Privacy Policy

Privacy policy

Good morning!

If you have arrived here, it is a reliable sign that you value your privacy. We understand this very well, which is why we are providing you with a document in which you will find, in one place, the rules for the processing of personal data and the use of cookies and other tracking technologies in connection with the functioning of the https://kedu.ac website.

Formal information to start – the administrator of the website is Kairos Edu sp. z o.o. ul.Warszawska 18a, 21-300 Radzyń Podlaski, VAT NUMBER: 5381861456

This privacy policy has been structured in the form of questions and answers. The choice of this form was dictated by the concern for clarity and legibility of the information presented to you. Below you will find a table of contents of this policy corresponding to the questions we answer in turn.

# 1: Who is the controller of your personal data?

# 2: Who can you contact about the processing of your personal data?

# 3: What information do we hold about you?

# 4: Where do we have your personal data from?

# 5: Is your data secure?

# 6: For what purposes do we process your personal data?

User account – details

Orders – details

Complaints and withdrawals – details

Newsletter – details

Product comments and reviews – details

Mail handling – details

Tax and accounting obligations – details

Archive – details

Self-marketing – details

Analysis, statistics, optimisation – details

# 7: How long will we keep your personal data?

# 8: Who are the recipients of your personal data?

# 9: Do we transfer your data to third countries or international organisations?

# 10: Do we use profiling? Do we make automated decisions based on your personal data?

# 11: What rights do you have in relation to the processing of your personal data?

# 12: Do we use cookies and what are they?

# 13: On what basis do we use cookies?

# 14: Can you disable cookies?

# 15: For what purposes do we use our own cookies?

# 16: What third party cookies are used?

Google Analytics – details

Google Tag Manager – details

Google AdWords – details

Google AdSense – details

You Tube – details

Vimeo – details

# 17: Do we track your behaviour on our website?

# 18: Do we target you with targeted advertising?

# 19: How can you manage your privacy?

# 20: What are server logs?

# 21: Is there anything else you should know?

If you have any concerns about the privacy policy, you can contact us at any time by sending an email to support@kedu.ac.

#1: Who is the administrator of your personal data?

The administrator of your personal data is Kairos Edu sp. z o. o. ul.Warszawska 18a, 21-300 Radzyń Podlaski, VAT NUMBER: 5381861456.

# 2: Who can you contact regarding the processing of your personal data?

As part of the implementation of data protection in our organisation, we have decided not to appoint a Data Protection Officer due to the fact that it is not mandatory in our situation. You can contact us on matters relating to data protection and privacy more broadly at the following email address support@kedu.ac

# 3: What information do we hold about you?

Depending on the purpose, we may process the following information about you:

  • name,
  • residential address
  • business address,
  • tax identification number
  • e-mail address
  • telephone number,
  • data contained in correspondence addressed to us,
  • bank account number,
  • IP address,
  • your image (profile picture),
  • products you have viewed
  • details of orders placed,
  • details of abandoned baskets,
  • your activity with regard to newsletter messages,
  • information about the operating system and the web browser you are using,
  • the pages you view,
  • time spent on the site,
  • transitions between pages
  • clicks on individual links,
  • the source you came to our site from,
  • the age range you are in,
  • your gender,
  • Your approximate location limited to your locality,
  • Your interests as determined by your online activities.

We have described the scope of the processing precisely for each processing purpose. Information in this regard can be found later in this policy.

# 4: Where do we get your personal data from? In most cases, you provide it to us yourself. This happens when:

  • you register a user account,
  • place an order,
  • send a complaint or cancel a contract,
  • subscribe to a newsletter,
  • add a comment or review a product,
  • contact us.

In addition, some information about you may be automatically collected by the tools we use:

  • the website mechanism and the newsletter system collect your IP address,
  • the web page mechanism collects information on products you have viewed, details of orders placed, including unfinished orders,
  • the mechanism of the newsletter system collects information on your activity in relation to the content sent to you within the newsletter, such as opening messages, clicking on links, etc,
  • Google Analytics collects a range of information about how you use our website.

# 5: Is your data secure?

We take care of the security of your personal data. We have analysed the risks involved in the various processes of processing your data and then implemented appropriate security and data protection measures. We continuously monitor the state of our technical infrastructure, train our staff, look at the procedures in place and make the necessary improvements. If you have any questions about your personal data, we are at your disposal at support@kedu.ac.

# 6: For what purposes do we process your personal data?

There are more than one of these purposes. Below is a list of them, followed by a more detailed discussion. We have also assigned the respective legal grounds for processing to the various purposes.

  • registration and maintenance of user account – article 6(1)(b) RODO,
  • Order processing – article 6(1)(b) RODO,
  • handling of complaints or withdrawals – article 6(1)(f) RODO,
  • sending a newsletter – article 6(1)(a) RODO,
  • handling of comments or feedback on a product – article 6(1)(a) RODO,
  • handling of correspondence – article 6(1)(f) RODO,
  • fulfilment of tax and accounting obligations – article 6(1)(c) RODO,
  • creation of an archive for the possible need to defend, establish or assert claims, as well as for the identification of a returning customer – article 6(1)(f) RODO,
  • own marketing – article 6(1)(f) RODO,
  • analysis, statistics and optimisation – article 6(1)(f) RODO.

