Privacy Policy

This Privacy Policy applies worldwide. Where mandatory local privacy laws
apply, such laws prevail, and this Privacy Policy explains how you can exercise
your rights.
This Privacy Policy explains our commitments and your rights concerning your
information. You should read the Privacy Policy carefully. If you do not agree
with this Privacy Policy, please do not use our Sites or Services. The Privacy
Policy is duly incorporated and subject to the Terms of Service and governs the
same Services and Sites as the ones mentioned in the Terms of Service. Any
terms we use in the Privacy Policy without defining them have the same
definition given to them in the Terms of Service.
BASICALLY
This Privacy Policy applies everywhere we operate. Local privacy laws may give
you extra rights, and if they do, those rules come first. This policy explains how
we use your data and what rights you have. By using our sites or services, you
agree to it. If you do not agree, please do not use our services.
WE COLLECT INFORMATION THE FOLLOWING WAYS:
• When you give it to us or give us permission to obtain it
We may collect information from you in a variety of ways such as your name,
email address, phone number and bank account information. You may,
however, visit our Sites anonymously if you choose to do so. We will collect
information from you only if you voluntarily choose to submit such information
to us. You can always refuse to provide this information to us. If you choose to
subscribe to a Service from us, we or the mobile operator of your network will
collect your information related to the payment for the subscription of our
Services. Account and billing information collected by the mobile operator is
subject to their respective privacy policies.
• We get technical information when you visit our Sites and/or
Services We may collect technical information about you whenever you visit our Sites or
use our Services. Technical information we collect may include the user agent,
and technical information about your means of connection to our Site, such as
the type of device you use, the device screen size, browser type, geographic
location (country only), unique device identifiers, Internet Protocol address,
mouse events (movements, location and number of clicks), landing pages,
operating system, information about your use of our Services and other similar
information.
We also use cookies and other technologies to collect technical information
from you. A cookie is a piece of information that is stored on your device’s hard
drive for record-keeping purposes and sometimes to track information. For
example, we use cookies to store your language preferences or other
redundant settings, so you don’t have to set them up every time you visit our
Sites or Services.
• Our partners and advertisers collect and share information with us
We use Google Analytics, a web analysis service of Google Inc. (“Google”) which
assists website owners and operators in learning and understanding the usage
patterns of visitors who use their websites by collecting information, namely;
which individual web pages were visited, how long users spent on the website,
which websites referred the most visitors, general geographic location of
visitors, and other similar anonymous statistics.
For this reason, Google Analytics may create and store several cookies on your
device. Google Analytics does not collect any personally identifiable information
by default. Google Analytics collects anonymized IP address or internet
connections used by visitors to websites on which Google Analytics has been
installed. Google Analytics does not reveal or expose the IP address of visitors
to the owners of the website on which Google Analytics is installed.
We also use Google AdWords remarketing services to advertise on third-party
websites including Google, to visitors who have previously visited our Sites or
Services. The advertisement can be on the Google search results page or a
website that has the Google display network implemented. For this reason,
third-party vendors including Google may create several cookies on your
device. We also enable Hotjar, an analysis software, by inserting a tracking code within
our Sites and Services, which further transmits to Hotjar servers based in
Ireland (EU).
This tracking code contacts Hotjar’s servers and provides a script to your device
accessing the Site or Service. This script will capture specific data related to your
interaction with that particular Site or Service. This information is then sent to
Hotjar’s servers for further processing. Through these tools, we receive
heatmaps, visitor’s recordings, funnels and form analysis, that help us to
provide you with a better experience and service as well as assist us in
diagnosing technical problems and analyse user trends.
Hotjar uses cookies to collect technical information including standard internet
log information and details of your behavioural patterns when you visit our
Sites and Service. This is done to provide you with a better experience, identify
preferences, diagnose technical problems, analyse trends and generally to help
improve our Sites and Services. Hotjar may also use cookies to record login
details on your device. This helps to determine whether a particular device
previously visited our Sites or Services so that the login details would not have
to be re-entered each time you visit that Site or Service. Hotjar also uses cookies
to determine if someone has opted out of being tracked by Hotjar services.
