ALGORITHMICS GLOBAL FZE 

PRIVACY POLICY 

This is the privacy policy of ALGORITHMICS GLOBAL FZE. 

By using our platform, websites, services, products, software ("Services"), you  understand and agree to the collection and use of your and your child's  information in accordance with this privacy policy. Our privacy policy applies to all  visitors, users, clients, and other natural persons who access our Services ("you" or  "your") provided we execute the function of the data controller (joint data  controller) with respect to your and/or your child's personal data. 

PLEASE READ THIS POLICY ATTENTIVELY. 

1. WHO WE ARE 

IN SHORT: We are a group of companies developing an interactive platform for  children whose parents are interested in their children receiving after-school  programming/mathematics classes. Customers get access to its functionality  directly. We obtain and process personal data regarding our clients in  accordance with applicable legislation. 

We, at Algorithmics Global FZE, have developed an interactive platform for  children whose parents are interested in their children receiving after-school  programming/mathematics classes ("Platform"). We provide the Services to  Customers directly, we administer the Platform. 

We therefore mainly obtain and process the following personal data of our clients:  when they provide us directly with (1) their personal data as well as with (2) the  personal data of their children.  

This privacy policy explains how we collect, use, share and protect information in  relation to our Services. Our Services, other than the Platform and contact forms of  our websites, are not designed to target data subjects specifically. Even if any  personal data processing of data subjects takes place, this happens inadvertently  or incidentally.

2. HOW TO CONTACT US 

You may contact Algorithmics Global FZE regarding data processing issues using  the following contact details: [email protected]. 

3. WHAT INFORMATION WE COLLECT 

IN SHORT: We collect personal data that you provide us with such as your and  your child's name, age, country, contact information. We get some personal  data when you and (or) your child use our Services. We collect some personal  data automatically. 

(a) What data we collect 

● Data you disclose to us 

● Data we get when and (or) after you use the Services  

When you contact us with the purpose to discuss our after-school  programming/mathematics classes for children, we get access to the following  personal data: 

● your name 

● your location (country and address) 

● your contact phone number 

● your contact e-mail address 

● your date of birth and your age 

● your passport details 

● your legal basis for exercising parental rights with respect to your child ● your child's name 

● your child's gender

● your child's age 

● your child's contact phone number 

● your child's contact e-mail address 

● your child's individual progress with the Services  

● other information with respect to you and/or your child that we receive from  you  

When you enter into agreement with us, we additionally get access to the  following data with respect to you and/or your child: 

● your child's individual progress with the Services  

● pages you or your child viewed 

● the features you or your child use 

● error reports 

● links you or your child click on to leave or interact with our Platform ● other applications your child uses on their device 

● video and sound recordings of the lessons which we record for quality control  purposes 

● other information with respect to you and/or your child that we receive from  you 

After you enter into an agreement with us, we may get in contact with you directly  in a limited number of cases and receive the following data with respect to you  and/or your child: 

● your and your child's feedback with respect to Platform

● your and your child's feedback with respect to services that we provide or have  provided to you, including your impression as to the quality of these Services 

● your and your child's feedback as to our staff compliance with our standards  and policies 

(c) What data we collect automatically 

● Internet Protocol (IP) address when you or your child log into the Services and  respective log information and error messages 

● browser type that you or your child use when you access our websites 

● type of device (personal computer/notebook, mobile device), respective unique  device identifiers, such as device Media Access Control (MAC) address, precise  location data, device motion data, or both, if you or your child grant permission to  do so in your device settings 

● time of access to our websites 

(d) What data we receive from cookies 

We will also receive information from cookies. We have special policy for cookies  which can also be found at our web-page. 

(e) What data we have to have 

We noted above that we administer the Platform and therefore we get access to  all information that we input in it. It is impossible to restrict us from getting access  to this information. You should not enter into agreement with us if you don't want  that we get access to your and your child's data. 

4. HOW WE USE YOUR INFORMATION 

IN SHORT: We use your and/or your child's personal data for a variety of  business purposes. Below we explain how and for which purpose we use that  information.

If you are a person exercising parental rights with respect to a child – we indicate  the specific legal basis of processing grounds we rely on next to each purpose  listed below: 

Identify you and your child. We will use information to get understanding of a  person who entered into agreement with us and of a person who uses the Platform  and consumes our Services. We use this information based on your consent. 

