Privacy Policy
Last modified: March 11, 2025
Privacy Policy
This privacy policy describes how we process personal data in the EdTool System and how its users can exercise their privacy rights.
Definitions
In this document, we use capitalized terms whose definitions are set out in Terms of Use. In addition, the following additional definitions apply to this Privacy Policy:
“Personal Data” means any information that identifies a natural person or can be used to identify a natural person, directly or indirectly. Examples of Personal Data include, but are not limited to: name, surname, e-mail address, profession or similar.
“Privacy Policy” means this privacy policy.
Who are we?
Learnetic is an educational technology company offering its products and services in dozens of countries around the world. Therefore, we take the utmost care to ensure the privacy and security of our users. We also make sure to ensure the greatest possible transparency in the processing of data we collect in our systems.
We operate globally and, as an entity based in the European Union, we process the data of our users, regardless of their place of residence, in a manner no less restrictive than that resulting from EU regulations in this area. Where required, we try to take into account specific requirements arising from national or regional regulations in this area.
Learnetic as a personal data controller and as an entity processing personal data
Learnetic acts as the personal data controller when you decide to create a user account in our EdTool System, both as a Consumer and an Organization. Therefore, we will process your data needed to create an account and to provide you with appropriate services in our EdTool System. We also administer data for other purposes described in this Privacy Policy.
If you use Functional Plans for Organizations – you will appoint your own Account Administrator and you can add your own Audience – you will be the administrator of Personal Data of users associated with your Organization collected using the EdTool System. Learnetic will act as the personal data processor in this case.
For what purposes do we collect users’ Personal Data? Do we have the right to do this?
When collecting and processing data, we can most often rely on the following legal bases: required for the performance of the contract, user consent, provisions of other law overlapping obligations imposed on us (e.g. education law, financial regulations) or our legitimate interest as entrepreneurs.
The data we collect may be used for the purposes described below.
As required for the performance of the contract:
to conclude and perform the contract (setting up a user account, user data, e-mail address and password);
for settlement and payment (billing address, payment method, transaction history, IP address and geolocation data enabling the determination of tax residence);
to save the generated User Content (text files, audio files, images, electronic tests, interactive lessons, interactions with other users and any derivatives of this data);
to implement various functionalities of the EdTool System (e.g. cooperation of users within their Organizations, conducting tests, collecting results, analyzing and creating reports, etc.).
By way of user consent:
to solve your problem (data you provide when interacting with our support team);
to use your e-mail address to send you a marketing offer of our services and promotion of materials available on the platform (when we ask for such consent for a specific purpose and you agree);
to subscribe to our newsletter (after obtaining your consent);
to get to know you and your needs better by voluntarily providing additional information about you and the Organization you belong to.
Note: You have the right to withdraw your consent to the processing of data collected on this legal basis at any time. However, this will not affect the lawfulness of processing based on consent before its withdrawal.
We will not send you unsolicited marketing materials of ours or any materials from other companies.
As required for fulfillment of legal obligation:
to fulfill legal obligations, e.g. financial, tax, or those requiring the storage of documentation.
By way of legitimate interest of the administrator:
to assess the correct and safe functioning of the EdTool System (login data and information about the device on which it was used, such as: IP address, browser type and version, time zone settings and location, operating system);
for profiling, which involves automatic examination of your activity in the EdTool System in order to adapt our service or offer (details of the interaction of your devices with our services, selection of service types, pages visited, metrics on the use of individual functionalities);
to contact users on topics related to the current operation of the EdTool System (e.g. account support, complaints, handling user reports and inquiries, solving platform operation problems, removing errors, technical support)
to provide, protect and improve our products as best as possible (information about cookies and other identifiers). For more information, please see our Cookies Policy.
to establish, pursue and defend against possible claims
Data collected automatically
Your data may be processed in an automated manner, but this will not have any legal consequences for you or otherwise affect your situation. We do not use advanced profiling of our users.
We constantly try to improve the functionality of the EdTool System. Based on the collected automatic data and feedback received from users, we try to better adapt the functions of our services to your needs. In addition, this data allows us to improve the moderation and technical support of our systems.
Who do we share Personal Data with?
Depending on the Functional Plan you have selected or to which your Organization has joined, the EdTool System will collect data (e.g. your test results) that may be available to the Administrator or Lead Educators of your Organization in connection with the username by which you are identified in the EdTool System.
Moreover, in some situations we have the right to forward your data – if it is necessary for us to provide our services.
