MLS would like to inform you in this privacy statement about the type, scope and purpose of personal data collection, processing and use upon use of MLs Platforms and sub-domains and of the services offered on such websites (e.g. apps). MLS is trustworthy and the protection of your personal data is very important. This is why MLS would like to show you in a transparent way how and why your data are being used. MLS would like to offer you user-friendly, good, customer oriented and secure services by storing, processing and using personal data. MLS also complies with U.S. laws, including the Family Educational Rights and Privacy Act (“FERPA”), where applicable, which provide privacy protections for personal data.
§ 1 Definitions
“personal data” means any information relating to an identified or identifiable natural person (“data subject” or “you”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
“controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
“third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
§ 2 Name and contact data of the controller
The following party is responsible within the meaning of EU-GDPR and other applicable data protection laws of the European Union and its member states:
Manan Learning Solutions ApS
(“MLS”, “we” or “us”)
Telephone: +45 70 70 76 20
§ 3 Name and contact data of the data protection officer
The data protection officer of the controller for data processing is:
Mr. Shahid Q. Manan
Manan Learning Solutions ApS
(“data protection officer”)
Any person concerned may contact the data protection officer directly at any time to email firstname.lastname@example.org if he/she has any questions or suggestions regarding data protection.
§ 4 Purpose and legal basis of data processing
MLS operates platforms that records online courses for students and professionals in cooperation with experts and makes them available via browser and mobile apps. The services of MLS are generally time and location-independent. Various data relating to your member account are collected, stored, processed and used depending on the extent to which you use the services offered by us.
Collection of general data and information
Specific data transmitted by your browser when visiting MLS Platforms are stored automatically by our servers. The log files created thereby include data like your IP address, the URL and landing page, the time, type and number of requests, data volume transferred, date, time and duration of individual accesses, your browser type as well as other similar information that serve as emergency response in the case of attacks on our IT systems and as protection against license abuse.
The collection and use of the information stored in the log files only serves to correctly deliver the contents of MLS Platforms, for anonymous evaluations for statistical purposes (like analyzing the user behavior), to improve our services and to provide law enforcement authorities information necessary for prosecution in the case of cyber attacks. These data are not used to draw conclusions about a person concerned.
Data and information provided by the user
Monitoring of learning progress
Our system collects data about your personal user behavior, such as your learning progress, viewed videos and answered quiz questions or similar activities in order to provide you with optimal support while learning. These may be viewed depending on the implementation of the administrators of your employer or your university / educational institution. Data regarding your learning progress are not passed on to unauthorized third parties under any circumstances.
Educator’s learning content
Learning content uploaded and created by using services provided by MLS – such as videos, screencasts, quiz questions, documents and similar educational content (“educational content”) – is only available to users within the same organization in which they were created or submitted and to which they have been allocated.
§ 5 Recipient of personal data
Additional processors and third parties are necessary for the delivery of MLS service. These receive, inter alia, personal data. These services and the purposes for which the data are submitted to them are listed in the following paragraphs. Apart from this, only specific employees from MLS have access to personal data when this is required for delivering a service.
§ 6 User account and registration
We store and use data provided by you when subscribing to or using MLS services, such as when opening a member account, for the purpose of performing the services you would like to use according to contract. These data include email address, password, name, title as well as other information (such as age, sex, location, final degree, etc.) that you submit when setting up a member account. If you have submitted on this occasion a high school email address also, it will be used for the sole purpose of verifying if you attend that specific school or educational institute.
§ 7 Payment services
If you want to provide fee-based services on MLS Platforms, you will have to additionally submit bank, credit card or other payment processing data and your address as well as other information during the ordering process. Of course, we will handle all information submitted by you in accordance with legal requirements and within the framework of the collaboration agreed upon. Payment processing data will be forwarded to processors within the framework of the statutory provisions in order to be able to process the payment. We will not store your credit card data. The personal data provided by you and relevant for the payment processing are subject to the security and data protection regulations of the following services:
PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxemburg, Luxemburg (“PayPal”).
Braintree Inc., 222 W Merchandise Mart Plaza, Suite 800, Chicago, IL 60654, USA (“Braintree”).
Stripe Inc., 185 Berry Street, Suite 550, San Francisco, CA 94107, USA (“Stripe”).
