PRIVACY POLICY
Last update: 12 January 2023
This privacy policy explains to you how we collect, use, and disclose your personal data when you use our website. It also informs you about the choices that you have with respect to your personal data.
Please read the privacy policy carefully.
In this section, we provide you with general information about us and this website.
1.1 About. This privacy policy (the “Privacy Policy”) explains how we collect personal data from individual users (“you” and “your”) through the website https://www.wns-academy.com (the “Website”) and how we use such data. The Website offers courses in the field of embroidery and hosts a virtual community for persons interested in embroidery.
1.2 Data controller. The Website is owned and operated by Boris Zhelezniak having an address at Yitskhak Shalev 6/1, Jerusalem, Israel, 9641327 (“we,” “us,” and “our”). We act as a data controller with regard to the personal data that you submit through the Website.
1.3 Third-party websites. The Privacy Policy does not cover any third-party websites, applications or software that integrate with the Website. We are not responsible for the privacy policies of websites to which the Website links. If you provide any information to such third parties different rules regarding the collection and use of your personal data may apply. You should contact these entities directly if you have any questions about their use of the data that they collect.
1.4 Children. The Website is not intended for use by persons under the age of 18. We do not knowingly collect personal data belonging to persons younger than 18. If you become aware that such a person has provided us with his or her personal data and you are a parent or a legal guardian of that person, please contact us immediately and we will remove the child’s personal data from our systems.
1.5 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.
1.6 Amendments. This Privacy Policy can be changed or updated occasionally. Therefore, you are encouraged to frequently visit this page to be updated about the changes. Such modifications will be effective on the day they are posted. The amended version of the Privacy Policy will be posted on this page and, if we have your email address, we will send you a notice about all the changes implemented by us. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.
In this section, we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use the Website, and how we communicate with you.
2.1 Sources of personal data. We obtain your personal data from the following categories of sources:
- Directly from you. For example, if you register your user account or contact us;
- Directly or indirectly through your activity on the Website. When you use the Website, we automatically collect technical information about your visits by means of cookies and analytics services; and
- From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a legal basis for disclosing your personal data to us (for example, for analytics purposes).
2.2 Collection of personal data. We comply with data minimisation principles. This means that we collect only a minimal amount of personal data that is necessary for your use of the Website. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. We do not repurpose your personal data. This means that we do not use it for any purposes that are different from the purposes for which your personal data was provided. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.
- Your Membership. When you purchase a membership plan on the Website, we collect your full name and email address. When you make a payment, we ask you to login to your PayPal account by providing your PayPal credentials. We use this information to process your orders, grant you access to the Embroidery Academy, register and maintain your profile, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate interests’ (i.e., operate, analyze, grow, protect, and administer the Website). We will store your account data until you delete your account. In certain cases, we may be required by law to keep your data longer (for example, for accounting record keeping purposes), in which case we will delete your personal data as soon as the required time period expires.
- Your profile. If you decide to update your profile on the Website, you can do so by submitting your avatar and social media information. We use such data to update and feature your profile to the other members of our community. The legal basis on which we rely when processing such personal data is ‘your consent,’ as such data is optional. We will keep such data until you update or delete your profile.
- When you contact us, we collect your name, email address, and any information that you decide to include in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to grow and promote the Website) and ‘your consent’ (for personal data that you disclose at your sole discretion). We will store this data until you stop communicating with us.
- When you subscribe for our newsletter, we collect your email address. We use it to deliver you our newsletter. The legal basis on which we rely is ‘your consent’. We will store your email address until you unsubscribe from our newsletter as explained in section 2.10.
- Your content. When you post any content on the Website (for example, posts, videos, photos of your works and crafts, and links), such content may contain personal data that you decide to provide. Please note that the provision of personal data in this context is at your sole discretion. Therefore, we ask you to exercise due diligence when disclosing your or other person’s personal data. If your content features any personal data, we will process it on the ’your consent’ basis and keep it as long as your user account is active, unless you decide to delete the content earlier.
2.3 Cookies. When you browse the Website, we collect your cookie-related data and use other tracking technologies as described in our Cookie Policy.
2.4 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.
2.5 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use certain parts of the Website (e.g., purchase your membership plan), receive the requested information, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.
2.6 Collection of analytics data. When you browse the Website, we collect certain technical analytics data collected from you. Such data includes the following information:
- URL addresses from which you access the Website;
- Device type;
- Operating system;
- Interactions per visit;
- Exit pages;
- Bounce rates;
- Conversion rates;
- Approximate location (eg., country, city, or state); and
- Your other online behavior.