User account – details

When creating a user account, you will need to provide the data necessary to set up the account: e-mail address and password. The provision of the data is voluntary, but necessary to set up the account.

As part of editing your account details, you can enter your further data, in particular data that may be used to place orders, such as your name, residential or business address, VAT number, telephone number. Within the framework of editing your account data, you can also set up your avatar, e.g. a profile picture including an image.

If you create an account through integration with a social media account, we will access certain data stored within the social media account (name, email address, profile picture) on the basis of your prior authorisation.

In addition, our system used for user accounts records your IP number, which you used when registering your user account.

Furthermore, we use the integration of the Google Analytics tool with the user account mechanism. In this way, the data collected by the Google Analytics tracking code about your use of our website is assigned to your user account. This includes information such as:

  • information about the operating system and the web browser you are using,
  • your browsing activity
  • time spent on the site,
  • transitions between different sub-pages,
  • clicks on individual links,
  • the source you came to our site from,
  • the age range you are in,
  • your gender,
  • Your approximate location limited to your locality,
  • Your interests as determined by your online activities.

We analyse such information about you in order to optimise our websites for user experience, efficiency and conversion, which is our legitimate interest as referred to in Article 6(1)(f) of the DPA.

You can modify the information about you provided to us in connection with the registration of your user account at any time. However, in a situation where you have created an account using an integration with an account on a social network, the data retrieved from this social network cannot be modified.

The data provided by you in connection with the creation of your account is processed in order to provide you with an electronic service consisting of providing you with the possibility to use your user account. This service is provided on the basis of a contract concluded in accordance with the terms and conditions described in the Terms and Conditions, which means that in this respect the legal basis for the processing of your personal data is Article 6(1)(b) RODO.

The data will be stored for the duration of the user account. You can decide to delete your account at any time, however this will not lead to the deletion of information about your orders placed using your account from our database. Order data is stored in our archive until the expiry of the statute of limitations for contractual claims / for the lifetime of the website due to ensuring that we can identify the returning customer, reconstruct their purchase history, discounts granted, etc., which is our legitimate interest as referred to in Article 6(1)(f) RODO.

Orders – details

When placing an order, you will need to provide the data necessary to process the order. Depending on the details of your order, the catalogue of data may be different. For example, if you are ordering physical products, we need to know the address where we will deliver the order to you. If you are requesting a VAT invoice for a company, we need to know the VAT number and business address. The provision of data is voluntary, but necessary to place an order.

In addition, our system used to process your order saves the IP number you used to place the order.

Each order is saved in our database, which means that your personal data assigned to the order is also accompanied by order-related information such as the products you ordered, the payment method you selected, the delivery method you selected, and the payment deadline.

The data collected in connection with your order, is processed for the purpose of fulfilling the contract concluded by placing the order (Art. 6(1)(b) RODO), issuing an invoice (Art. 6(1)(c) RODO in connection with the regulations governing the issuance of invoices), including the invoice in the accounting documentation and fulfilling other tax and accounting obligations (Art. 6(1)(c) RODO in conjunction with the provisions governing tax and accounting obligations) and for archiving purposes for the possible need to defend, establish or assert claims, as well as to identify a returning customer, which is our legitimate interest (Art. 6(1)(f) RODO).

Order data will be processed for the time necessary to process the order and thereafter until the expiry of the limitation period for claims under the contract concluded. In addition, after the expiry of this period, the data may still be processed by us for archival purposes for the possible need to defend, establish or assert claims, as well as to identify the returning customer. Please also note that we are obliged to keep accounting records, which may contain your personal data, for the period required by law.

Complaints and withdrawals – details

If you make a complaint or withdraw from the contract, you provide the personal data contained in the content of the complaint or statement of withdrawal, which includes your name, address, telephone number, e-mail address, bank account number. The provision of data is voluntary, but necessary in order to make a complaint or withdraw from the contract.

The data provided to us in connection with the lodging of a complaint or withdrawal from the contract are used for the purpose of the complaint procedure or withdrawal procedure and subsequently for archiving purposes, which is our legitimate interest (Article 6(1)(f) RODO).

The data will be processed for the time necessary to carry out the complaints procedure or the withdrawal procedure. Complaint documents will be stored until the warranty entitlement period has expired. Statements of withdrawal will be stored together with accounting records for the period required by law.

Newsletter – details

By subscribing to the newsletter, you provide us with your name and email address. The provision of data is voluntary, but necessary to subscribe to the newsletter.

In addition, our system used for the newsletter, records your IP number, which you used when signing up for the newsletter, determines your approximate location, the mail client you use for email and tracks your actions taken in relation to the messages sent to you. Accordingly, we also have information about which messages you have opened, within which messages you have clicked on links, etc.

