The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
“Company” (referred to as either "the Company", "we", "us" or "our") means to Preparity OÜ; Sepapaja 6, Tallinn 15551, Republic of Estonia;
“Consumer”, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA forother than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose;
“Content” means any information, including but not limited to training materials, text, images, figures, charts, means of communications, articles, web-links, entertainment and other services, which the Company provides at the Platform or its associated subdomains;
“Cookies” mean small files that are placed on your computer, mobile device or any other device by a Platform, containing the details of your browsing history on that Platform;
“Data Controller”, for the purposes of the GDPR (General Data Protection Regulation), means the company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. For the purpose of the GDPR, the Company is the Data Controller;
“Device” means any device that can access the Platform such as a computer, a cellphone or a digital tablet;
“Do Not Track” (DNT) means a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites;
“Facebook Fan Page” means a public profile specifically created by the Company on the Facebook social network;
“Personal Data” means any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you;
“Sale”, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal information to another business or a third party for monetary or other valuable consideration;
“Services” mean the online services related to assistance with preparation to consulting industry tests, which are available for the Users at the Platform at each particular period of time. The Services, inter alia, comprise the following services:
“Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals arranged by the Company to facilitate the Platform and the Services, to provide and assist with providing the Services on behalf of the Company, as well as to assist the Company in analyzing how the Platform is used. For the purpose of the GDPR, Service Providers are considered Data Processors;
“Third-party Social Media Service” means any website or any social network website via which the User can log in or create an account to use the Platform;
“Usage Data” means data collected automatically, either generated by the use of the Platform or from the Platform’s infrastructure itself (for example, the duration of a page visit);
“User (or you, etc.)” means an individual who accesses or uses the Platform and the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Platform and the Services, as applicable. Under GDPR (General Data Protection Regulation), you can be referred to as the data subjector as the User as you are the individual using the Platform;
“Visitor” means an individual who visits the Platform without registering or authorizing itself as a User.
3.1. Collected Data
3.1.1. Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience better and easier. While using our Platform, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
3.1.2. When you make a payment with respect to the Services via bank transfer, we may ask you to provide information to facilitate this transaction and to verify your identity. Such information may include, without limitation:
3.1.3. Usage Data is collected automatically when you use the Platform and the Services.
3.1.4. Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), type of your Device, browser type, browser version, the pages of the Platform that you visit, the time and date of your visit, the timespent on those pages, unique device identifiers and other diagnostic data.
3.1.5. When you use the Platform by or via a mobile Device, we may collect certain information automatically, including, but not limited to, the type of mobile Device you use, your mobile Device unique ID, the IP address of your mobile Device, your mobile operating system, the type of mobile internet browser you use, unique Device identifiers and other diagnostic data.
3.1.6. We may also collect information that your browser sends whenever you visit the Platform or when you access the Platform by or via a mobile Device.
Information from Third-Party Social Media Services
3.1.7. The Company allows you to create an account and log in to use the Platform and the Services via the following Third-party Social Media Services:
3.1.8. If you decide to register at the Platform via a Third-Party Social Media Service or otherwise grant us access there to, we may collect Personal Data that is already associated with your Third-Party Social Media Service's account, such as your name, your email address, your activities or your contact list associated with that account.
Tracking Technologies and Cookies
3.1.11. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Platform.
3.1.12. Cookies can be "persistent" or "session" Cookies. Persistent Cookies remain on your personal computer or mobile Device when you go offline, while session Cookies are deleted as soon as you close your web browser. Learn more about cookies: All About Cookies, available at: https://www.termsfeed.com/blog/cookies/.
3.1.13. We use both session and persistent Cookies for the purposes set out below:
Necessary / Essential / Strictly Necessary Cookies
Type: Session Cookies
Administered by: us
Purpose: These Cookies are essential to provide you with the Services available at the Platform and to enable you to use some of its features. They help to authenticate Users and prevent fraudulent use of Users’ accounts. Without these Cookies, the Services that you have asked for cannot be provided, and we only use these Cookies in order to provide you with those Services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: us
Type: Persistent Cookies
Administered by: us
Purpose: These Cookies allow us to remember choices you make when you use the Platform, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Platform.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: third parties
Purpose: These Cookies areused to track information with respect to traffic to the Platform and how Users use the Platform. The information gathered via these Cookies may directly or indirectly identify you as an individual Visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the Device you use to access the Platform. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Platform to see howour Users react to them.