Contact with you and your child. We will use information to communicate with  you and your child; to request feedback regarding our Platform, our services; to  answer your requests; to provide you with any support and assistance that you or  your child may need. We need this information for our legitimate business interests  and based on your consent. 

Provide you and your child with personalized service. We will use this  information to ensure that you receive from us the Services that you have accessed  or requested or the Services that are the most suitable for your child; to personalize  your and their experience; to make statistical analysis (including with the use of  special web instruments, such as Google.Analytics); to ensure that we propose you  the services that are the most suitable for your child; to provide technical support  to you and your child. We need this information for our legitimate business  interests and based on your consent. 

Keep the results of your child's individual progress with our Services. We will  use information to ensure that our staff provides you and your child with regular  update of the progress your child has with the Services; to ensure that our staff  takes steps to identify areas for their further improvement; to ensure that our staff  provides you with a tailored feedback; to make statistical analysis (including with  the use of special web instruments, such as Google.Analytics). We need this  information for our legitimate business interests and based on your consent. 

Improve our Platform and the quality of our Services. We will use information to  improve, test, and monitor the effectiveness of our Platform and improve the  quality of our Services; to develop new services and features that we may propose  to you and other clients; to make statistical analysis (including with the use of 

special web instruments, such as Google.Analytics); to monitor metrics such as  total number of visitors, traffic, and demographic patterns; to protect and improve  the security and safety of our Platform, you, your child and other customers,  Algorithmics Global FZE, our business partners, and others. We need this  information for our legitimate business interests and based on your consent. 

Other business reasons. We will use this information to enforce our terms,  conditions and policies, to respond to legal requests and prevent harm. We may  also use your information for other business purposes, such as data analysis,  identifying usage trends, determining the effectiveness of our promotional  campaigns and to evaluate and improve our marketing efforts. We need this  information for our legitimate business interests and based on your consent. 

Your and/or your child's personal data will not be used for any automated decision making, including profiling. We do not sell, trade or otherwise transfer user's  personal data to any third parties for commercial purposes. 

5. DO WE SHARE YOUR INFORMATION WITH ANYONE 

IN SHORT: Yes, but we only do this to comply with laws, to protect your rights,  or to fulfill business obligations. 

There are several situations when we can share your and/or your child's personal  data, namely: 

Compliance. We may disclose your and/or your child's personal data where we are  legally required to do so in order to comply with applicable law, governmental  requests, a judicial proceeding, court order, or legal process, such as in response to  a court order or a subpoena (including in response to public authorities to meet  national security or law enforcement requirements). 

Vital Interests and Legal Rights. We may disclose your and/or your child's  personal data where we believe it is necessary to enforce, remedy, or apply our  terms of service and other agreements; for debt collection; to investigate, prevent,  or take action regarding potential violations of our policies, suspected fraud,  situations involving potential threats to the rights, property or safety of any 

person/entity (including Algorithmics Global FZE, you or your child) and illegal  activities, or as evidence in litigation in which we are involved. 

Third-Party Service Providers. We may share your and/or your child's personal  data with third-party vendors, service providers, advertising companies,  contractors, agents or other business partners who perform services for us or on  our behalf and require access to such information to do that work and only to the  extent they need such info to do that work. This information may be used to,  among other things, analyze and track data, determine the popularity of certain  content and better understand online activity, arrange for joint sales, promotions,  and events, enable us to operate our business or to offer you certain products,  services or promotions. Some of those third-party service providers may use  information about your or your child's visits to our websites that are contained in  web cookies and other tracking technologies in order to provide advertisements  about goods and services of interest to you. 

Unless described in this policy, we do not share, sell, rent or trade any of your and/or  your child's personal data with third parties for their promotional purposes. 

Business Transfers. We may share or transfer your and/or your child's personal  data If we are involved with a merger, asset sale, financing, liquidation, bankruptcy,  or the acquisition of all or part of our business to another company. In such a case  we may need to share information with that company and its advisors. 

Affiliates. We may share your information within Algorithmics Global FZE and with  our affiliates, in which case we will require them to honor this privacy policy.  Affiliates include our parent company and any subsidiaries, joint venture partners  or other companies that we control or that are under common control with us. 