Furthermore, we use Google DoubleClick to advertise based on what’s relevant
to a user, improve reporting on campaign performance, and to avoid showing
advertisements the user has already seen. For this reason, Google DoubleClick
creates several cookies on your device. For example, Google DoubleClick uses
cookies to keep a log of which advertisements were shown on which browser.
When it’s time to serve an advertisement to a browser, Google DoubleClick can
use the browser’s cookies to check which Google DoubleClick advertisements
have already been delivered to that particular browser. That’s how Google
DoubleClick avoids showing advertisements the user has already seen. In the
same way, cookies allow Google DoubleClick to log conversions related to
advertisement requests—such as when a user views a Google DoubleClick
advertisement and later uses the same browser to visit the advertiser’s website
and make a purchase.
BASICALLY This Privacy Policy applies everywhere we operate. Local privacy laws may give
you extra rights, and if they do, those rules come first. This policy explains how
we use your data and what rights you have. By using our sites or services, you
agree to it. If you do not agree, please do not use our services.
HOW TO PREVENT COOKIE STORAGE AND OPT-OUT?
You may choose to set your web browser to refuse cookies or to alert you when
cookies are being sent.
You can also prevent the collection of your data by Google Analytics by visiting
Google Analytics opt-out page and installing the Google add-on for your
browser. https://tools.google.com/dlpage/gaoptout or
visit https://www.google.com/settings/ads to set your settings for Google
Analytics, Google AdWords, and Google DoubleClick.
You may opt-out from having Hotjar collect your information when visiting our
Sites and Services at any time by visiting www.hotjar.com/opt-out and clicking
‘Disable Hotjar’.
For more details on installing and uninstalling the Google add-on, Google
Analytics, Google DoubleClick or AdWords, please visit Google’s website.
BASICALLY
You can control cookies and tracking. Change your browser settings to block
them or use the tools from Google or Hotjar to opt out. Links are provided if
you want to stop being tracked.
HOW WE USE COLLECTED INFORMATION
We may use your information for the following purposes:
• Provide the Service(s) you request.
• Bill and collect for the Service(s) provided to you.
• Send you marketing communications.
• Provide customer care.
• Protect our rights or property.
• Enforce the Terms of Service.
• Comply with legal requirements. • To improve our Sites and Services.
• Respond to your inquiries, questions, and/or other requests; and
• Respond to court orders, subpoenas or other legal proceedings.
We process your personal data only where a lawful basis applies, including:
• Contract performance (to provide Services to you).
• Legal obligation (where we must comply with law).
• Legitimate interests (to improve our services, prevent fraud, protect
security), balanced against your rights.
• Your consent (e.g., for marketing or newsletters).
BASICALLY
We use your information to:
• Provide and bill our services,
• Answer your questions,
• Improve our sites,
• Send you marketing if you agree,
• Protect against fraud and follow the law.
We only use your data when we have a valid reason — for example, to perform
a contract, meet legal obligations, protect our interests (balanced with your
rights), or when you give consent.
HOW LONG WE KEEP YOUR INFORMATION
We retain personal data only as long as necessary for the purposes described in
this Policy and as required by applicable law. Once retention is no longer
necessary, we securely delete or anonymize your data. In some jurisdictions
(e.g., EU, UK, Canada), you may request earlier deletion where retention is not
legally required.
BASICALLY We only keep your information as long as we need it for services or as required
by law. After that, we delete or anonymize it. In some places (like EU, UK,
Canada), you can ask us to delete it sooner if it’s no longer required.
HOW WE PROTECT YOUR INFORMATION ALSO OUTSIDE THE EU
We are concerned with protecting your privacy and data, but we cannot ensure
or warrant the security of any information you transmit to us or guarantee that
your information may not be accessed, disclosed, altered or destroyed by
breach of any of our industry standard physical, technical or managerial
safeguards. We adopt appropriate data collection, storage and processing
practices and security measures to protect against unauthorized or accidental
access, alteration, disclosure or destruction of your information, transaction
information and data stored on our Sites.
However, no method of transmission over the internet or method of electronic
storage is 100% secure. Therefore, we cannot guarantee its absolute security.
We will continue to enhance our security procedures as new technology
becomes available.