These may be:
persons authorized by us – our employees and collaborators;
our service providers to whom we have commissioned services for us (we sign special contracts with them entrusting them processing our data) – e.g. companies providing accounting services, software development companies, law firms;
legal/regulatory entities – we can share data to law enforcement agencies, government/treasury institutions as necessary to comply with the law or legal processes;
other data recipients – e.g. courier companies, payment processing companies;
other third parties with your express consent
We make sure that they process Personal Data in accordance with applicable law and they fulfil standards regarding their safety.
We do not sell, transfer or share Personal Data with any third parties for marketing purposes.
Security of stored data
To secure stored data, we use a combination of physical, technical and organizational security measures. These safeguards include access authorizations only for selected members of our staff, access controls, staff training in data security, confidentiality agreements (for staff and third parties), third party audits, verification tests and reporting of observed incidents. But also encryption of data in transit and at rest, secure network configuration and network security monitoring, including intrusion detection and prevention.
International transfers
We collect user data from all over the world and may transfer, process and store this information outside the EdTool System user’s country of residence, i.e. where we (the European Union) or our independent service providers operating our systems operate. This may therefore include countries where data protection, privacy rights and other regulations may be different than those in your country. Whenever we transfer your information, we take steps, including preventive measures, to protect the Personal Data of our users.
For all international transfers, including to our sub-processors, we ensure that the recipient of Personal Data provides a sufficient level of protection by entering into appropriate reverse agreements with our sub-processors. All international transfers to a third country (i.e. a country outside the European Union or European Economic Area) are carried out on the basis of an appropriate legal basis.
For more information about international transfers and the measures we take to ensure the security of your Personal Information, please contact us at: iod@learnetic.com.
How long do we store your data?
We only retain Personal Data for as long as necessary to fulfill the purposes outlined in our policy, unless a longer period is required by law.
If the basis for storing data is the performance of the contract, the data will be stored until the end of the contract (until the account is deleted), and then until the limitation period for claims under the contract or defense against them expires (no longer than 10 years).
If the basis for processing is consent, Personal Data may be processed until the consent is withdrawn.
If the basis for processing is our legitimate interest, the data is stored until the data subject raises an effective objection or until such legitimate interest has expired. However, there are specific provisions specifying the period for which Personal Data should be stored, and such provisions may extend the processing time of Personal Data (e.g. accounting regulations, educational regulations).
When we no longer need your Personal Data, we securely delete or anonymize it. We regularly review our data sets so as not to store data that we no longer need.
Use of the EdTool System by minors
What rights do you have regarding the processing of your data?
The fact that we process your data does not mean that you no longer have a say in the matter and that you have lost control over it. This is not the case – the provisions of the General Data Protection Regulation (GDPR) guarantee you a number of rights:
the right to access and rectify or update your data – you have the right to request information about what data we process or to update your data;
the right to delete data – if you think that we no longer need the data for the above-mentioned processing purposes or you withdraw your consent to their processing;
the right to limit their processing – if you think that we process too much of your data.
If your data is processed on the basis of your consent, you can always withdraw such consent.
If your data is processed on the basis of legitimate interest of the data controller, and the objection is justified by a special situation – you can object to such processing of your data.
To stop further collection of your Personal Data, you can delete your account in the EdTool System. Deleting your account does not necessarily mean that all of your Personal Data will be automatically deleted from our systems. Certain legal provisions (e.g. regarding finance and accounting) may oblige us to retain your Personal Data for a longer period of time resulting from these provisions.
In any of the above cases, you can contact us and exercise your rights by sending an e-mail to: iod@learnetic.com.
We will respond to your requests within 30 days. The complicated nature of your application may extend this time to 90 days. We may need to verify your identity before your request can be processed.
If you live in the EEA, Switzerland or the United Kingdom, you also have the right to lodge a complaint with the supervisory authority dealing with data protection, i.e. the President of the Personal Data Protection Office (President of the Personal Data Protection Office in Poland) or the local supervisory authority, depending on your place of residence.
Contact us
If the above information is insufficient or if you have questions regarding the protection of Personal Data, you can contact our Data Protection Officer by e-mail at the following e-mail address: iod@learnetic.com.
For general matters, you can contact us by e-mail at: info@learnetic.com, or via the “Contact” tab on our websites: edtool.com, learnetic.com.
Changes to the Privacy Policy
The provisions in our Privacy Policy may change, in particular due to changes in legal regulations, changes in the functionality of our platform or the use of new technological solutions. The current text of the Privacy Policy is available at www.EdTool.com/privacy-policy/.
