Data privacy

What data do we collect and process?

When you use our Services, we collect the following personal data from you:

  1. Registration/login data: When you register to use our Services, we collect your contact details and other relevant personal data that you provide us with on this occasion. If you authenticate yourself with an existing account (social login), we may receive personal data from these services.

  2. Data collected through Integrated Services: If you decide to grant us access to a third-party integrated service, such as Moodle or Microsoft, we may collect the personal data associated with your Integrated Service account. You may also have the option of sharing additional data (e.g. class or student data) with us through an Integrated Service. If you choose to provide such information, during registration or otherwise, you are giving us permission to use, share, and store it in a manner consistent with this Privacy Policy. You may revoke our access to your account on any Integrated Service at any time by updating the appropriate settings in the account preferences of the respective Integrated Service.

  3. Communication data: We store communication between you and us, such as service-related emails regarding account management, notifications on technical issues, or changes to the Services.

  4. Other personal data: We process other personal data you store on the learning platform of your own accord or that result from your use of the learning platform.

  5. Product analytics: We log information related to your usage of our Services.

  6. When you visit our website, the server automatically logs general technical information such as your IP address or the browser you used. We ask for your consent for the use of cookies, to ensure the functionality of the Website and collect information to improve our services.

Data processing purposes

We may process your data:

  1. to contractually provide you with our Services as per our terms & conditions,

  2. on the basis of your consent (when applicable),

  3. on the basis of our legitimate interests, for example, to guarantee the security of our systems, or with regards to potential legal claims,

  4. to comply with legal obligations.

  5. Product information, newsletters: We may send you mailings and newsletters to inform you about our Services and their developments. You can opt-out of receiving mailings and newsletters at any time.

Third-party integrations

We may engage with third parties and a transfer of your personal data may be necessary to fulfill the contract, to protect our interests, or to comply with legal regulations:

  1. We may engage third parties to perform business-related functions, such as maintaining databases, sending e-mail messages, providing and developing certain functionalities, billing, or marketing. In that case, we will only provide the third party with the data it needs to perform its specific function.

  2. We may disclose collected data if and to the extent necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property or the rights or property of our users (including, without limitation, against liability claims), or (iii) protect the security or integrity of the Services.

  3. We may share your personal information with third parties to whom we transfer our business or parts thereof or with whom we merge.

In the event we would transfer your personal data to third parties outside the European Economic Area, we will conclude standard contractual clauses to comply with the provisions of the applicable data protection laws on international data transfers.

We do not rent or sell your personal data to third parties.

Data security

Our database is stored on certified servers in Switzerland and Germany, which are operated either by us or by an IT service provider commissioned by us.

We protect your personal data in particular by means of the following technical and organizational security measures against unintentional, illegal, or unauthorized manipulation, deletion, modification, access, disclosure, use, or loss:

  1. connections between app and server and to the database are encrypted (TLS),

  2. only selected employees have access to the database,

  3. daily backups.

How long is your personal data stored?

We only keep your personal data for as long and to the extent necessary for the purposes described above, or for legal reasons.

Personal data stored in user accounts will be deleted 12 months after the deletion of the corresponding account.

What are your rights in connection with your personal data?

Subject to applicable law, you have the following rights in connection with your personal data:

  1. Right to access your data: you can request a copy of your personal data by email.

  2. Right to rectify data, either directly through your account settings, or by requesting a modification by email.

  3. Right to erasure, by requesting an account deletion by email.

  4. Right to restrict the processing of your data, by asking us to stop or limit the processing by email.

  5. Right to data portability, by asking us to send you your personal data in a structured, machine-readable format and transfer it to another data controller.

To exercise your rights in connection with your personal data, please contact us by e-mail at support@smartest.io.

We will answer your request at the latest within 30 days, but in some cases, we may need to keep part of your personal data due to legal requirements.

Complaints

If you are not satisfied with the way in which we process your personal data, you have the right to complain to the Swiss Federal Data Protection and Information Commissioner or, if the GDPR is applicable, to your supervisory authority.

Please contact us first though at support@smartest.io – we will strive to resolve the issue directly.

Business changes

Should Smartest Learning engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of the company’s assets or stock, or similar transaction, your personal data may be shared or transferred.

Modifications

We may modify this Privacy Policy at any time. New versions will come into effect for you as soon as we have notified you by publishing them on our Website.

Contact

Smartest Learning AG
Technopark
8005 Zurich
Switzerland
support@smartest.io

Last update: 07.07.2022