The data you provide to us in connection with your subscription to the newsletter is used for the purpose of sending you the newsletter, and the legal basis for the processing is your consent (Article 6(1)(a) RODO) given when you signed up to the newsletter. With regard to the processing of information that does not originate from you but is collected automatically by our mailing system, we rely in this respect on our legitimate interest (Article 6(1)(f) RODO) to analyse the behaviour of newsletter subscribers in order to optimise mailing activities.

You can unsubscribe from the newsletter at any time by clicking on the dedicated link included in each message sent as part of the newsletter or by simply contacting us. Despite opting out of the newsletter, your data will continue to be stored in our database for the purpose of identifying the returning subscriber and for the possible defence of claims relating to the sending of the newsletter to you, in particular for the purpose of demonstrating the fact that you have given your consent to receive the newsletter and when you withdrew it, which is our legitimate interest referred to in Article 6(1)(f) of the RODO.

You can modify your data provided for the purposes of receiving the newsletter at any time by clicking on the relevant link visible in each message sent as part of the newsletter or by simply contacting us.

Product comments and opinions – details

When adding a comment or opinion on a product, you must provide at least a user name that will be assigned to the comment or opinion (the name may contain personal data, such as your first or last name) and an e-mail address. Providing this data is voluntary, but necessary to add a comment or opinion. You can also add your avatar (which may include your image, such as a photo) and provide your website address, but this is not obligatory.

Data provided in connection with the addition of a comment or opinion will be processed for the purpose of publishing the comment or opinion on the website. The basis for the processing is your consent (Article 6(1)(a)) resulting from the submission of the form used to publish your comment or opinion. You can withdraw your consent at any time by requesting that your comment or opinion be deleted.

Your comment or opinion will remain publicly available on the website for the duration of its online availability, unless you request the deletion of your comment or opinion beforehand. You can also modify the content of your comment at any time, as well as modify the data assigned to it as about the person who added the comment or opinion.

Correspondence handling – details 

When you contact us, you naturally provide us with your personal data contained in the content of your correspondence, in particular your e-mail address and your name. The provision of data is voluntary, but necessary in order to make contact.

Your data is processed in this case for the purpose of contacting you, and the basis for the processing is Article 6(1)(f) RODO, i.e. our legitimate interest. The legal basis for post-contact processing is also our legitimate purpose of archiving your correspondence for the purpose of ensuring that we can prove certain facts in the future (Article 6(1)(f) RODO).

The content of the correspondence may be subject to archiving and we are not in a position to determine unequivocally when it will be deleted. You have the right to request the history of any correspondence you have had with us (if it has been subject to archiving), as well as to request its deletion, unless its archiving is justified by our overriding interests, e.g. defence against potential claims from you.

Tax and accounting obligations – details

If we issue an invoice to you, it forms part of your accounting records, which will be kept for the period of time required by law. Your personal data is then processed for the purpose of fulfilling our tax and accounting obligations (Art. 6(1)(c) RODO in conjunction with the provisions governing tax and accounting obligations).

Archive – details

As part of the description of the various purposes for processing personal data above, we have indicated the time limits for storing personal data. These time limits are often related to our archiving of certain data for the purpose of ensuring that we are able to prove certain facts in the future, to reconstruct the course of our cooperation with you, the correspondence exchanged, to defend ourselves, to establish or assert claims. We rely in this respect on our legitimate interest as referred to in Article 6(1)(f) RODO.

Self-marketing – details

As part of our website, we use an abandoned cart recovery mechanism. In a situation where you start the ordering process but do not complete it, our system will note this fact in order to take action to encourage you to complete your order. These actions may include, but are not limited to, sending you an email with an incentive to complete your order or displaying a targeted advertisement while you are browsing the internet.

Analysis, statistics, optimisation – details

We collect statistical information about your browsing behaviour on our websites, such as clicks on links, transitions between sub-pages, time spent on individual pages, etc. We analyse this information in order to optimise our websites for user experience, efficiency and conversion. In most cases, the information processed in this way is not personal data. The exception is if you are a registered user. We may then collate this information with other data you have collected in your user account.

We carry out the activities described above on the basis of our legitimate interest referred to in Article 6(1)(f) RODO to optimise our websites.

# 7: How long will we keep your personal data?

Data retention periods are indicated separately in relation to each processing purpose. You will find this information within the details dedicated to each separate purpose of processing.

# 8: Who are the recipients of your personal data?

We would venture to say that modern business cannot do without services provided by third parties. We also make use of such services. Some of these services involve the processing of your personal data. Third-party service providers who are involved in the processing of your personal data are:

  • the cloud computing service provider where backups that may contain your personal data are stored,
  • the mailing system provider, where we store your data if you are a newsletter subscriber,
  • the provider of a CRM system in which we store your data in order to improve the customer service process and for archiving purposes,
  • the invoicing system provider, where we store your data for the purpose of invoicing,
  • the accounting firm, which processes your data shown on invoices,
  • the courier companies that process your data to the extent necessary to deliver your order,
  • a law firm that accesses your data where this is necessary to provide legal assistance to us,
  • a maintenance service provider who accesses the data if the technical work carried out relates to areas where personal data is located,
  • other subcontractors who access the data if the scope of their activities requires such access.