Because we operate internationally, your personal information may be
transferred outside your country of residence, including to the United States,
the United Arab Emirates, and other jurisdictions. Where required by law (e.g.,
EU/UK GDPR), we use appropriate safeguards such as Standard Contractual
Clauses approved by the European Commission or the UK ICO, or other lawful
transfer mechanisms. Where UAE Federal Decree-Law No. 45 of 2021 requires
prior approval from the UAE Data Office for transfers outside the UAE, or where
data localization obligations apply, we will comply with those requirements
before transferring your data.
BASICALLY
We do our best to keep your data safe with technical and organizational
measures, but no system is 100% secure. Sometimes your data needs to be
transferred internationally (for example, to the US or UAE). We use legal
safeguards (like approved contracts) when required. In the UAE, if the law
requires that data stays in the country or needs government approval before
leaving, we follow those rules
SHARING YOUR INFORMATION We share your information with online advertisers and third-party companies
that we or they use to audit or improve the delivery and performance of ads or
content on websites and apps (for example, through Google Analytics and
Google AdWords) as outlined above.
Other than as explicitly described in this Privacy Policy, we will not share
personally identifiable information with any third party. However, we reserve
the right to share the information that we collect with third parties in
aggregated and/or anonymous form, and we will not necessarily ask for your
permission or even inform you that we are doing so. We may also disclose
information that we collect, if required to do so by law or in good faith that
disclosure is necessary to (1) comply with the law or with legal process served
on us; (2) protect and defend our rights or property; or (3) act in an emergency
to protect someone’s safety. Note that we may be required to release
personally identifying data in response to lawful requests from public
authorities including to meet national security and law enforcement
requirements.
BASICALLY
We may share anonymous or aggregated data with partners like Google or
Hotjar to improve ads and services. We do not sell your personal information.
We only share identifiable information if required by law, to protect our rights,
or in emergencies. Authorities may request it for national security or law
enforcement.
CHILDREN’S PRIVACY
Protecting the privacy of children is important. We do not knowingly collect or
solicit information from anyone under the age of 13. If you are based in the
EU/UK, we do not knowingly collect data from children under the age of 16
without parental consent, unless local law sets a lower age (not below 13).
California residents under 16 years of age may have additional rights regarding
the collection and sale of their personal information.
In Singapore, parental consent is required for children under the age of 13 in
accordance with the PDPA.
BASICALLY We do not collect information from children under 13. In the EU/UK, we also
require parental consent if the child is under 16 (or a lower local age, but never
under 13). In California, children under 16 have special rights. In Singapore,
parental consent is required for children under 13.
YOUR PRIVACY RIGHTS BY JURISDICTION
European Union (GDPR)
If you are located in the EU, we process your personal data under the General
Data Protection Regulation (EU) 2016/679 (GDPR). You have the right to access,
rectify, erase, or restrict processing of your personal data; data portability;
object to processing based on legitimate interest; and lodge a complaint with
your local supervisory authority. Where required, we have appointed a Data
Protection Officer and an EU representative to ensure compliance.
United Kingdom (UK GDPR)
If you are located in the UK, our processing is subject to the UK GDPR and the
Data Protection Act 2018. You have the same rights as under GDPR and may
complain to the UK ICO. Where required, we have appointed a UK
representative.
United States (CCPA/CPRA and state laws)
If you are a resident of California, the California Consumer Privacy Act of 2018,
as amended by the California Privacy Rights Act of 2020, grants you rights to
know what data we collect, request deletion, correct inaccurate data, opt out of
“sale” or “sharing,” and not be discriminated against. Residents of other U.S.
states may have similar rights under local laws (e.g., Colorado, Virginia,
Connecticut, Utah). We will comply with mandatory state laws that apply to you.
Canada (PIPEDA)
If you are located in Canada, your personal information is protected under the
Personal Information Protection and Electronic Documents Act (PIPEDA) and
applicable provincial laws. You have the right to access the personal
information we hold, request correction of inaccuracies, withdraw consent
(subject to legal/contractual limits), and complain to the Office of the Privacy
Commissioner of Canada (OPC). In Quebec, additional rights may apply,
including enhanced consent requirements and mandatory breach notifications
under Law 25. Singapore (PDPA)
If you are located in Singapore, we comply with the Personal Data Protection
Act 2012 (PDPA). You have the right to be informed of purposes for collection,
use and disclosure; access and request correction of your data; withdraw
consent at any time (subject to restrictions); opt out of marketing via the Do Not
Call Registry; and be notified where a data breach has occurred that poses a
risk of significant harm.
