Privacy Policy

Effective starting: September 15, 2021.

This Privacy Policy informs you of our policies and procedures regarding the collection, use, and disclosure of personal information we receive from visitors and registered users of KSRA.eu (this “Site”). This Privacy Policy applies only to information that you provide to us through this Site and explains in plain language what we do with that information, how we share it, and how we handle the content you place. It also explains your rights and the choices available to you regarding our use of your personal information and how you can access and update this information.

Our Privacy Policy may be updated from time to time, and we will notify you of any material changes by posting the new Privacy Policy on the Site at the Privacy policy and revising the “Effective Starting” date at the top of this policy.  We encourage you to review our Privacy Policy whenever you use this “Site” to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this Privacy Policy, you will need to stop using this “Site” and deactivate your account(s), as outlined below.

This Privacy Policy applies to the information that we obtain through your use of “Site” via a “Device” or when you otherwise interact with KSRA. A “Device” is any computer used to access the “Site”, including without limitation a desktop, laptop, mobile phone, tablet, or other consumers electronic device. “Site” includes the KSRALMS website and LMS service but does not include any other own or third-party products or services for which a separate privacy policy is provided. These are third-party products or services that you may choose to integrate with KSRA services. You should always review the policies of third-party products and services to make sure you are comfortable with the ways in which they collect and use your information.

By accessing and using this Site, you confirm that you have read and fully understood this Privacy Policy, that you agree to the collection and the usage of your own and others’ personal information in accordance with the Privacy Policy and that you have the authority to provide us with all information submitted by you via the Site, including but not limited to personal information of third parties. By registering for or using KSRA Services and accepting the Terms of Service you consent to the collection, transfer, processing, storage, disclosure, and other uses described in this Privacy Policy.

1. Who we are

KSRA research association of Empowerment is a global non-profit organization committed to bringing empowerment through education by utilizing innovative mobile technology and educational research from experts and scientists. KSRA research association emerged in 2012 as a catalytic force to reach the hard-to-reach populations worldwide through mobile learning.

The KSRA research association team partners with local under-served communities around the world to improve the access to and quality of knowledge based on education, amplify and augment learning programs where they exist, and create new opportunities for e-learning where traditional education systems are lacking or non-existent

Our website address is https://ksra.eu.

2. Collection: The Personally Identifiable Information We Collect

Visitors and Users: In the course of using this Site, you may provide us with personally identifiable information. This refers to information about you that can be used to contact or identify you, and information on your use of and activities at our Site that may be connected with you (“Personal Information”). Personal Information that we collect may include but is not limited to, your name and email address. When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website. This information may include but is not limited to, your Internet Protocol address, browser type, the web page you were visiting before you came to our Site, and information you search for on our Site. Like many websites, we may also use “cookies” to collect information. A cookie is a small data file stored by your browser on your Device’s hard disk for record-keeping purposes. We use “session ID cookies” in order to support login and main service functionality. We may also store cookies of third-party providers. In particular, Google stores a Google Analytics cookie in order to be able to differentiate between users and be able to show us how many times people visit the website on average (not individually) and information on what pages they’ve seen, how long the duration was, and so on; we do not identify who the visitor was, or what is his KSRA account (if any). We also use Google AdWords and Facebook Pixel cookies for running advertising campaigns over audiences that may be interested in our services; our ads will only start working when the audience is big enough so no third party can use this information to personally identify the users. Epignosis does not collect or store data from third-party cookies. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of our services.

In some cases, another User (such as an administrator) may create an account on your behalf and may provide your information, including Personal Information (most commonly when your company requests that you use our service). We collect Information under the direction of our Customers and often have no direct relationship with the individuals whose Personal Information we process. If you are an employee of one of our Customers and would no longer like us to process your information, please contact your employer and us at the contact information below.