Your personal data may also be forwarded to the tax authorities to the extent necessary for the fulfilment of tax and accounting obligations. This includes, in particular, all declarations, reports, statements and other accounting documents containing your personal data.

In addition, if necessary, your personal data may be made available to entities, authorities or institutions entitled to access the data under the law, such as police services, security services, courts, public prosecutors’ offices.

Furthermore, we use tools that collect a range of information about you related to your use of our website. This includes, in particular, the following information:

  • information about the operating system and the web browser you are using,
  • your browsing activity
  • time spent on the site,
  • transitions between different sub-pages,
  • clicks on individual links,
  • the source you came to our site from,
  • the age range you are in,
  • Your gender,
  • Your approximate location limited to your locality.
  • Your interests as determined by your online activity.

This information in itself does not, in our opinion, have the nature of personal data. As this information is collected by the external tools we use, this information is also processed by the tool providers under the terms of their terms of use and privacy policies. Generally, this information is used to provide, improve and manage our services, to develop new services, to measure the effectiveness of advertising, to protect against fraud and abuse, and to personalise the content and advertising displayed on individual services, websites and applications. We have attempted to describe the details of this later in this policy as part of the explanation of each tool.

# 9: Do we transfer your data to third countries or international organisations?

Yes, part of the processing of your personal data may involve the transfer of your data to third countries.

We transfer your personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, in particular in the USA. The providers of these tools guarantee an adequate level of protection of personal data through the relevant compliance mechanisms provided for by the RODO, in particular by joining the Privacy Shield programme or by using standard contractual clauses.

  • ActiveCampagne mailing system, whose provider is ActiveCampagne LLC, 1 North Dearborn Street, Suite 500, Chicago, IL 6062, USA – with regard to your name, email address, IP address and statistical information related to your reactions to the messages we send,
  • Google’s G-Suite services, whose provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland – with respect to all data processed by Google services, including that contained in files subject to synchronisation with Google Drive.
  • Google: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI,
  • Vimeo INC, 555 West 18th Street, New York, New York 10011-in order to use the videos of the Vimeo service, which involves the use of cookies,
  • Owners of social networks: Facebook, Instagram, LinkedIn, YouTube under the terms of the data processing defined by the owners of these sites, in the event that you like my social profiles carried out within these sites.2) Your data may be transferred by data recipients outside the EEA. The guarantees for the protection of your data derive from the participation of data recipients in the Privacy Shield programme established under Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-US Privacy Shield (ActiveCampaign LLC: https://www.privacyshield.gov/participant?id=a2zt0000000GnH6AAK, Google LLC: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active, Vimeo INC: https://www.privacyshield.gov/participant?id=a2zt00000008V77AAE&status=Active)

# 10: Do we use profiling? Do we make automated decisions based on your personal data?

We do not make decisions to you based solely on automated processing, including profiling, which would produce legal effects on you or similarly significantly affect you.

Yes, we do use tools that may take certain actions depending on the information collected through tracking mechanisms, but we believe that these actions do not materially affect you as they do not differentiate your situation as a customer, do not affect the terms of the contract you may enter into with us, etc.

Using certain tools, we may, for example, target you with personalised advertising based on previous actions you have taken on our website or suggest products that may be of interest to you. This is known as behavioural advertising. We encourage you to learn more about behavioural advertising, particularly with regard to privacy issues. You can find detailed information, including the possibility of managing your settings with regard to behavioural advertising, here: http://www.youronlinechoices.com.

We emphasise that within the tools we use, we do not have access to information that would allow us to identify you. The information we are referring to here is, in particular:

  • information about the operating system and the web browser you are using,
  • your browsing activity
  • time spent on the site,
  • transitions between pages,
  • the source you came to our site from,
  • your age range,
  • your gender,
  • Your approximate location limited to your town,
  • Your interests as determined by your online activities.

We do not collate the information indicated above with your personal data held in our databases. This information is anonymous and does not allow us to identify you. This information is stored on the servers of the providers of the individual tools, and these servers can most often be located around the world.

An exception to the anonymous nature of the information referred to above is if you have a user account. In that case, this information may be collated with your data stored in your user account. However, we still do not, using this information, make decisions towards you based solely on automated processing, including profiling, which would produce legal effects towards you or similarly significantly affect you. We consider that the activities of targeting you with advertisements depending on your activity on our website and taking optimisation measures do not materially affect you. Therefore, we rely on our legitimate interest as referred to in Article 6(1)(f) of the RODO in this respect.