Targeting and Advertising Cookies
Type: Persistent Cookies
Administered by: third parties
Purpose: These Cookies are used to demonstrate advertising that is likely to be of interest to you based on your browsing habits. These Cookies, as served by our Content and/or advertising providers, may combine information they collected from the Platform with other information they have independently collected relating to your web browser's activities across the network of websites. If you choose to remove or disable these targeting or advertising Cookies, you will still see advertising, but they may not be relevant to you.
Social Media Cookies
Type: Persistent Cookies
Administered by: third parties
Purpose: In addition to Our own Cookies, We may also use various third party plug-ins from social media networking websites such as Facebook, Instagram, Twitter or Google+ to report usage statistics of the Website and to provide social media features. These third party plug-ins may store Cookies. We do not control these Social Media Cookies. Please refer to the relevant social media networking’s website privacy policies for information about their cookies.
Your Choices Regarding Cookies
3.1.15. If You do not accept our Cookies, you may experience some inconvenience in your use of the Platform and some features may not function properly.
3.1.17. You can learn more about cookies: https://www.termsfeed.com/blog/cookies/
3.1.18. If you have any questions about this Cookies Policy, You can contact us by email: email@example.com/
Recording Training Sessions
3.1.19. Your training sessions may be recorded, but these recordings will be only stored and viewed by the Company’s team to provide you such services and features that most likely meet your needs and customize our Services to make your experience better and easier. We will inform you at the start of the relevant session if such a session is being recorded and ask for your consent.If you do not consent to be recorded, you can choose to leave the session.
3.2. Use of Your Personal Data
3.2.1. The Company may use Personal Data for the following purposes:
3.2.2. We may share your personal information in the following situations:
3.3. Retention of Your Personal Data
3.3.2. The Company will also retain Usage Data for internal analysis purposes. Usage Datais generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Platform, or we are legally obligated to retain this data for longer time periods.
3.4. Transfer of Your Personal Data
3.4.1. Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. By using the Platform you expressly provide consent for such transfer of the information, even if any such place of collection or storage of your information has more rigorous data protection standards.
3.5. Disclosure of Your Personal Data
3.5.2. Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law orin response to valid requests by public authorities (e.g. a court or a government agency).
Other Legal Requirements
3.5.3. The Company reserves the rights todisclose your Personal Data in reasonable belief that such action is necessary to:
3.6. Security of Your Personal Data
3.6.1. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receiveit. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
3.7. Detailed Information on the Processing of Your Personal Data
3.7.1. Service Providers have access to your Personal Data only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose.
3.7.2. We may use Third-Party Service Providers to monitor and analyze the use of our Platform.
Google Analytics is a web analytics service offered by Google that tracks and reports Platform traffic. Google uses the data collected to track and monitor the use of our Platform. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Firebase is an analytics service provided by Google Inc.
We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245
For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Flurry Analytics service is provided by Yahoo! Inc.
You can opt-out from Flurry Analytics service to prevent Flurry Analytics from using and sharing your information by visiting the Flurry's Opt-out page: https://developer.yahoo.com/flurry/end-user-opt-out/
Mixpanel is provided by Mixpanel Inc.
You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/
Unity Analytics is provided by Unity Technologies.
Google Tag Manager
3.7.3. We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may use third party email marketing Service Providers to manage and send emails to you.
Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
AWeber is an email marketing sending service provided by AWeber Communications.
GetResponse is an email marketing sending service provided by GetResponse.
4.1. The Company may provide the Services at the Platform on the paid basis. In that case, we may use third-party services for payment processing (e.g. payment processors).
