- Privacy Notice
Last updated: 13.11.2021
We respect your privacy and are committed to protecting your Personal Data when you use our website (https://explaim.com/) including any mobile or a device-specific version of the website or any other products or Services we provide, including our official representations on social media (together the “Website”).
We will tell you:
- Our contact details
- Our roles in the processing of Personal Data
- How we collect your Personal Data
- How we use your Personal Data
- When we share your Personal Data with others
- Processing children’s personal data
- How we transfer Personal Data outside the United Kingdom and European Economic Area
- Your data protection rights
- How to complain
- How we secure your Personal Data
- How we store your Personal Data
- Cookies and other tracking technologies
- Modifications to this Privacy Notice
You can find the vocabulary of the definitions and legal references at the end of this Privacy Notice.
OUR CONTACT DETAILS
Name: Loonomy OÜ. Any references in this document to “we”, “us” or “our” are references to Loonomy OÜ only.
Registration number: 16246772
Address: Harju maakond, Tallinn, Kristiine linnaosa, A. H. Tammsaare tee 47 11316
OUR ROLES IN THE PROCESSING OF PERSONAL DATA
While providing Services to our customers and processing Personal Data, we act as either the Controller or the Processor, depending on the case.
In cases we determine the purposes and means of the processing, i.e., why and how the processing is carried out, and when we do not act not on behalf of someone else, we are a Data Controller.
Any references to “you” and “your” include all individuals whose Personal Data we collect, hold and process as a Data Controller while providing Services.
We are committed to processing your Personal Data as described in this Privacy Notice.
In case of provision of Services to legal entities, we can have access to the Personal Data of their representatives, employees, officers, agents, shareholders. Respective legal entities remain Data Controllers of this Personal Data. We only process Personal Data as strictly necessary for the provision of Services and according to their instructions.
This Privacy Notice does not apply to the extent we process Personal Data in the role of a Data Processor.
HOW WE COLLECT YOUR PERSONAL DATA
- Personal Data you give to us:
- Identity data: Information that you provide by placing order on the Website (full name, home address). We will allocate you a unique user ID.
- Contact data: When you place an order, fill a contact form on the Website or otherwise contact us, you provide us with an email address, telephone number and content of communication. Please note that we may retain a history of communication with you.
- Regulatory data: Records of registration of your organization with any applicable regulatory authority, regulated status and any regulatory references (legal entity, registration number, authorized representative, etc.).
- Payment data: While providing Services, we collect your payment details, receipts or other documents confirming payments and any other payment data depending on the jurisdiction and payment methods used.
- Communication data: If you communicate with us, it means that we collect some data regarding calls, texts, or other communications, including date and time of communications, the content of communications, and your responses to our communication.
- Information collected automatically:
- Login data: We may collect data about your device, including IP address, OS, location, browser you use.
- Usage data: We may collect information about how your use of the Website, pages visited, courses learned, grades received, time spent, features used, etc.
- Social media data: Social media platforms include Facebook and LinkedIn. We receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “likes”, comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and individual users’ public profiles.
- Marketing data: We collect information about how you interact with our marketing activities (for example, information about when you click on our advertisements or open our email communications).
- What happens if you don’t give us your data
You are under no obligation to provide us with your Personal Data. However, some Personal Data is necessary so that we can supply you with the Services you have purchased or requested, and authenticate you so that we know it is you and not someone else. For example, if you do not provide us with your email address, we will not be able to create an account for you.
HOW WE USE YOUR PERSONAL DATA
We use your Personal Data for the following purposes:
|Purpose||Type of Data||Lawful basis|
|To provide you with our Services, which includes creating and managing your account, providing access to Services, processing and managing payments||
|Performing a contract with you
Legitimate interests (for example, to ensure account functionality)
|To manage our relationship with you as a user of the Website which includes notifying you about changes on the Website, modification to the Terms and Conditions or this Privacy Notice||
|Performing a contract with you
Legitimate interests (for instance, to keep our records updated)
|To provide supporting customer services to you, which includes answering any issue that has arisen, responding to your comments, improving our support processes||
|Legitimate interests (e.g., to deal with your requests)|
|To maintain safety, security, and integrity of the Website, which includes ensuring confidentiality, integrity, and availability of the Website, as well as preventing unauthorized access to our information systems||
|Legitimate interests (for example, to ensure network security)
|To use data analytics to improve our Website, marketing, customer relationships and experiences||
|Legitimate interests (for instance, to develop our business)
|To send you marketing communications||
|To deliver relevant content and advertisements to you and measure/understand the effectiveness of the advertising we serve to you||
|Legitimate interests (e.g., to notify you of news and updates related to our Services)
WHEN WE SHARE YOUR PERSONAL DATA WITH OTHERS
- Service providers and business partners:
We provide your Personal Data to our service providers to process it for us, based on our instructions, this Privacy Notice and conditions of data processing agreements.