# 11: What rights do you have in relation to the processing of your personal data?

The RODO grants you the following potential rights in relation to the processing of your personal data:

  • the right to access your data and to receive a copy of your data,
  • the right to rectification (amendment) of your data,
  • the right to erasure (if, in your opinion, there are no grounds for us to process your data, you can request that we erase it),
  • the right to restrict the processing of your data (you can request that we restrict the processing of your data only to storing it or carrying out activities agreed with you, if in your opinion we have incorrect data or are processing it unfoundedly),
  • the right to object to processing (you have the right to object to processing on the basis of a legitimate interest; you should indicate the particular situation which you think justifies us stopping the processing covered by your objection; we will stop processing your data for these purposes unless we can demonstrate that the grounds for our processing override your rights or that your data is necessary for us to establish, assert or defend our claims),
  • the right to data portability (you have the right to receive from us in a structured, commonly used machine-readable format the personal data you have provided to us under the contract or your consent; you can have this data sent directly to another party),
  • the right to withdraw your consent to the processing of personal data where you have previously given such consent,
  • the right to lodge a complaint with a supervisory authority (if you find that we are processing your data unlawfully, you may lodge a complaint to this effect with the President of the Office for Personal Data Protection or any other competent supervisory authority).

The rules related to the exercise of the rights indicated above are described in detail in Articles 16 – 21 of the RODO. We encourage you to familiarise yourself with these provisions. For our part, we consider it necessary to explain to you that the rights indicated above are not absolute and you will not be entitled to them in relation to all processing activities of your personal data.

We would like to emphasise that one of the rights indicated above is always available to you – if you consider that we have committed an infringement of data protection legislation in the processing of your personal data, you have the possibility to lodge a complaint with the supervisory authority (the President of the Office for Personal Data Protection).

You can also always request that we provide you with information about what data we hold about you and for what purposes we process it. All you need to do is send an email to support@kedu.ac. However, we have made every effort to ensure that the information of interest to you is comprehensively set out in this privacy policy. You can also use the e-mail address given above if you have any questions about the processing of your personal data.

# 12: Do we use cookies and what are they?

Our website, like almost all other websites, uses cookies.

Cookies are small textual information stored on your terminal device (e.g. computer, tablet, smartphone) which can be read by our ICT system (our own cookies) or the ICT systems of third parties (third-party cookies). In cookies, specific information can be saved and stored, which ICT systems can then access for specific purposes.

Some of the cookies we use are deleted when your browser session ends, i.e. when you close your browser (so-called session cookies). Other cookies are stored on your terminal device and enable us to recognise your browser the next time you visit the website (persistent cookies).

If you want to find out more about cookies as such, you can read, for example, this material: https://en.wikipedia.org/wiki/HTTP_cookie.

# 13: On what basis do we use cookies?

We use cookies on the basis of your consent, except where cookies are necessary for the correct provision of the electronic service to you.

Cookies that are not necessary for the correct provision of the electronic service to you will remain blocked until you have given your consent to our use of cookies. During your first visit to our website, we display a message asking you for your consent together with the option of managing cookies, i.e. deciding which cookies you agree to and which you wish to block.

As far as your consent to cookies is concerned, we accept the option that you give your consent through the settings of your Internet browser or through additional software supporting the management of cookies. We assume that you agree to all cookies used by us that are not blocked by your browser or the additional software you use.

Please note that disabling or restricting cookies may prevent you from using some of the features available on the website and may cause difficulties in using our website, as well as many other websites that use cookies. For example, if you block social media plug-in cookies, the buttons, widgets and social features implemented on our site may not be available to you.

# 14: Can you disable cookies?

Yes, you can manage your cookie settings within your web browser. You can block all or selected cookies. You can also block the cookies of specific sites. You can also delete previously saved cookies and other site and plug-in data at any time.

Web browsers also offer the option of using incognito mode. You can use this mode if you do not want information about websites you have visited and files you have downloaded to be saved in your browsing and download history. Cookies created in incognito mode are deleted when all windows in this mode are closed.

Browser plug-ins to control cookies are also available, such as Ghostery (https://www.ghostery.com). The option to control cookies may also be provided by additional software, in particular anti-virus packages, etc.

Furthermore, there are tools available on the internet that allow the control of certain types of cookies, in particular the collective management of behavioural advertising settings (e.g. www.youronlinechoices.com/, www.networkadvertising.org/choices).

# 15: For what purposes do we use our own cookies?

Proprietary cookies are used to ensure the proper functioning of the various mechanisms of the website, such as maintaining the session after logging into your account, remembering the last products you browsed and the products you added to your shopping cart.

# 16: What third-party cookies are used?

The following third-party cookies operate within our website:

  • Google Analytics,
  • Google Tag Manager,
  • Google AdWords,
  • Google AdSense,
  • Facebook Custom Audiences,
  • Facebook, Twitter, LinkedIN, Pinterest (social media cookies),
  • Vimeo,
  • Hotjar,
  • YouTube.

Details of individual third-party cookies are described below.