Braintree, Stripe and PayPal are PCI DSS certified and therefore meet the most stringent requirements for safe handling and storage of credit card data.
You will find more information about the security of your personal data with regard to credit card payments on https://www.braintreepayments.com/en-dk/features/data-security and https://stripe.com/dk/legal.
§ 8 Cookies
We use so-called cookies on our websites. These are small text information that is stored on your computer. Cookies enable us to speed up the navigation on our website, to adapt it to your needs and interests and to avoid the misuse of our services. Our server may thus identify your computer as soon as you connect to our website, so that you do not have to log in every time you visit our website. We use so-called permanent cookies on our websites. These enable us to preserve and provide your personal settings or displays over a longer period (depending on each service) within the context of the service. Permanent cookies are deleted automatically after a specified duration that may be different for each cookie. You may delete the cookies at any time in the security settings of your browser. You can configure your browser settings according to your wishes and refuse to accept cookies. But please note that you may not be able to use all functions of the website in this case.
§ 9 Web analytics and social plugins
Google Analytics and Google Tag Manager
MLS Platforms use Google Analytics and Google Tag Manager, a web analysis service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics and Google Tag Manager also use so-called “cookies”, text files that are stored on your computer and enable an analysis of your use of our website. The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there.
We have activated IP anonymisation, so that your IP address will be previously shortened by Google within member states of the European Union or in other contractual states to the Agreement on the European Economic Area. Your full IP address will be transferred to a Google server in the USA and shortened there only in exceptional cases. Google will use this information on our behalf in order to evaluate the use of the website, to compile reports on website activities and to provide other services associated with website use and internet us on our behalf.
The IP address transmitted by your browser within the scope of Google Analytics will not be merged with other data from Google.
You may prevent the storage of cookies by setting your browser accordingly; but please note, that you may not be able to use all functions of the website to the full extent in this case. You can also prevent Google to process and collect data generated by the cookie with regard to your use of our website (incl. your IP address) by using the following link to download and install the browser plugin for deactivation: https://tools.google.com/dlpage/gaoptout
You will find more information about the date protection regulation of Google Analytics on: https://support.google.com/analytics/answer/6004245
We use various services in order to make the internet offer more interesting for you. This advertising function enables us to show users who have already visited our website and were interested in our offer, targeted, personalized and interest-related advertisements on other websites, such as in Google Display net. The advertisement is inserted by using cookies that help us analyze the user behavior when visiting our website and may be subsequently used for targeted product recommendations and interest-based advertising. The personal data are not stored and user profiles with personal data are also not created.
The following remarketing services are used on our website:
Google Adwords (“Google Adwords”) from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). You can object to the use of the corresponding cookies in the advertisement manager https://adssettings.google.com/authenticated?hl=en. You will find the data protection regulation of Google here: https://www.google.com/intl/policies/policies/privacy/
Social plugins (Facebook, Google+ and Twitter)
So-called social plugins (“plugins”) of the social networks Facebook, Google+ and of the micro blogging service Twitter are used on our website. These services are provided by the following companies (“providers”): Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”), Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google” or “Google+”) and Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”).
You can find an overview of the plugins from Facebook and their appearance here:
You can find an overview of the plugins from Google and their appearance here:
You can find an overview of the Twitter buttons and their appearance here:
Your browser will establish a direct connection with the servers of Facebook, Google or Twitter when opening a page of our advertising presence that contains such plugins. The respective provider transmits the content of the plugin directly to the browser and integrates it in the page. By integrating the plugin, the providers receive the information that your browser has opened the respective page of our advertising presence, even if you don’t have a profile or are not logged in. This information (including your IP address) is transmitted directly by your browser to a server of the respective provider in the USA and stored there.
If you are logged in on one of the services, the provider may directly associate the visit on our webpage with your profile on Facebook, Google+ or Twitter. If you interact with the plugins, for example by clicking the “Like”, “+1” or “Twitter” button, the corresponding information will also be transmitted directly to a server of the provider and stored there. The information will also be shared with your contacts on the social network or your twitter account.
You will find more information about the purpose and extent of data collection and further processing and use of the data by providers as well as your rights and settings available to protect your privacy in the data protection notice of the providers.
