Privacy Policy

Our Commitment to Your Privacy

Elab Education Laboratory, for which shall be considered Elab Education Laboratory spółka z ograniczoną odpowiedzialnością spółka komandytowa (limited liability company limited partnership) domiciled in Warsaw, Poland as well as Elab Education Laboratory S.R.L.(limited liability company) domiciled in Rome, Italy as well as Fundacja (Foundation) domiciled in Warsaw, Poland (hereinafter referred to together as “ELAB”) is committed to protecting the privacy of our potential and existing customers. The ELAB privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined below) processed by us, including Personal Data collected or submitted through our websites, mobile applications or through our official social media pages or through other channels online and offline as further described below (collectively the “ELAB Channels”).

If you cannot, or will not, provide us with the personal information we reasonably require, we may not be unable to provide you with the information, goods or services you have requested. ELAB is the administrator for the processing of your Personal Data, as set out in this Privacy Policy, and the scope of data processing will depend on which ELAB product(s) or service(s) you are interested in or have engaged with. Being the administrator means that ELAB is responsible for ensuring that your personal data is processed in compliance with applicable privacy and data protection legislation i.e. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”) or, if applicable, UK General Data Protection Regulation, the Data Protection Act 2018 (the “UK GDPR”).

Personal Data are information or pieces of information that could allow you to be identified, i.e.:
1. Name and contact details (e.g. postal and email address, telephone number),
2. internet account information (e.g. user name, profile picture or social media account ID),
3. country of residence, address,
4. date & place of birth,
5. technical information, e.g. screen/user name, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data, and location data,
6. preferences (e.g. shopping habits, preferred educational courses),
7. company or school name and address,
8. Credit or debit card number,
9. medical condition (e.g. allergies or illness),
10. localization data.
How do we collect Personal Data ? We collect Personal Data in a variety of ways, e.g.:
1. Directly from you, either by you providing the information directly to us or you acting in a manner that provides us with the information, in particular:
  1. Online: For example, if you leave us Personal data when you’re interested in particular the product(s) or service(s), if you subscribe to an event or when you sign up for a newsletter or a brochure, enrol in a product or visit our Website, we collect Personal Data through:
    1. Cookies which allows a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want to pass us information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/,
    2. Pixels which is a code that we place on our website collecting data that helps us track conversions from Social Media ads, optimize ads, build targeted audiences for future ads, and remarket to people who have already taken some kind of action on our website,
    3. Use of mobile application. When you download and use one of our mobile applications, and to the extent allowed by your privacy settings in the application, we track and collect mobile application usage data, such as the date and time the mobile application on your device accessing our servers and what information and files have been downloaded to the mobile application based on your device number,
    4. Your device. Provided that you have enabled that function on your device, we collect the physical location of it to provide you with personalized location-based services and content,
    5. If you browse our sites. We may also collect information about your use of our services through your browser to trace activity on our sites, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the ELAB Channels you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit the ELAB Channels, along with the time of the visit and the page(s) that were visited. These data are only stored and used together with other Personal Data that you have submitted if you have given your consent to do so,
    6. as a result of using Google services. If the user browses our websites using the Google browser or we obtained them using add-ons or other applications provided by Google. These data are stored and used together with the Personal Data provided by the user on the terms set out in https://policies.google.com/technologies/partner-sites.
  2. Online and Offline. When you contact or Corporate affiliates (as defined below), including customer service, sales department or when you enroll for a product or when you use our services:
    1. From our corporate affiliates, such as the local ELAB company that promotes the sales of our services and offers customer service in your country of residence and provides us with the Personal Data that is needed to come to an agreement with you on your order, (hereinafter “Corporate Affiliates”),
    2. From our partner Schools: in your country of destination that provides some of the services that you have ordered from ELAB or it’s Corporate Affiliate that is responsible for the performance of the contract with you for any of our programs or services, (hereinafter “Partner Schools”)
