Introduction

·     eLearningX.org is the data controller of the personal information we collect about you (i.e., the entity that determines the means and purposes of collecting, using, and disclosing the personal information).

·     We collect the personal information set out in the "What Information We Collect" section of this Privacy Notice below, including account registration details such as name and email, details of Content Offerings you undertake, survey information (where you provide it), identity verification data, and information about your use of our site and Services.

·     We use your personal information for the purposes set out in the "How We Use the Information" section of this Privacy Notice below, including providing our site and Services to you, ensuring the security and performance of our site, conducting research relating to Content Offerings, sharing information with our Content Providers and our suppliers, direct marketing, and performing statistical analysis of the use of our site and Services.

·     You have a number of rights that you can exercise in relation to our use of your personal information, as set out in the "Updating or Deleting Your Personally Identifiable Information" section of this Privacy Notice below.

 

Purpose and who we are

The purpose of this Privacy Notice is to describe how eLearningX.org., our subsidiaries, and our international branches, ("eLearningX," "us," "we," or "our") collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to eLearningX.org (collectively referred to herein as the "Site"). Please read this Privacy Notice carefully to understand what we do. If you do not understand any aspects of our Privacy Notice, please feel free to contact us at info@eLearningX.org. Your use of our Site is also governed by our Terms.

Terms used but not defined in this Privacy Notice can be found in our Terms of Use. eLearningX is the data controller of all Personal Data (as defined below) collected via the Site and of certain Personal Data collected from third parties, as set out in this Privacy Notice.

What Information this Privacy Notice Covers

This Privacy Notice covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any Personal Data, but for features or Services related to the Content Offerings, Personal Data is required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect, "Personal Data" (i.e., information that can be used to identify you and which may also be referred to as “personally identifiable information” or “personal information”). Personal Data can include information such as your name, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personal Data you submit to eLearningX. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary ways in which we communicate with you.

What You Agree to by Using Our Site

We consider that the legal bases for using your personal information as set out in this Privacy Notice are as follows:

·     our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the Terms of Use of our Site which you accept by browsing our website and/or to comply with our contract to provide Services to you, your academic institution, your employer, or other organization that may be providing you with access to our Services); or

·     our use of your personal information is necessary for complying with our legal obligations; or

·     use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:

· run, grow and develop our business;

· operate our Site and provide our Services;

· select appropriately skilled and qualified suppliers;

· build relationships with partners and academic institutions;

· carry out research and statistical analysis;

· carry out marketing and business development; and

· for internal administrative and auditing purposes.

·     consent, to send you certain communications or where you submit certain information to us, or where required to rely upon consent by local law.

Which legal basis applies to a specific activity will depend on the type of personal information used and the context in which it is being used.

If we rely on our (or another party’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent and we will stop doing so. If you withdraw your consent, this may impact the ability for us to provide some of our Services to you.

What Information We Collect

We gather two types of information about users through the Site:

·     Information relating to your use of our Site. When users come to our Site, we may track, collect, and aggregate information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system, and browser software used by each user of the Site. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of their point of connectivity. Location data may be used to route your traffic to the nearest regional server to reduce latency and improve your experience. We may also use cookies and web beacons when you visit our Site.

·     Personal Data provided directly by you or via third parties. We collect Personal Data that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our Site. We may use the Personal Data that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other eLearningX events, and send you email messages about Site maintenance or updates.

·     Account Registration. If you register for an account on our Site, you may be required to provide us with Personal Data such as your name and email address.

·     Updates. eLearningX may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these Services, you may be required to provide us with Personal Data such as your name and email address.

·     Forums. eLearningX may offer public forums from time to time (the "Forums") where you can share comments and thoughts. In order to participate in the Forums, you may be required to register with us and/or provide us with Personal Data such as your name and email address. Please keep in mind that information you post or make available in Forums will be publicly available. You should not include any personal information or other information of a personal or sensitive nature, whether relating to you or another person, in a Forum post. Please also reference our Terms of Use for additional information about proper use of our Forums.

·     Participation in Content Offerings. eLearningX offers users the opportunity to participate in Content Offerings on or through the Site. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.

If you participate in a Content Offering, we may collect certain user-generated content, such as assignments you submit, peer-graded assignments, and peer grading feedback. We also collect course data, such as responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate in or submit such assignments, exams, or surveys.

·     Identity Verification. eLearningX may offer you the ability to verify your identity for select Services. In order to enroll for these Services, you may be required to provide us or our third-party identity verification vendor with Personal Data such as your name, address, date of birth, a headshot taken using a webcam, and a photo identification document. Additionally, if you apply for financial aid in connection with these Services, you may be required to provide information regarding your income.