Google Analytics – details

We use the Google Analytics tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We carry out activities in this respect based on our legitimate interest in creating statistics and analysing them in order to optimise our websites.

In order to use Google Analytics, we have implemented a special Google Analytics tracking code in the code of our website. The tracking code uses cookies from Google LLC concerning the Google Analytics service. You can block the Google Analytics tracking code at any time by installing the browser add-on provided by Google: https://tools.google.com/dlpage/gaoptout.

Google Analytics automatically collects information about your use of our website. The information collected in this way is usually transmitted to and stored on Google servers, which may be located around the world.

Due to the IP address anonymisation activated by us, your IP address is truncated before being passed on. Only in exceptional cases is the full IP address transmitted to Google’s servers and only shortened there. The anonymised IP address transmitted by your browser within the scope of Google Analytics is generally not combined with other Google data.

We would like to emphasise that we do not collect any data within the scope of Google Analytics that would allow you to be identified. Therefore, the data collected within the framework of Google Analytics does not have the character of personal data for us. The information we have access to within Google Analytics is, in particular:

  • information about the operating system and the internet browser you are using,
  • the pages you view within our site
  • the time you spend on our site and on its sub-sites,
  • transitions between pages,
  • the source from which you came to our site.

In addition, we use the following Advertising Functions within Google Analytics:

  • demographic and interest reports,
  • remarketing,
  • ad reporting functions, user-ID.

As part of the Advertising Functions, we also do not collect personal data. The information we have access to is, in particular:

  • the age range you are in,
  • your gender
  • Your approximate location limited to your locality,
  • Your interests as determined by your online activities.

Google Analytics and Google Analytics 360 services have been certified to the independent security standard ISO 27001. ISO 27001 is one of the most widely recognised standards in the world and certifies that the systems operating Google Analytics and Google Analytics 360 meet the relevant requirements.

If you are interested in the details related to Google’s use of data from sites and applications that use Google services, we encourage you to read this information: https://policies.google.com/technologies/partner-sites.

Google Tag Manager – details

We use the Google Tag Manager tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and allows us to manage tags, which are small pieces of code through which we are able to control user traffic and behaviour, collect information about the effectiveness of advertising and take action to improve our website. Google Tag Manager does not collect any personally identifiable information about you, however, this tool triggers other tags which in turn may collect data.

Google AdWords – details

We use remarketing functions available within the Google AdWords system operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We carry out activities in this respect based on our legitimate interest in marketing our own products or services.

When you visit our website, a remarketing cookie from Google is automatically left on your device, which collects information about your activity on our website. With the information collected in this way, we are able to display advertisements to you within the Google network depending on your behaviour on our website. For example, if you view a product, this information will be recorded by a remarketing cookie so that we can target you with an ad for that product or any other ad we deem appropriate. This advertising will be displayed to you within the Google network when you use the Internet, browse other websites, etc.

We emphasise that we, when using Google Ads, do not collect any data that would allow you to be identified. The possible collation of data in such a way that it takes on the character of personal data may be carried out on Google’s part, but to this extent, we are no longer responsible for this, as Google carries out these activities on the basis of the agreement concluded with you as a user of Google services.

We, using Google AdWords, are only able to define the audience groups we would like our advertisements to reach. On this basis, Google decides when and how it will present our advertising to you.

Further processing of your information only takes place if you have agreed to Google linking your browsing history to your account and using information from your Google account to personalise the advertisements that are displayed on the websites. In this case, Google will use your data to create and define target group lists for remarketing purposes on different devices. For this purpose, Google will temporarily combine the information collected with other data it has in order to create target groups.

If you do not wish to receive personalised advertising, you can manage your advertising settings directly on Google’s website: https://adssettings.google.com/.

If you are interested in details related to Google’s use of data from sites and applications that use Google services, we encourage you to read this information: https://policies.google.com/technologies/partner-sites.

Google AdSense – details

We display advertisements on our pages as part of the Google AdSense network operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We carry out activities in this respect based on our legitimate interest in monetising the content we publish.

Our website, in connection with the display of advertisements on it within the AdSense network, contains advertising tags which issue your browser with a command to send a request for advertising content from Google’s servers. Along with the advertising content, the server also sends a cookie. Cookies are used to display advertisements based on your previous visits to our website or other websites. AdSense also uses cookies to improve the quality of advertisements. Common uses include targeting ads based on topics of interest to you, improving campaign performance reports and skipping ads you have already seen.

We emphasise that we, using Google AdSense, do not collect any data that would allow you to be identified. The possible compilation of data in such a way that it acquires the character of personal data may be carried out on Google’s part, but to this extent we are no longer responsible for this, as Google carries out these activities on the basis of the agreement concluded with you as a user of Google services.

Further processing of the information only takes place if you have consented to Google linking your browsing history to your account and using the information from your Google account to personalise the advertisements that are displayed on the websites. In this case, Google will use your data to create and define target group lists for remarketing purposes on different devices. For this purpose, Google will temporarily combine the information collected with other data it has in order to create target groups.