    3. From our business partners, such as local sales agents that promote the sales of our services in your country of residence. We may receive Personal Data from other parties in conjunction with your course/program (hereinafter “Business Partners”)
    4. From service providers, such as providers of IT systems, for example for managing customer relations or payments, scheduling classes or storing learning results; or providers of software and services for digital marketing automation and analytics (hereinafter “Service Providers”),
    5. From companies providing legal assistance or claim handlers who receive information about your debts or claims,
  3. In addition, we can receive personal data from other sources, such as public databases; joint marketing partners such as marketing agencies or providers of software and services for digital marketing automation and analytics; social media platforms, including but not limited to: Facebook, Instagram, Snapchat, Musically, LinkedIn, Twitter, YouTube and messenger services such as WhatsApp or Facebook Messenger; from people with whom you are friends or otherwise connected with on social media platforms, as well as from other third parties.
How do we use Personal Data? Your Personal Data will be processed by ELAB for the purposes of providing you with the products and services that you have ordered or wish to order, for customer service, administrative services or as otherwise necessary to perform the contract between you and us or as further described in this document. We may also use Personal Data for:
1. statistical purposes, calculating usage levels, and helping diagnose server problems with the ELAB Channels as well as to ensure that the ELAB Channels function properly,
2. allowing us to contact and be contacted by other users through the ELAB Channels, as permitted by the applicable product,
3. allowing you to participate on our events, message boards, chat, profile pages and blogs and use other services enabling you to post information and materials,
4. , in addition, if you have given your consent:
  1. analyzing and improving our offers by identifying usage trends, determining the effectiveness of our promotional campaigns and tailoring the ELAB Channels experience and content based on your past activities on the ELAB Channels,
  2. providing you with personalized location-based services and content through the use of your device’s physical location,
  3. marketing of our products and services, including special promotions based on your interests, for example through email marketing solutions such as Salesforce Marketing Cloud’s management software which maintains mailing lists and schedules and modifies email messages based on what recipients read, click-on or forward. All such email communication will include a clear unsubscribe link.
Profiling. ELAB does not use automated data processing for profiling purposes.
Ads personalisation. If ad personalisation is turned on, Google will use your information to make your ads more useful for you. If ad personalisation is off, Google will not collect or use your information to create an ad profile or personalise the ads that Google shows to you. You will still see ads, but they may not be as useful. Ads may still be based on the topic of the website or app that you’re looking at, your current search terms or on your general location, but not on your interests, search history or browsing history. Your information can still be used for the other purposes mentioned above, such as to measure the effectiveness of advertising and protect against fraud and abuse (more: https://policies.google.com/technologies/partner-sites).
How do we share Personal Data? We share your Personal Data with our Corporate Affiliates, Business Partners, Partner Schools and Service Providers both within and outside the EEA and Switzerland. We have put appropriate safeguards in place for transfers of your Personal Data outside the EEA and Switzerland, including the standard data protection clauses adopted by the European Commission, available at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915 and http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087. For more information on standard data protection clauses in place, please see the contact section below. We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
On what do we base our right to collect and use Personal Data? We base our right to collect and use your Personal Data on the need to do so in order to provide you with the services or products that you have ordered from us, or when there is a legitimate interest for us (i.e. the service provider) to use your Personal Data, such as for the marketing of products or services similar to the one(s) you have already purchased from that same legal entity. To the extent we use sensitive Personal Data, we base this on your explicit consent. Sensitive data can for example be information about health, ethnicity or religious beliefs, read more under “Sensitive data”. To the extent that we use your Personal Data to send you offers beyond what is considered to be within our legitimate interest, such as marketing of products and services provided by an ELAB Corporate Affiliates, we base this on your specific consent.
Security. We use appropriate organizational, technical and administrative measures to keep the Personal Data under our control accurate and up-to-date, as well as to protect the Personal Data against unauthorized or unlawful processing and the accidental loss, destruction or damage of the Personal Data.