Data protection notice of Facebook: https://www.facebook.com/policy.php
Data protection notice of Google: https://developers.google.com/+/web/buttons-policy
Data protection notice of Twitter: https://twitter.com/en/privacy
If you don’t want Google, Facebook or Twitter to directly associate the data collected via our advertising presence with your profile in the respective service, you will have to log out from the corresponding service before visiting our webpage. You can also completely prevent loading the plugins through add-ons for your browser, such as the script blocker “NoScript” (https://noscript.net/).
MLS Platforms also use services of third-party provider UscreenTV, LLC. 1875 Connecticut Ave, 10th Floor, Washington DC 20007. By using MLs Platforms, you agree to the processing of the data collected by Uscreen.
§ 10 App analytics and push messages
You have the possibility to activate the option “push messages” when you use our apps via a push-capable device. We use push messages in order to help you get started by sending useful tips to your device and informing you about the latest course releases and specific content as well as occasional discount campaigns and similar content based on your learning progress. You can revoke your consent to receive messages at any time by changing your device settings. Push messages are sent via a service of Mixpanel Inc., 405 Howard Street, Floor 2, San Francisco, CA 94105, USA (“Mixpanel”).
We also us an analysis tool from Mixpanel in our apps in order to collect user data from the iOS and Android app and better understand how users interact with their apps. Mixpanel is used to retrace and improve activities within the app, such as the navigation between courses or app logouts. These non-personal data are stored on Mixpanel servers in the USA. You can find further information in the privacy statement of Mixpanel: https://mixpanel.com/privacy/.
§ 11 Newsletter
You have the possibility to subscribe to our newsletter. The submission of your email address is necessary for this purpose. We use MailChimp® , a service provided by The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA, to send our newsletter. After subscription to our newsletter, you will receive an email where you will be asked for confirmation. When registering for the newsletter, we will store your IP address and the date of registration. This storing only serves as proof in the case that a third party misuses an email address and subscribes to the newsletter without the knowledge of the party concerned.
A so-called tracking pixel is used upon opening a newsletter. The following data are stored thereby: email address, newsletter, opening date and time. The links in our newsletters contain tracking information that enables us to determine which links were of interest to you if you have clicked them. The following data are stored in MailChimp via the tracking link: email address, newsletter, link, date and time.
You can revoke your approval to receive newsletters at the email address specified by you at any time for the future by sending an email to email@example.com.
§ 12 Duration during which personal data are stored
The duration of personal data storage is based upon the legal storage period and the personal data are routinely deleted after the expiry of this period or immediately after termination of the membership of MLS or at an earlier date upon request of a person concerned, insofar as the data are not required to fulfill or initiate a contract. The following data are stored beyond termination of contract for so long as they are required for a specific purpose:
offer data: 1 year (after feedback from the client),
contract documents: 10 years,
IP data: 3 years (regular limitation period)
legal matters: 6 years
claims: 10 years
In order to terminate your membership, please contact our customer service by sending an email to firstname.lastname@example.org.
§ 13 Rights of the data subject
You have as person concerned the following rights:
right of access by the data subject
right to rectification or erasure as well as restriction of data processing
right to object to data processing
right to data portability
right of appeal before supervisory authoritie
If you want to exercise any of these rights, please contact our data protection officer or our customer service by sending an email to email@example.com. We reserve the right to charge an appropriate fee on the basis of administrative costs in the case of unusually common requests of individual persons.
§ 14 Transfer of personal data to third parties
We collaborate with specific external service providers in order to process your data, for IT hosting services also. We guarantee that the data are transferred with due regard to the applicable data protection provisions. If these service providers are located in a country outside the EU or EEA, we inform them about these provisions in conjunction with the respective functions. These data are also processed in compliance with the prevailing legal norms.
§ 15 Sweepstakes
Separate conditions apply to the collection and processing of personal data when taking part in sweepstakes, contest or competitions organized by us.
§ 16 Miscellaneous
If a third party registered with us by using your email address, please inform us and we will immediately delete your profile, if this is what you desire.
We reserve the right to update this privacy statement at any time in the course of improving our services and implementing new technologies. We therefore recommend that you reread this privacy statement from time to time.