We do not share in other way or sell your personal information.
|Category of recipient||Purpose of processing|
|Web hosting provider||To store and transfer our content and data|
|Payment service providers||To process payments|
|Marketing partners||To deliver service and marketing messages|
|Data analytics||To measure and understand our audience, tailor our marketing activities|
|Consultants, lawyers, accountants and other professional service providers||To receive professional advice|
- Other disclosures
In addition to the disclosures for the purposes identified above, we may disclose your Personal Data to third parties:
- To comply with legal obligations and respond to requests from government agencies;
- To address disputes, claims, or to establish, exercise and protect our rights.
Processing children’s personal data
We do not aim any of our services directly at children under the age of eighteen (18). Subsequently we do not knowingly collect personal data about children under eighteen (18) years old. If you know that we process personal data of user under eighteen (18) years old, please inform us by sending email at firstname.lastname@example.org or via telephone number + 44 20 4577 2151.
HOW WE TRANSFER PERSONAL DATA OUTSIDE
THE UNITED KINGDOM AND EUROPEAN ECONOMIC AREA
Information we collect about you could be processed in countries outside the United Kingdom and/or European Economic Area. We rely on the following methods for transfers of Personal Data outside the United Kingdom and/or European Economic Area:
- Adequacy: We may transfer Personal Data to a third country when such a third country has received a finding of “adequacy” from the relevant regulator(s) (see the full list of these countries here);
- Appropriate safeguards: We are providing appropriate safeguards by entering binding, standard data protection clauses adopted by the relevant regulator(s) and enforceable by data subjects in the United Kingdom and/or European Economic Area (see a copy of these clauses here);
- Derogations: Depending on the circumstance, we also collect and transfer Personal Data based on certain derogations such as explicit consent of the data subject, performance of a contract involving the data subject, important public interest reasons, establishment, exercise or defense of legal claims.
YOUR DATA PROTECTION RIGHTS
You have certain data protection rights. You can learn more about these rights below:
- Right of access: You have the right to ask us for copies of your Personal Data;
- Right to rectification: You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete Personal Data you think is incomplete;
- Right to erasure (right to “be forgotten”): You have the right to have all of your Personal Data erased when you stop using the Services and close your account;
- Right to restriction of processing: You have the right to ask us to restrict the processing of your Personal Data in certain circumstances;
- Right to object to processing: You have the right to object to the processing of your Personal Data in certain circumstances;
- Right to data portability: You have the right to ask that we transfer the Personal Data you gave us to another organization, or to you, in certain circumstances.
We do not sell your data therefore opt out request option and disclosing of the categories of personal information that we sell or disclose for business purposes or categories of third parties to whom we have sold your information or disclosed it for business purpose are not applicable in the case at hand. If we decide to do so, we will notify you and give you the possibility to opt out from selling your personal data.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. To ensure that you who are making any of the aforementioned requests is the consumer we may ask you to verify your request.
You can exercise your rights by contacting us at email@example.com.
HOW TO COMPLAIN
In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you are unhappy with how we process your Personal Data.
If you have questions, concerns, or complaints, please try to contact us at firstname.lastname@example.org.
HOW WE SECURE YOUR PERSONAL DATA
To help protect the privacy of Personal Data, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your Personal Data to those employees and vendors who need to know that information to provide Services to you. Also, we train our employees and contractors about the importance of confidentiality and maintaining the privacy and security of your Personal Data.
HOW WE STORE YOUR PERSONAL DATA
We will not keep your Personal Data for longer than required. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the Personal Data, the purposes for which we process your Personal Data, and what the law requires us to do.
For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription.
When we no longer need to keep your Personal Data, we anonymize or delete it. In certain cases, we need to securely retain certain Personal Data to fulfil our legal and regulatory obligations.
Cookies and other tracking technologies
You can see our Cookie Notice here.
MODIFICATIONS TO THIS PRIVACY NOTICE
We keep our Privacy Notice under regular review to make sure it is up to date and accurate. We recommend that you revisit and read this Privacy Notice regularly to ensure that you are up-to-date with the current terms. Check the “Last updated” date at the top of this page to see when this Privacy Notice was last updated.
DEFINITIONS AND LEGAL REFERENCES
|A 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.|
|Data Processor||A natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller and according to its instructions|
|European Economic Area (EEA)||Member states of the European Union and three additional countries, namely Iceland, Liechtenstein, and Norway|
|Personal Data||Any information that directly, indirectly, or in connection with other information allows for the identification of a natural person|
Services provided by us as described in the relative Terms and Conditions on the Website.