Unsubscribe. If at any time you wish to stop receiving marketing communications from us you can use the unsubscribe feature in the marketing communication you received or let us know by using the contact information listed in the “Contact Us” section. In your request, please indicate that you wish to stop receiving marketing communications from us. Please note that changes may not be effective immediately. We will endeavor to comply with your request(s) as soon as reasonably practicable.
Third Party Sites. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the ELAB Channels contain a link. The inclusion of a link on ELAB Channels does not imply endorsement of the linked site by us or by our affiliates. Additionally, we may provide you with access to third-party functionality that permits you to share your activities on ELAB Channels to your social media account(s), for example Facebook or LinkedIn. Please note that any information that you provide through the use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this functionality.
How long do we store personal data? We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been communicated. We will keep limited parts of your Personal Data which are necessary for marketing purposes until you withdraw your consent, but in no event for longer than 10 years after your last completed service or delivery of product.
Right to be forgotten. Each data subject has the right to request Elab to delete his personal data immediately, and Elab is obliged to delete this personal data without undue delay, if one of the following circumstances occurs:
1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
2. the data subject withdraws consent on which the processing is based where there is no other legal ground for the processing;
3. the data subject objects to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing;
4. the personal data have been unlawfully processed;
5. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
6. the personal data have been collected in relation to the offer of information society services.
If you are under the age of 16. If you are under the age of 16, you should review this document together with your parent or guardian to make sure you both understand them. We are not responsible for checking your age but sometimes we still do verification checks. If we learn that you are under the age of 16 and that we have collected information about you without consent from your parent or guardian, we will delete the information as soon as possible and you will not be able to use ELAB Channels.
Sensitive Data. We do not generally seek to collect any sensitive Personal Data. Sensitive Personal Data is data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or medical condition, criminal background or trade union membership. In certain situations, this might however be necessary (for example when it’s necessary in order to provide you with the services or products you ordered). We will make sure that we receive your explicit consent to such processing and treat this information securely.
Updates to this Privacy Policy. Our Privacy Policy may change from time to time. We will not significantly reduce your rights under this Privacy Policy without informing you. We will post any Privacy Policy changes on this page and, prior to implementing such changes, we will provide a more prominent notice. Where required by law, we will seek your prior consent to any change.
Your Rights. You have a right to, once per calendar year, contact us and without cost find out which information about you that is being used. You have a right to receive your Personal Data in a machine-readable format and you have a right to transfer your personal to another data controller. You have the right to, at any time, withdraw your consent or object to us using your Personal Data for direct marketing purposes and you may at any time request that the use of your Personal Data is restricted or that we shall delete your Personal Data. Note however that a restriction or deletion could mean that we are not able to provide you with information, services or products as you have requested. Upon your request, we are also obliged to correct Personal Data about you that is incorrect, incomplete or misleading.
Data protection officer. ELAB did not appoint a data protection officer.
Contact Us. If you would like to have a copy of the information ELAB or its Corporate Affiliates holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact us at the address: email: office@elab.edu.pl or postal: Elab Education Laboratory, Nowogrodzka 68, 02-014 Warsaw, Poland. If you have complaints about our handling of your Personal Data, you have a right to contact the supervisory authority in the country where you live.
If you want to know more. This Privacy policy is governed by the following provisions:
1. REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (UE) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (https://eur-lex.europa.eu/legal-content/EN-PL/TXT/?qid=1602765415141&uri=CELEX:32016R0679&from=EN),
2. UK General Data Protection Regulation, the Data Protection Act 2018 (https://www.legislation.gov.uk/ukpga/2018/12/contents/enacted),
3. Act of 18 July, 2002 on Providing Services by Electronic Means (https://www.giodo.gov.pl/data/filemanager_en/51.pdf),
4. Act of 16 July 2004 – Telecommunications Law (http://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20041711800).

Privacy Policy

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