Customers: In addition to the data we collect about all users, we also collect data that are required for your contract with us, such as your company affiliation, invoicing data, and also service usage data that prove that the service is used in accordance with your subscription terms. We also collect service usage data in aggregate form (i.e. demographics) to improve our service. We may also acquire additional data through our Customers’ support requests to the extent this is required for us to resolve a technical issue or respond to a request or complaint. When you register for the service, we collect information about your industry and your position in the company through Clearbit, to adjust the service to the needs of your industry and make KSRA more functional for your industry. You can see Clearbit’s privacy policy by clicking here. We also collect certain information about Customers’ use of service (this applies only to account owners and not learners or instructors) to email to our Customers newsletters, announcements regarding KSRA and our products, or marketing material. We use marketing automation software, Intercom, and/or Marketo to achieve this. You can see Intercom’s here and Marketo’s privacy policy here. If you are a Customer and no longer wish to receive such emails you can remove yourself from the recipient’s list at any time by selecting the “unsubscribe” link provided within the e-mail footer. Occasionally and for a limited amount of time (typically a week) we use Hotjar in order to better understand our Customers’ (this applies only to account owners and not learners or instructors) needs and to optimize this service and experience. Hotjar uses cookies and other technologies to collect data on our customers’ behavior and their devices, device screen size, device type, browser information, geographic location (country only), preferred language used to display our website. We do not store any data fields’ actual text or Personal Information. Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link. You can opt-out from Hotjar by following this opt-out link.

 

Third-party integrations in KSRA LMS: You may access third-party services via KSRA LMS. These services may include access to content, such as courses or YouTube, Twitter, or Facebook by linking your account in KSRA LMS with an account on the third-party service or by clicking on third-party buttons (such as “like” or “share” buttons), which you have created subject to the third party’s Terms of Use. KSRA LMS may also contain links to third-party websites. Linked websites and third-party services are not under our control, and we are not responsible for their content.

Third-party integrations may also enable access to functionalities, such as videoconferencing (Microsoft Teams, Zoom), helpdesk (Zendesk). Use of these third-party services is optional, and you may have access to them by linking your account in KSRA LMS with an account on the third-party service, which you have created subject to the third party’s Terms of Use.

By using one of the above third-party integrations (offering content or functionality), you agree that such third parties may process the Personal Information you provide them by using their services. To the fullest extent permitted by law, we are not responsible for any third-party service’s use of the Customer’s exported information.

Credit Cards: We do not store your credit card information in our systems. All credit card transactions are processed using secure encryption – the same level of encryption used by leading banks. Card information is transmitted, stored, and processed securely at gateways on a PCI-compliant network.

Content: We collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our “Site”. Such Content includes any Personal Information or other sensitive information that you choose to include (“incidentally-collected Personal Information”). Although Epignosis owns the code, databases, and all rights to the KSRA service, Customers retain ownership, control, and all rights to their records and data which are their property.

Other submissions: We collect other data that you submit to our “Site” or as you participate in any interactive features of the KSRA Services, participate in a survey, contest, activity, or event, request Customer support, or otherwise communicate with us.

Media: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies: If you leave a comment on our site you may opt-in to save your name, email address, and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

3-Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

4-How long do we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profiles. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

5-What rights do you have over your data?

If you have an account on this site or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

6. How We Use, Process, and Retain Personal Information

Personal Information is or may be used for the following purposes:

  • to provide and improve our Site, services, features, and content,
  • to administer your use of our Site,
  • to enable you to enjoy and easily navigate the Site,
  • to better understand your needs and interests,
  • to fulfill requests you may make,
  • to personalize your experience,
  • to provide or offer software updates and product announcements, and
  • to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, including newsletters, marketing, or promotional.

We use the information we obtain by technical means (such as the logging performed by our servers or through the use of cookies) for the above purposes and in order to monitor and analyze the use of the Site and our services, for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, to better tailor it to your needs, to generate and derive useful data and information concerning the interests, characteristics, and website use behavior, and to verify that visitors to the Site meet the criteria required to process their requests.

We collect and process personal data in a transparent manner, to the extent necessary for specified, explicit, and legitimate purposes, and do not process it further in a manner incompatible with those purposes. We take care that the data we collect is accurate and, when necessary, updated. We take all reasonable steps to immediately delete or rectify personal data, if inaccurate. We process data in a way that guarantees their security, including their protection against unauthorized or unlawful processing and accidental loss, destruction or degradation, using appropriate technical or organizational measures. We are ready to prove at any moment how we adhere to the above principles. We take the appropriate technical and organizational measures for the security, confidentiality, integrity, and availability of the data. We expressly declare that these measures ensure that, by definition, personal data are not made accessible without the intervention of the natural person to an indeterminate number of natural persons.