2.7 Purposes of analytics data. We use your analytics data to analyze what kind of users access and use the Website, measure your engagement with the Website, see which parts of the Website are interesting to you, develop new features of the Website and our content, and investigate and prevent security issues and abuse. In most cases, such analytics data is non-personal and it does not allow us to identify you as a natural person. However, your IP address collected by our analytics service providers Google Analytics and Kajabi may be considered personal data and we will make sure that we have the necessary legal basis for processing such data. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyze, improve, and protect the Website) and ‘your consent’ bases.
2.8 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).
2.9 Aggregate and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregate data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.
2.10 Newsletters. When you subscribe for our newsletter on the Website or purchase your membership plan, we will inform you about our new content, products, services, and special offers. The legal bases on which we rely when sending our newsletters are ‘pursuing our legitimate business interests’ (i.e., promoting the Website) and ‘your consent’ (if you subscribe for our newsletter). You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters or by contacting us directly.
2.11 Transactional notices. If we have your email address and it is necessary to do so, we may send you important informational messages, such as order confirmations and updates, requests for more information, and other technical or administrative emails. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.
In this section, we explain for how long we keep your data in our systems and how we delete it.
3.1 Storage of personal data. We and our data processors store your personal data only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to update or delete your personal data, whichever comes first. For more details about the period for which each type of personal data is stored, please refer to section 2.2. After your personal data is no longer necessary for its purposes and there is no other legal basis for storing it, we will immediately securely delete your personal data from our systems. We do not store any personal data longer than strictly necessary.
3.2 Storage of non-personal data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include storing non-personal data for the period of time needed for us to examine our activities, fulfil our contractual obligations, pursue our legitimate interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
3.3 Storage as required by law. In very seldom cases, we may be obliged by law to store your personal data for a certain period of time. If such a requirement exists, we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.
In this section, you can find information about third parties that may have access to your personal data.
4.1 Disclosure to data processors. We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, payment processing, and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations when it is required for the following purposes:
- Ensuring the proper operation of the Website;
- Ensuring the delivery of the products and services that you purchase;
- Responding to your enquiries;
- Pursuing our legitimate interests like record keeping and product development;
- Enforcing our rights, preventing fraud, and security purposes;
- Carrying out our contractual obligations;
- Law enforcement purposes; or
- If you provide your prior consent to such a disclosure.
4.2 List of data processors. We choose our data processors carefully and make sure that they ensure an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that will have access to your personal data are:
- Our web hosting and mailing service provider Kajabi located in the United States;
- Our payment service provider PayPal located in the United States;
- Our marketing service provider Meta (Facebook Ads) located in the United States;
- Our analytics service providers Google Analytics and Kajabi located in the United States;
- Our email service provider Google (Gmail) located in the United States; and
- Our independent contractors and consultants.
4.3 International transfers. Some of our data processors may be based outside the country where you reside. For example, if you reside in a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved Standard Contractual Clauses).
4.4 Disclosure of non-personal data. Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving the Website, responding to lawful requests from public authorities or developing new products and services.
4.5 Legal requests. If requested by a public authority, we will disclose information about the users of the Website to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
Here you can find information on how we protect your data against breaches.
5.1 Security measures. We implement technical and organizational information security measures that protect your personal data from loss, misuse, unauthorized access and disclosure. The security measures taken by us include proper authentication, secured networks, strong passwords, limited access to your personal data by our staff, anonymisation of personal data (when possible), and carefully selected data processors.
5.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights.
6.1 The list of your rights. You have the right to control how we process your personal data. Subject to any exemptions provided by law, you have the following rights:
- Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
- Right to rectification: you can rectify inaccurate personal data that we hold about you;
- Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
- Right to restriction: you can ask us to restrict the processing of your personal data;
- Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
- Right to object: you can ask us to stop processing your personal data;
- Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
- Right to complaint: you can submit your complaint regarding our processing of your personal data.
6.2 How to exercise your rights? If you would like to exercise any of your legitimate rights, please contact us by using our contact details available at the end of the Privacy Policy and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.
6.3 Complaints. If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
If you have any questions about this Privacy Policy, your rights, or our data protection practices, please contact us by using the following contact details:
Email: [email protected]
Address: Podbielskiallee 44, 14195, Berlin