United Arab Emirates (UAE PDPL and DIFC DP Law)
If you are located in the UAE, we comply with Federal Decree-Law No. 45 of
2021 (UAE PDPL). If your data is processed in the Dubai International Financial
Centre, the DIFC Data Protection Law No. 5 of 2020 applies. You have the right
to be informed of collection and use; access, correct, or delete personal data;
withdraw consent where applicable; object to certain processing; and complain
to the UAE Data Office or the DIFC Commissioner of Data Protection.
BASICALLY
Depending on where you live, you have different rights:
• EU: You can access, correct, delete, restrict, or move your data, and
complain to your local regulator.
• UK: Same rights as EU, with complaints to the ICO.
• US: In California and some other states, you can see what we collect,
delete it, correct it, opt out of selling/sharing, and not face discrimination.
• Canada: You can see, correct, and withdraw consent for your data, and
complain to federal or provincial regulators. In Quebec, you get even
stricter rights (like stronger consent and breach notifications).
• Singapore: You can access, correct, withdraw consent, stop marketing
via the Do Not Call Registry, and will be notified if a serious breach
happens.
• UAE: You can see, correct, delete, or object to use of your data, withdraw
consent, and complain to the UAE Data Office or DIFC regulator.
ACCEPTANCE OF PRIVACY POLICY
By using the Sites or any of our Services, you consent to our collection and use
of your information in accordance with this Privacy Policy. We reserve the right to modify this Privacy Policy at any time by posting the changes on this page. If
we modify the terms of this Privacy Notice, we will notify you by posting a notice
on our website thirty (30) days prior to the effective date of the changes.
Please check the revision date at the bottom of this page to determine if the
policy has been modified since you last reviewed it. Your continued use of any
portion of our Site or Services following the posting of the updated Privacy
Policy will constitute your acceptance of the changes.
BASICALLY
By using our services, you agree to this Privacy Policy. If we change it, we will
post an update and give you notice 30 days before it takes effect. If you keep
using our services after that, it means you accept the changes
CHANGES TO THIS PRIVACY POLICY
We may make changes in our Privacy Policy from time to time. If we decide to
change our Privacy Policy, we will post those changes on this page so that you
can always access the latest Privacy Policy.
BASICALLY
We sometimes update this policy. If we do, we will post the new version here so
you can always see the latest rules.
CONTACTING US
We want you to be in control of how your personal data is used by us. You can
do this in the following ways:
• You can ask us for a copy of the personal data we hold about you.
• You can inform us of any changes to your personal data, or you can ask
us to correct any of the personal data we hold about you.
• In certain situations, you can ask us to erase, block, or restrict the
processing of the personal data we hold about you, or object to particular
ways in which we are using your personal data; and,
• In certain situations, you can also ask us to send the personal data you
have given us to a third party. Where we use your personal data on the basis of your consent, you are entitled
to withdraw that consent at any time subject to applicable law. Moreover,
where we process your personal data based on legitimate interest, you have
the right to object at any time to that use of your personal data subject to
applicable law.
We rely on you to ensure that your personal data is complete, accurate and
current. Please inform us of any changes to or inaccuracies of to your personal
data by contacting us immediately.
For any of your requests, questions about this Privacy Policy, or to exercise
your rights, please contact us at:
Email: support@learnflowtv.com
Tel: +31 85 064 4415
If you are based in the EU or UK and are of the opinion that we have not
complied with data protection laws, you have a right to lodge a complaint with
the Data Protection Commission in The Netherlands or with your local
supervisory authority.
BASICALLY
You can contact us to see, fix, delete, or move your data, or to object to how we
use it. You can also withdraw your consent. Please keep your details accurate
and up to date. Use our contact details if you have questions or want to exercise
your rights.
If you are in the EU or UK, you can complain to your local data protection
authority (for example, the ICO in the UK or the Dutch Data Protection
Authority). If you are outside, you can complain to your local regulator where
applicable.