If you do not wish to receive personalised advertising, you can manage your advertising settings directly on the Google website: https://adssettings.google.com/.

If you are interested in details related to Google’s use of data from sites and applications that use Google services, we encourage you to read this information: https://policies.google.com/technologies/partner-sites.

Facebook Custom Audiences – details

As part of the Facebook Ads system provided by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA, we use the Custom Audience Groups function to target specific user groups with targeted advertising messages. We carry out activities in this regard based on our legitimate interest in marketing our own products or services.

In order to target you with advertisements personalised to your behaviour on our website, we have implemented the Facebook Pixel within our website, which automatically collects information about your use of our website. The information collected in this way is usually transmitted to Facebook servers, which may be located worldwide, particularly in the United States of America (USA).

The information collected as part of the Facebook Pixel is anonymous, i.e. it does not allow us to identify you. Depending on your activity on our pages, you may reach a specific audience, but we do not in any way identify individuals belonging to these groups.

However, we would like to inform you that Facebook may combine the information collected with other information about you collected through your use of Facebook and use it for its own purposes, including marketing. Such activities of Facebook are no longer dependent on us, and you can look for information about them directly in Facebook’s privacy policy: https://www.facebook.com/privacy/explanation. From your Facebook account, you can also manage your privacy settings. Here you will find useful information in this regard: https://www.facebook.com/ads/settings.

Social tools – details

Our website uses plugins, buttons and other social media tools, collectively referred to as “plugins”, provided by social networks such as Facebook, Instagram, LinkedIN, Twitter, Pinterest.

When you view our website containing a plug-in of a particular social network, your browser sends information to the administrator of this social network about your visit. As the plug-in is a piece of the social network embedded in our website, your browser sends a request to download the content of the respective social network to our website.

Plug-ins collect certain information about you, such as your user ID, the website you visited, the date and time and other browser information.

The social network administrators use some of this information to personalise the viewing experience on our site. For example, when you visit a page with a “Like” button, the social network administrator needs information about who you are in order to show you which of your friends also like our page.

The information collected by the plugins may also be used by the social network administrators for their own purposes, such as, for example, improving their own products, creating user profiles, analysing and optimising their own activities, targeting advertisements. We have no real influence on how the information collected by the plugins is subsequently used by the social network administrators. You can refer to the rules and privacy policies of the individual social networks for details in this regard.

Social network plug-ins collect and transmit information to the administrators of these social networks even when you browse our website without being logged into your social network account. However, the browser then sends a more limited set of information.

If you have logged in to one of the social networks, the administrator of the social network will be able to directly attribute your visit to our website to your profile on the respective social network.

If you do not want the social networks to attribute the data collected during your visit to our website directly to your profile on the respective social network, then you must log out of that social network before visiting our website. You can also prevent plug-ins from loading on the website altogether by using appropriate extensions for your browser, such as script blocking.

In addition, the use of certain plug-ins may involve the publication of certain information within your social profiles. For example, information about clicks on the ‘Like’ button may be available on your Facebook timeline. Of course, if you share some content on your social media using plugins embedded on our website, this sharing will naturally be visible on your profile.

With regard to the details related to the processing by the social media administrators of the information collected by the plugins, in particular the purpose and scope of the data collection and its further processing and use by the administrators, as well as the possibility to contact us and your rights in this respect and the possibility to make settings to ensure the protection of your privacy, you will find everything in the privacy policies of the respective service providers:

Hotjar – details

We use the Hotjar tool to better understand your needs and to optimise our website for your user experience, which is our legitimate interest. The tool is provided by a third party entity, i.e. Hotjar Limited, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta.

Hotjar records every visitor to our site and enables us to play a video recording of their traffic on our site, as well as to generate so-called heat maps. Within the Hotjar tool we do not have access to information that allows us to identify you, as Hotjar does not record the process of filling in forms. The information we have access to within Hotjar is, in particular:

  • information about the operating system and the internet browser you are using,
  • the pages you view within our site,
  • the time spent on our site and on any sub-sites,
  • transitions between pages within our site,
  • the source from which you navigate to our site,
  • the locations you clicked on.

In order to use Hotjar, we have implemented a special Hotjar tracking code in the code of our website. The tracking code uses cookies from Hotjar Limited. The information collected through cookies is stored by Hotjar as part of a pseudonymous user profile. Neither Hotjar nor we use this information to identify you.

You can object to Hotjar’s creation of your user profile, Hotjar’s storage of information about your use of our website and Hotjar’s use of cookies here: https://www.hotjar.com/legal/compliance/opt-out.

If you are interested in the details related to Hotjar’s data processing, we encourage you to read Hotjar’s privacy policy: https://www.hotjar.com/legal/policies/privacy.

YouTube – details

YouTube widgets are embedded on our pages, allowing you to play videos available on YouTube directly from our pages. YouTube is operated by Google LLC.