All credit/debit cards' details and personally identifiable information will NOT be  stored, sold, shared, rented or leased to any third parties.  

http://algonova.id.tilda.ws/ will not pass any debit/credit card details to third parties. http://algonova.id.tilda.ws/ takes appropriate steps to ensure data privacy and security  including through various hardware and software methodologies. However,  http://algonova.id.tilda.ws/ cannot guarantee the security of any information that is  disclosed online. 

The http://algonova.id.tilda.ws/ is not responsible for the privacy policies of websites to  which it links. If you provide any information to such third parties different rules  regarding the collection and use of your personal information may apply. You  should contact these entities directly if you have any questions about their use of  the information that they collect. 

6. HOW, WHERE AND FOR HOW LONG WE STORE PERSONAL DATA 

IN SHORT: We keep your and your child's data to the extent we need to fulfill the purposes outlined in this policy unless the law requires otherwise. We aim  to protect your and your child's data with the use of a system of organizational  and technical security measures. 

Algorithmics Global FZE does not retain your and/or your child's personal data any  longer than it is required for attaining the purposes for which it was collected. Your  and/or your child's personal data will be deleted or blocked as soon as the purpose  for its storage ceases to apply, provided the deletion of the same is not in breach of  any statutory storage obligations. 

If you are a person exercising parental rights with respect to a child, your and/or  your child's personal data will be deleted once we delete it from the Platform. If this  happens, we will also delete any other information related to you or your child's  respective personal data that we obtained directly within thirty ('30') calendar days. 

Please draw your attention that the advantage of our Platform is that you can  always see your child's progress with services you obtained from us irrespective of  time elapsed from the completion of respective service. We will therefore store  your and/or your child's personal data to the extent we must satisfy your potential  request to see the child's progress with our Services. 

We will also continue keeping your and/or your child's personal data to the extent  necessary for either of the following purposes:

● to send you newsletter, marketing and promotional communications (this  you can change at any time) 

● for legal and regulatory compliance purposes 

● for general Services' improvement purposes 

We will permanently delete or de-identify the above information in accordance  with our standard data retention practices once all the above purposes cease to be  applicable. 

We will also permanently delete or de-identify your and/or your child's personal  data once you specifically ask us to delete it. 

It may happen that we are unable to fully delete or de-identify your information  due to technical or other operational reasons (for example where information has  been archived and stored in backup systems). Where this is the case, we will take  reasonable measures to securely isolate information from any further processing  and store it until such time as we are able to delete or de-identify it. 

Algorithmics Global FZE has taken appropriate technical and organizational  measures by using the latest technologies to protect your and/or your child's  personal data against loss or unlawful processing but there cannot be 100%  guarantee that would safeguard your and/or your child's personal data a from  unpermitted disclosure or leakage. 

While we will do all reasonable effort to protect your and/or your child's personal  data, the Internet itself is not a secure means of transmission. Your internet  connection is at your own risk. This is your responsibility that you and your child  access to Services with the use of a secure Internet connection. You are responsible  for maintaining the secrecy of your unique password and account information, and  for controlling access to e-mails between you and Algorithmics Global FZE, at all  times. 

7. WHAT RIGHTS YOU HAVE 

IN SHORT: You have certain rights with respect to your and/or your child's  personal data that we collect and process.

You have a variety of rights granted to you pursuant to applicable legislation. Below  we outline the main of them in brief albeit there are others that we did not list.  Should you need more detailed guidance, please contact us, our representative or  independent legal specialist on your rights. 

Right of consent withdrawal. You have the right to withdraw from us your  consent to process your and/or your child's personal data at any time. The  withdrawal of consent shall not affect the lawfulness of processing based on  consent before its withdrawal. For more details on this right please read applicable  legislation. 

Right of access. You have the right to obtain from us confirmation as to whether  your and/or your child's personal data are being processed, and, where that is the  case, access to that personal data, the information concerning how we process it  and some other information. For more details on this right please read applicable  legislation. 

Right to rectification. You have the right to obtain from us the rectification of  inaccurate your and/or your child's personal data. You also have the right to have  incomplete personal data completed. For more details on this right please read  applicable legislation. 

Right to erasure ('right to be forgotten'). You have the right to obtain from us the  erasure of your and/or your child's personal data, and we will erase that personal  data without undue delay. For more details on this right please read applicable  legislation. 