Each domain’s data are retained for as long as the Customer’s paid subscription to the service or free plan lasts. If Customer elects not to renew a Subscription, Customer’s account is downgraded to the free version of the Services. If the Customer has a free version account and does not log into an account for more than 365 days, that account is permanently deleted. We will provide reminder notifications before deleting the Customer’s account.

7. Your Rights

Epignosis respects your rights as a data subject. When Epignosis processes personal data on behalf of and as instructed by its Customers, our Customers are responsible for the data subjects and you should contact the respective Customer to which the content of your service belongs for exercising your rights. In this case, Epignosis does not respond directly to your requests for the exercise of your rights that come to our knowledge, but we inform the Customer without delay and provide all reasonable assistance to satisfy your requests in accordance with the instructions of the Customer. The service has all the necessary features to enable our Customers to protect the rights of the data subjects on their behalf. For example, the service provides the ability to obtain and manage consent and to implement strict and secure password policies as well as to exercise the right to be forgotten.

A synopsis of your rights as a data subject is provided below. You may also refer to the KSRALMS GDPR page for detailed step-by-step instructions on how you can exercise these rights by means of invoking KSRALMS service features.

Transparency, information, and answers to requests: Epignosis adheres to the principle of transparency in processing. For any questions regarding this policy, you may contact us at privacy at KSRA LMS  We will respond without delay and in any case within one month upon receipt of the request.

Access: You have the right to receive from Epignosis confirmation on whether your personal data are processed and in case this happens all required information thereof (processing means, goal, records, etc.).

Rectification: You have the right to require the rectification of inaccurate data relating to you without undue delay, as well as to fill in incomplete data if necessary for processing. If you have an account on our Site you can update your account data through your profile by selecting “My information” from the options menu at the top of the screen.

Erasure: You have the right to ask for the erasure of personal data concerning you without undue delay. Epignosis by means of its designated personnel will erase the data where one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes of the processing, or b) the person requesting the erasure withdraws consent on which the processing is based and there is no other legal ground for the processing; or c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing or the data subject objects to processing for direct marketing; or d) the personal data have to be erased for compliance with a legal obligation. Epignosis will not proceed to the erasure of the personal data if the data must be maintained for compliance with a legal obligation or in cases where the processing is required for the establishment, exercise, or defense of legal claims. If you receive marketing emails, you can remove yourself from the recipient’s list by selecting the “unsubscribe” link within the e-mail.

Restriction of processing: You have the right to request the restriction of processing if the accuracy of personal data is disputed, for that period of time that allows Epignosis to verify the accuracy of personal data or based on any other legitimate reason specified in applicable Data Protection Laws.

Data Portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format as well as the right to request the direct transmission of personal data by Epignosis to another if this is technically feasible.

Right to Object: You may oppose the processing of personal data which takes place without your consent. In this case, Epignosis no longer submits the personal data unless it demonstrates imperative and legitimate reasons for the processing that outweigh the interests, rights, and freedoms of you as a data subject or for the foundation, exercise, or support of legal claims. If you receive promotional emails, you can remove yourself from the recipient’s list by selecting the “unsubscribe” link within the e-mail content. You may also oppose processing at any time by contacting us at the email provided at the end of this Policy.

Complaint to Supervisory Authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of your personal data infringes Data Privacy Laws.

Right to opt-out and right to Non-Discrimination: If you are a California resident, you should be specifically aware that you have the right to direct a business that sells (or may in the future sell) your Personal Information to stop selling your Personal Information and to refrain from doing so in the future. We do not sell your Personal Information to any other party.

If you are a California resident, you should be specifically aware that we will not discriminate against California residents or against any person, if they exercise any of the rights provided in the CCPA, or any applicable privacy law provision. In particular, we will not deny goods or services; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services, or suggest that anybody (including California residents) will receive a different price or rate for goods or services or a different level or quality of goods or services.

8. Security

KSRALMS is very concerned with safeguarding your information. We employ reasonable measures designed to protect your information from unauthorized access.

9. Data Ownership

Although Epignosis owns the code, databases, and all rights to the KSRALMS service, Customers retain ownership, control, and all rights to their records and data which are their property.

10. Data Transfers from the EU and the UK to the United States

The transfers are subject to the latest versions of the appropriate form of the Standard Contractual Clauses.

12. Contacting Us

If you have any questions about this Privacy Policy, please contact us at privacy at KSRALMS