The videos are embedded on the website in a privacy-protected mode. Based on the information provided by YouTube, this means that no cookies are stored on your device nor does Google collect any information about you until you play the recording.

When you play a video, YouTube saves cookies on your device and receives information that you have played the video from a specific website, even if you do not have a Google Account or are not currently signed in. If you are logged in to your Google account, this service provider will be able to directly associate your visit to our website with your account. The purpose and scope of data collection and their further processing and use by Google, as well as your rights in this respect and the possibility to make settings to protect your privacy are described in Google’s privacy policy.

If you do not want Google to attribute the data collected during video playback directly to your profile, you must log out of your account before playing the video. You can also prevent the loading of plug-ins on the website altogether by using appropriate extensions for your browser, such as script blocking.

The information collected through the cookies associated with the YouTube videos embedded on our pages is used by Google in order to ensure the correct and safe functioning of the widget, to analyse and optimise the services provided by YouTube, as well as for personalisation and advertising purposes.

Please note that by playing the videos available on YouTube, you are using services provided electronically by Google LLC. Google LLC is an independent, third-party provider of electronic services to you. For details on YouTube’s terms of use, including privacy, you can refer to the documents provided directly by YouTube:

  • terms and conditions: https://www.youtube.com/t/terms,
  • privacy policy: https://policies.google.com/privacy.

Vimeo – details

Vimeo widgets are embedded on our pages, allowing you to play the recordings available on Vimeo directly from our pages. Vimeo is operated by Vimeo INC.

The videos are embedded on the website in a privacy-protected mode. Based on the information provided by Vimeo, this means that no cookies are stored on your device nor does Vimeo collect any information about you until you play the recording.

When you play a recording, Vimeo saves cookies on your device and receives information that you have played the recording from a specific website, even if you do not have a Vimeo account or are not currently logged in. If you have logged into your Vimeo account, this service provider will be able to directly associate your visit to our website with your account. The purpose and scope of data collection and the further processing and use of your data by Vimeo, as well as the possibility to contact us and your rights in this respect and the possibility to make settings to protect your privacy are described in Vimeo’s privacy policy.

If you do not want Vimeo to attribute the data collected during video playback directly to your profile, you must log out of your account before playing the video. You can also completely prevent plug-ins from loading on the website by using the appropriate extensions for your browser, such as script blocking.

The information collected through cookies related to embedded videos from Vimeo on our pages is used by Vimeo to ensure the correct and secure functioning of the widget, to analyse and optimise the services provided by YouTube, as well as for personalisation and advertising purposes.

Please note that by playing the recordings available on Vimeo, you are using the services provided electronically by Vimeo INC, 555 West 18th Street, New York, New York 10011 is a standalone, independent entity providing electronic services to you. You may refer to the documents provided directly by Vimeo for details regarding Vimeo’s terms of use, including privacy protections:

  • terms and conditions: https://www.vimeo/terms,
  • privacy policy: https://vimeo.comm/privacy.

# 17: Do we track your behaviour on our website?

Yes, we use Google Analytics, Google AdWords, Hotjar and Facebook Custom Audiences tools that involve collecting information about your activities on our website. These tools are described in detail under the question on third-party cookies, so we will not repeat this information here either.

# 18: Do we target ads to you?

Yes, we use Facebook Ads and Google Ads, where we can target adverts to specific target groups defined based on various criteria such as age, gender, interests, profession, job, activities previously undertaken on our website. These tools are described in detail under the question on third-party cookies, so we will not repeat this information here either.

# 19: How can you manage your privacy?

The answer to this question can be found in many places in this privacy policy when describing the various tools, behavioural advertising, cookie consent, etc. Nevertheless, we have once again gathered this information in one place for your convenience. Below you will find a list of options for managing your privacy.

  • the cookie settings within your internet browser,
  • browser plug-ins supporting cookie management, e.g. Ghostery,
  • additional cookie management software
  • incognito mode in your browser
  • behavioural advertising settings, e.g. youronlinechoices.com,
  • the cookie management mechanism from our website,
  • Google Analytics Opt-out:
  • Google Ads Settings: https://adssettings.google.com/
  • Facebook Ads Settings: https://www.facebook.com/ads/settings
  • HotJar Opt-out: https://www.hotjar.com/legal/compliance/opt-out

# 20: What are server logs?

Using the website involves sending requests to the server where the website is stored. Each request made to the server is recorded in the server logs.

The logs include, among other things, your IP address, the date and time of the server, information about your browser and the operating system you are using. The logs are saved and stored on the server.

The data stored in the server logs are not associated with specific users of the website and are not used by us to identify you.

The server logs are only ancillary material for the administration of the site and their contents are not disclosed to anyone other than those authorised to administer the server.

# 21: Is there anything else you should know?

As you can see, the topics of personal data processing, the use of cookies and the management of privacy in general are quite complex. We have done our best to ensure that this document provides you with as much knowledge as possible on the issues that are important to you. If anything is unclear to you, you would like to find out more or simply discuss your privacy, please email us at support@kedu.ac.