Right to restriction of processing. You have the right to ask us to restrict  processing your and/or your child's personal data. For more details on this right  please read applicable legislation. 

Right to object. You have the right to object on grounds relating to your particular  situation to processing of your and/or your child's personal data and we will no  longer process that personal data unless we are able to demonstrate compelling  legitimate grounds for such processing. For more details on this right please read  applicable legislation.

Right to data portability. You have the right to receive from us your and/or your  child's personal data which you have provided to us in a structured, commonly  used and machine-readable format and have the right to transmit those data to  another controller. For more details on this right please read applicable legislation. 

Right to lodge a complaint. You have the right to lodge a complaint with a  supervisory authority. For more details on this right please read applicable  legislation. 

You can always manage the privacy of your and/or your child's personal data by  updating your privacy settings, by managing marketing and promotional  communications from us or changing your browser settings to opt-out of cookies  in your browser settings (if you however disallow some or all of the cookies, the  Services may not work). 

We respond to all requests we receive from individuals in Indonesia that are using  the Services directed to Indonesia wishing to exercise their data protection rights  in accordance with applicable data protection laws. 

To file a request or act on one of your rights, please contact us at the contact details  provided above in section How to Contact Us. 

8. DO WE PROCESS YOUR PERSONAL DATA OUTSIDE INDONESIA 

IN SHORT: We store your and/or your child's personal data in Finland and  process it in INDONESIA and UAE. We will ensure an adequate level of  protection for your and your child's rights and freedoms. 

We store your and/or your child's personal data on our servers located in Finland  and Western Asia.  

Since Algorithmics Global FZE is a UAE company, we will process your and/or your  child's personal data in UAE. We are committed to ensuring an adequate level of  protection for your rights and freedoms. 

We are the controllers of your and/or your child's personal data. 

9. HOW WE ARE CONNECTED WITH THIRD-PARTY APPLICATIONS, WEBSITES  AND SERVICES 

IN SHORT: We are generally not connected. If you go from your webpage to  their applications, websites and services, this policy does not apply, and you  are covered by their policies. Similarly, their policies do not work with our  Services and you should carefully read our policy. 

We are not responsible for the practices employed by any applications, websites or  services linked to or from our Service, including the information or content  contained within them. 

You need to remember that when you use a link to go from our Service to another  application, website or service, our privacy policy does not apply to those third party applications, websites or services. Your browsing and interaction on any  third-party application, website or service, including those that have a link on our  Services, are subject to that third party's own rules and policies. 

10. HOW DO WE SAFEGUARD CHILDREN'S PRIVACY 

IN SHORT: We do not intentionally collect data directly from children under 18  years of age without the permission of a person exercising parental rights with  respect to a child. 

If you are a person exercising parental rights with respect to a child, please draw  your attention to the following. 

Our services are primarily consumed by children and we therefore need some  personal data from them even if they are under 18. However, we aim at receiving  information regarding children under 18 from their parent or guardian or from  children but with parents or guardians' consent. 

We never knowingly enter in contract directly with a child and always seek for a  person exercising parental rights with respect to them with the purpose that this  person read and understood this policy and, further, contract with us, if they decide  so.

If you are a parent or a guardian and you are aware that your child has provided us  with their personal data without you having knowledge of that, please contact us.  If we become aware that we have collected personal data from a child under age  18 without verification of parental consent, we will take steps to permanently  remove that information from our servers. 

11. WILL WE CHANGE THIS PRIVACY POLICY 

IN SHORT: Yes, we will. We will always keep an updated version of our privacy  policy on our webpage http://algonova.id.tilda.ws/ so you can always read it. 

We will continually review our privacy policy to ensure that it accurately reflects the  applicable legislation, our processing activities and where we process the personal  data for a new purpose which was not indicated in the initial policy, then we will  provide a notice of policy amendment to cover this. 

We reserve the right to make changes or updates at any time. We will notify you of  any changes by posting the new privacy policy on http://algonova.id.tilda.ws/. We  recommend that you review this privacy policy periodically. If we make material  changes to the way we process your personal data, we will provide you notice and  if required by applicable data protection laws seek your consent to those material  changes. 

Amendments to this privacy policy are effective only when they are posted on the  link that we mentioned above.