·     Communications with eLearningX. We may receive Personal Data when you send us an email message or otherwise contact us.

·     Third Party Sites. We may receive Personal Data when you access or log-in to a third-party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personal Data available from the third-party site.

·     Surveys. We may receive Personal Data when you provide information in response to a survey operated by us or a Content Provider.

·     Partner sites. Partner sites providing Content Offering-related tools and services to eLearningX users may collect nonfinancial individual-level user data regarding the individual’s use of that partner site while the partner sites provide those services to eLearningX. The partner sites may share that data with ELearningX for the purpose of improving our Services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.

·     Third Party Payment Processing. eLearningX provides you with the ability to pay for Content Offerings and other Services using a credit card or other methods through a third party payment processing service provider. Please note that our service provider – not eLearningX – collects and processes your financial information.

How We Use the Information

·     Information relating to your use of our Site. We use information relating to your use of the Site to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our Services and the Site.

·     Personally-Identifiable Information provided directly by you or via third parties. Except as set forth in this Privacy Notice or as specifically agreed to by you, eLearningX will not disclose any of your Personal Data. In addition to the other uses set forth in this Privacy Notice, we may disclose and otherwise use Personal Data as described below.

·     Providing the Site and our Services.

We use Personal Data which you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or Services that you request from us.

·     Technical support and security.

We may use Personal Data to provide technical support to you, where required, and to ensure the security of our Services and the Site.

·     Updates.

We use Personal Data collected when you sign-up for our various email or update services to send you the messages in connection with the Site or Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.

·     Forums.

You should not post any personally identifiable information or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post personally identifiable information, such personally identifiable information may be collected during your use of the Forums. We may publish this information via extensions of our platform that use third-party services, like mobile applications. We reserve the right to reuse Forum posts that contain personally identifiable information in future versions of the Content Offerings, and to enhance future Content Offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the Content Provider, business partners, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using personally identifiable information.

·     Participation in Content Offerings.

We use the Personal Data that we collect from you when you participate in a Content Offering through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of the Content Offerings. We may also share your Personal Data and your performance in a given Content Offering with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.

·     Identity Verification.

For Services that require identity verification, we may use the Personal Data that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. This service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after successful verification of your profile information.

·     Communications with or from eLearningX.

When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Notice. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.

·     Communications with eLearningX Business Partners.

We may share your Personal Data with Content Providers and other business partners of eLearningX so that Content Providers and other business partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.

·     Research.

We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our Content Providers and other business partners so that our Content Providers and other business partners may use the data for research related to online education.

·     Disclosure to eLearningX Operations and Maintenance Contractors.

We use various service providers, vendors, and contractors (collectively, "Contractors") to assist us in providing our Services to you. Our Contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Content Offerings. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.

·     Government Authorities; Legal Rights and Actions.

eLearningX may share your Personal Data with various government authorities in response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personal Data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of ELearningX, the Site, our users, customers, or others; and in connection with our Terms of Use and other agreements.

·     Disclosure to Acquirers.

eLearningX may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of ELearningX to which your Personal Data relates.

·     e-Readers. If we receive any Personal Data related to the extent to which you use designated e-Readers or other devices to access ELearningX materials, we may archive it, and use it for research, business, or other purposes.

External Links

For your convenience we may provide links to sites operated by organizations other than eLearningX ("Third Party Sites") that we believe may be of interest to you. We do not disclose your Personal Data to these Third Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third Party Sites. If you choose to click on a link to one of these Third Party Sites, you should review the privacy policy posted on the other site to understand how that Third Party Site collects and uses your Personal Data.

Retention of Personally Identifiable Information

We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data is collected and processed. The length of time we retain Personal Data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.

Confidentiality & Security of Personally Identifiable Information

We will use industry standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Notice, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personal Data, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mail communications are typically not encrypted and should not be considered secure.

Updating or Deleting Your Personal Data

You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by logging into the Site, selecting ‘Settings’ from the dropdown in the top right, and scrolling down to find the appropriate option. The ability to delete an account may be disabled for some users, particularly those who are enrolled in for-credit offerings such as degrees, MasterTrack certificate programs, and other similar offerings.

If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via info@eLearningX.org. If you reside or are located in the EEA, United Kingdom, Switzerland, or other region that offers similar protections, you have the right to request that we:

·     provide access to any Personal Data we hold about you;

·     prevent the processing of your Personal Data for direct-marketing purposes;

·     update any Personal Data which is out of date or incorrect;

·     delete any Personal Data which we are holding about you;

·     restrict the way that we process your Personal Data;

·     provide your Personal Data to a third party provider of services; or

·     provide you with a copy of any Personal Data which we hold about you.

