed Data Types: Inventory data (e.g. names, addresses); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status).
  • Data Subjects: Customers; Prospective customers.
  • Purposes of Processing: Provision of contractual services and customer support.
  • Legal Basis: Performance of a contract and prior requests (Article 6(1)(1)(b) GDPR; Article 31(1) and 2(b) Swiss Data Protection Act).

Further information on processing methods, procedures and services used:

  • Stripe: Payment-Service-Provider (technical integration of online-payment-methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal Basis: Performance of a contract and prior requests (Article 6(1)(1)(b) GDPR; Article 31(1) and 2(b) Swiss Data Protection Act); Website: https://stripe.com/en; Privacy Policy: https://stripe.com/en/privacy.

Purchase of Applications via App Stores

The purchase of our apps is done via special online platforms operated by other service providers (so-called "app stores"). In this context, the data protection notices of the respective app stores apply in addition to our data protection notices. This applies in particular to the methods used on the platforms for webanalytics and for interest-related marketing as well as possible costs.

  • Processed Data Types: Inventory data (e.g. names, addresses), Payment Data (e.g. bank details, invoices, payment history), Contact data (e.g. e-mail, telephone numbers), Contract data (e.g. contract object, duration, customer category), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers.
  • Purposes of Processing: Contractual services and support.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

Contacting us

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the inquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested activities.

The response to contact enquiries within the framework of contractual or pre-contractual relationships is made in order to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of the legitimate interests in responding to the enquiries.

  • Processed Data Types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
  • Data Subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: Contact requests and communication.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Web analysis, Monitoring and Optimization

Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our Online Services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.

In addition to web analysis, we may use various tracking technologies, including pixels and cookies, from third-party providers such as social media platforms and advertising networks. These technologies help us understand user behavior, measure the effectiveness of our marketing efforts, and provide more relevant content and advertisements.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our Online Services or their components.

Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

Unless otherwise stated below, profiles, that is data summarized for a usage process or user, may be created for these purposes and stored in a browser or terminal device (so-called "cookies") or similar processes may be used for the same purpose. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data or profiles to us or to the providers of the services we use, these may also be processed, depending on the provider.

The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

Note: Exceptions include services like Sentry, which are used for monitoring system stability and identifying code errors. For these services, information such as email addresses, user IDs, and pseudonymised IP addresses can be stored to facilitate error resolution.

Information on Legal Basis: If we ask the users for their consent to the use of third party providers, the legal basis of the processing is consent. Furthermore, the processing can be a component of our (pre)contractual services, provided that the use of the third party was agreed within this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Processed Data types: Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Contact data (e.g., email addresses), Identifiers (e.g., user IDs).
  • Data subjects: Users (e.g. website visitors, users of Online Services).
  • Purposes of Processing: Web Analytics (e.g. access statistics, recognition of returning visitors), Conversion Tracking, Server monitoring and error detection, Provision of our Online Services and usability.
  • Security measures: IP Masking (Pseudonymization of the IP address).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Services and service providers being used:

  • Google Analytics: Web analytics and audience measurement service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://adssettings.google.com/authenticated.
  • PostHog: Web analysis and reach measurement - Collection of information about the use of the online offering by users in relation to its functions, content, and duration of use; Service provider: Executed on servers and/or computers under our controllership; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Website: https://posthog.com; Privacy Policy: https://posthog.com/privacy.
  • Sentry: Monitoring of system stability and identification of code errors, details of the device or time of error will be collected pseudonymously and deleted subsequently; Service provider: Functional Software Inc., Sentry, 132 Hawthorne Street, San Francisco, California 94107, USA; Website: https://sentry.io; Privacy Policy: https://sentry.io/privacy.
  • Other Tracking Technologies: We may use additional tracking technologies, such as pixels from social media platforms and advertising networks (e.g., Reddit), to enhance our marketing efforts and provide more relevant content. These technologies are subject to the user's consent and can be managed through our cookie consent dialog.