4.2. We will not collect or disclose your payment card details. We provide such information directly to our third-party payment processors, which collect and use your Personal Data in accordance with their relevant Privacy Policies. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
4.3. When you pay for the Services at the Platform via bank transfer, we may ask you to provide information to facilitate this transaction and to verify your identity.
5. Usage, Performance and Miscellaneous
5.1. We may use third-party Service Providersto improve functioning of the Platform and the use of the Services.
Mouseflow is a session replay and heatmap tool that shows how visitors click, move, scroll, browse, and pay attention at the Platform. This service is operated by ApS.
Mouseflow service may collect information from your Device.
FreshDesk is a customer support software. The service is operated by Freshworks, Inc.
FreshDesk service may collect information from your Device.
6. GDPR Privacy Regime
6.1. Legal Basis for Processing Personal Data under GDPR
6.1.1. We may process Personal Data under the following conditions:
6.1.2. If you have any questions or suggestions regarding exercise of your rights in connection with processing your Personal Data under the GDPR, please feel freecontact us at: firstname.lastname@example.org.
6.2. Your Rights under the GDPR
6.2.1. The Company undertakes to respect the confidentiality of your Personal Data and to take all reasonable efforts to procure the exercise of your rights on use and protection of your Personal Data.
6.2.3. You may exercise your rights of access, correction, withdrawal, and objection by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will take all reasonable efforts to provide a response as soon as possible.
6.2.4. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. If you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
6.3. Facebook Fan Page
Data Controller for the Facebook Fan Page
6.3.1. The Company is the Data Controller of your Personal Data collected while using the Platform. As operator of the Facebook Fan Page, the Company and the operator of the social network Facebook shall be deemed as Joint Controllers.
6.3.2. The Company entered into contract with Facebook that defines, inter alia, the terms for use of the Facebook Fan Page. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php
6.4. Facebook Insights
6.4.1. We use the Facebook insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about the Users.
6.4.2. For this purpose, Facebook places a Cookie on the Device of the User visiting our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end ofthis period.
6.4.3. Facebook receives, records and processes the information stored in the Cookie, especially when the User visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.
7. CCPA Privacy
7.1. Your Rights under the CCPA
The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to access / the right to request. The CCPA permits you to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell your Personal Data to third parties. You can submit such a request by visiting our "Do Not Sell My Personal Information" section or web page.
The right to know about your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
The right to delete Personal Data. You also have the right to request the deletion of your Personal Data that have been collected in the past 12 months.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your Consumer's rights, including by:
7.2. Exercising Your CCPA Data Protection Rights
7.2.1. In order to exercise any of your rights under the CCPA, and if you are a California resident, You can email or contact us within our customer support service.
7.2.2. The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.
7.3. Do Not Sell My Personal Information
7.3.1. We do not sell personal information. However, the Service Providers, with which we have partnership relationships (for example, our advertising partners) may use technology at the Platform that sells personal information as defined by the CCPA law.
7.3.2. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales, as defined under CCPA law, you may do so by following the instructions below.
7.3.3. Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
7.4.1. You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Platform:
7.4.2. The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
8. "Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
8.1. Our Platform does not respond to Do Not Track signals.
8.2. However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
9. Your California Privacy Rights (California's Shine the Light law)
9.1. Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
9.2. If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
10. California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
10.1. California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
10.2. To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.
10.3. Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
10.4. The Company does not intentionally, or knowingly, process personal information from individuals under the age of 18. When necessary, Users under the age of 18 will be told not to submit any personal details. We will make every effort to delete any details of such Users where a parent or guardian has informed us that these details have been collected. If you are under the age of 18 and a registered user of our Platform, you may request that we remove content and information that you post on our Platform. To obtain removal of such content or information, please send an email with a detailed description of the specific content or information you would like removed to email@example.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted, since the content and information may remain in our databases, may remain visible in a manner that does notidentify you, or may have been re-posted by another user. There may be other circumstances in which applicable laws do not require or allow removal even if requested.
11. Links to Other Platforms
11.2. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
13. Contact Us