We try to answer every request promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that when deleting your Personal Data there may be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if we need to retain your Personal Data to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.

Questions, Suggestions, and Complaints

If you have any privacy-related questions, suggestions, unresolved problems, or complaints, you may contact us via info@eLearningX.org. If you reside or are located in the EEA, United Kingdom, Switzerland, or other region that offers similar protections, our Data Protection Officer and Privacy Team may assist with all queries regarding our handling of Personal Data at info@eLearningX.org. If you reside or are located in the EEA, United Kingdom, Switzerland, or other region that offers similar protections, you may also make a complaint to our supervisory body for data protection matters (namely the UK Information Commissioner's Office or Dutch Autoriteit Persoonsgegevens) or seek a remedy through local courts if you believe that your rights have been breached.

 

International Privacy Practices

In order to provide our products and Services to you, you may be sending your Personal Data outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your Personal Data may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personal Data. We are committed to protecting the privacy and confidentiality of Personal Data when it is transferred. If you reside or are located within the EEA, United Kingdom, Switzerland, or other region that offers similar protections, and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA or other regions to the extent feasible under applicable law.

Changing Our Privacy Notice

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. We will notify you of any material change to this Privacy Notice by posting a notice on our Site’s homepage for a reasonable period of time following such update or by sending an email to the email address associated with your user account, and by changing the effective date (located at the top and bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Notice.

No Information from Children Under 13

eLearningX strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 13 is prohibited, and certain regions and Content Offerings may have additional requirements and/or restrictions. In line with this belief, we do not knowingly collect or maintain Personal Data on our Site from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personal Data of persons less than 13 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such Personal Data.

 

 Information provided by you on the understanding that it will be shared with a third party

Our website allows you to post information with a view to that information being read, copied, downloaded or used by other people. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

 Here are the individual cases where you may post information with a view to that information being read, copied, downloaded or used by other people:

       When you make a post on our website

You may post on our website by posting a resource item, posting in the forum, posting a review of another ELearningX user, posting a comment. Your posts and comments on our website are associated with your ELearningX account and will show the avatar and account name of the poster, which is a hyperlink. Clicking on the hyperlink will open your ELearningX profile. As such, all your posts are identified and associated with your ELearningX account. Aside from this, your forum posts do not include any personally-identifiable information unless you decide to include such information in your post. We believe that in creating a forum post, you would reasonably expect us to process the data in order for other people to use it. As a result, we process it on the basis that there is a legitimate interest to us in doing so, namely the proper administration of our website. We do not specifically use the information you provide except to allow it to be displayed or shared.

 

       When you post a job, course, language school or any other advert

Your adverts are associated with your ELearningX account and will show the account name of the poster, which is a hyperlink. Clicking on the hyperlink will open your ELearningX profile. As such, all your adverts are identified and associated with your ELearningX account. Banners are not associated with your ELearningX account. Aside from this, your adverts do not include any personally-identifiable information unless you decide to include such information in your advert. We believe that in creating an advert, you would reasonably expect us to process the data in order for other people to use it. As a result, we process it on the basis that there is a legitimate interest to us in doing so, namely the proper administration of our website. We do not specifically use the information you provide except to allow it to be displayed or shared.

 

·       When you apply to a job of advertise your product

When you apply to a job or advertise a product through our website, all of the personal user information that you provide in your account can be viewed by the job poster, including any attachments that you have uploaded and attached to the application. The information associated with a job application will be collected and stored in our database indefinitely, unless we deem it necessary to delete, you manually delete this information within your account or you delete your account with us.

 We store the information you provide until such time as it is no longer relevant to be displayed on the website or until you withdraw your consent. You can withdraw this consent at any time by emailing us at info@eLearningX.org.

 

When you make a payment for a product or service

Payment information is never taken by us either through our website or otherwise.

At the point of payment, you are transferred to a secure page on the website of either PayPal or Stripe, our payment service providers, or to a secure page on our website which operates the Stripe payment gateway through a pop-up window. You can find information about Paypal’s privacy policies and practices here, and about Stripe’s privacy policies and practices here.

Information we process because we have a legal obligation

We may process any of your data identified in this policy in order to comply with a legal obligation, or in order to protect your vital interests or the vital interests of another natural person. This may include your personal information.

Other information we may process

We may process any of your data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

Accessing, updating and removing your personal information

You can at any time request a copy of your personal data processed by us, or request to have it updated if it is incorrect. You can do both these things by sending an email to info@eLearningX.org After receiving your request, we will tell you when we expect to provide you with the information requested or correct the incorrect information.

If you wish to remove your personal information from our website, you can make a request by sending an email to info@eLearningX.org

Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

If you have any questions about how we handle your information, please contact us at info@eLearningX.org.