Erasure of data

The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose). This includes the automatic deletion of personal data from user accounts that have been inactive for a period of one year. Inactivity is defined as the lack of user-initiated activity, such as logging in or interacting with our services. Users will be notified in advance of the impending deletion of their data due to inactivity, providing them an opportunity to interact with our services and prevent such deletion.

If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

Further information on the erasure of personal data can also be found in the individual data protection notices of this privacy policy. Additionally, we offer users the option to independently delete their accounts and associated data. Detailed instructions for this can be found on our dedicated account deletion guide.

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

Rights of Data Subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 of the GDPR:

  • Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data based on Article 6(1) (e) or (f) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of Withdrawal for Consents: You have the right to revoke consents at any time.
  • Right of Access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
  • Right to Rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
  • Right to Erasure and Right to Restriction of Processing: You have the right to demand immediate erasure of your data or to demand restriction of the processing of your data, which includes data related to our policy of automatic account deletion due to inactivity, in accordance with the statutory provisions.
  • Right to Data Portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Complaint to the Supervisory Authority: You also have the right, under the conditions laid down by law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

If you wish to exercise any of these rights, please send us an email at privacy@educato.ai.

Supervisory authority competent for us:

National Supervisory Authority for Personal Data Processing (ANSPDCP)

B-dul G-ral. Gheorghe Magheru 28-30, Sector 1
010336, Bucharest
Romania

Phone: +40.318.059.211
Fax: +40.318.059.212

Email: anspdcp@dataprotection.ro
Homepage: https://www.dataprotection.ro

Terminology and Definitions

This section provides an overview of the terms used in this privacy policy. Many of the terms are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all for the purpose of comprehension. The terms are sorted alphabetically.

  • Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Conversion Tracking: "Conversion Tracking" refers to a procedure by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures are carried out and then called up again on the target website (e.g. this enables us to track whether the ads we placed on other websites were successful).
  • Cross-Device Tracking: Cross-Device Tracking is a form of tracking in which behavior and interest information of the user is recorded across all devices in so-called profiles by assigning an online identifier to the user. This means that user information can usually be analysed for marketing purposes, regardless of the browser or device used (e.g. mobile phone or desktop computer). With most Cross-Device Tracking providers, the online identifier is not linked to plain data such as names, postal addresses or e-mail addresses.
  • IP Masking: IP masking is a method by which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address alone can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, particularly in online marketing.
  • Interest-based and behavioral marketing: Interest-related and/or behaviour-related marketing is the term used when potential user interest in advertisements and other content is predicted if possible. This is done on the basis of information on the previous behaviour of users (e.g. visiting and staying on certain websites, purchasing behaviour or interaction with other users), which is stored in a so-called profile. For these purposes cookies are usually used.
  • Personal Data: "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: The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Profiling: "Profiling" means any automated processing of personal data consisting in the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information regarding age, gender, location and movement data, interaction with websites and their contents, shopping behaviour, social interactions with other people) (e.g. interests in certain contents or products, click behaviour on a website or the location). Cookies and web beacons are often used for profiling purposes.
  • Remarketing: Remarketing" or "retargeting" is the term used, for example, to indicate for advertising purposes which products a user is interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Server monitoring and error detection: With the help of server monitoring and error detection, we ensure the availability and integrity of our online service and use the data processed in this process to technically optimise our Online Services. For this purpose, performance, utilization and comparable technical values, which provide information about the stability and any conspicuous features of our online offer, are processed. In the event of errors and irregularities, individual requests from users of our Online Services are recorded in order to identify and eliminate sources of problems.
  • Targeting: "Tracking" is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.
  • Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to optimize the content of the website to better meet the needs of their visitors. For purposes of web analytics, pseudonymous cookies and web beacons are frequently used in order to recognise returning visitors and thus obtain more precise analyses of the use of an online service.