Last updated 7 September 2018
This notice will tell you how ibGenius uses your data; for further queries, you can contact our Data Protection Officer.
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); 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”.
Why does ibGenius need to collect and store personal data?
In order for us to provide you with our services, we need to collect personal data. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose. We value our users’ data protection and privacy rights and we have no interest in collecting data beyond what we need to make our services work for you.
If you are going to be contacted by us for marketing purposes, we will not rely solely on this notice, but will always seek an additional confirmation from you that it’s OK to do that.
Will ibGenius share my personal data with anyone else?
No, we are not sharing your personal data without your explicit consent.
How will ibGenius use the personal data it collects about me?
ibGenius will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. We maintain a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed. We are required to retain certain information in accordance with the Law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Can I find out the personal data that the organization holds about me?
At your request, we can confirm what information we hold about you and how it is processed. If ibGenius does hold personal data about you, you can request the following information:
· Identity and the contact details of the person or organization that has determined how and why to process your data.
· Contact details of our data protection officer in the EU, where applicable.
· The purpose of the processing as well as the legal basis for processing.
· If the processing is based on the legitimate interests of ibGenius or a third party, information about those interests.
· The categories of personal data collected, stored and processed.
· Recipient(s) or categories of recipients that the data is/will be disclosed to.
· If we intend to transfer the personal data to a third country or international organization, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.
· How long the data will be stored.
· Details of your rights to correct, erase, restrict or object to such processing.
· Information about your right to withdraw consent at any time.
· How to lodge a complaint with the supervisory authority.
· Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
· The source of personal data if it wasn’t collected directly from you.
· Any details and information on automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
We accept a request made through an ibGenius.com account while the person making the request is logged in.
All data subjects whose personal data is collected, in line with the requirements of the GDPR.
All data subjects whose personal data is collected, in line with the requirements of the GDPR and we, are the Data Controller for all the data collected.
3. Privacy notice
· 3.1 Who are we?
ibGenius.com is an online platform owned by Human Breeze OÜ, Sepapaja 6, Tallinn 15551, Estonia, Registry code: 14603311, which allows educators, of any kind, to use a private space online, filled with courses and activities, all optimized for collaborative learning.
Our legal basis for processing for personal data:
· Article 6.1(a), GDPR, Consent
· Article 6.1(b), GDPR, Contract
· Article 6.1(f), GDPR, Legitimate Interest
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Agreement with this Privacy Notice and its accompanying Terms and Conditions (as applicable) (and any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.
ibGenius will not pass on your personal data to third parties without your consent. We use cloud services hosted in the EU region (France & Germany).
3.4 Retention period
ibGenius will process different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. For further details on the retention period for any particular type of data, please contact
3.5 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
· Right of access – you have the right to request a copy of the information that we hold about you.
· Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
· Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
· Right to the restriction of processing – where certain conditions apply to have a right to restrict the processing.
· Right of portability – you have the right to have the data we hold about you transferred to another organization.
· Right to object – you have the right to object to certain types of processing such as direct marketing.
· Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
· Right to judicial review: in the event that ibGenius.com refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
In the event that you wish to make a complaint about how your personal data is being processed by ibGenius.com (or third parties as described in 3.3 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority.