Current as of 20 Jan 2022
Privacy Policy
Your privacy is important to us at Untitled. We respect your privacy regarding any information we may collect from you across our website.
General
Apex Learning Inc. (““Apex Learning”), wants to offer you the best experience through its service; For this reason, we are interested in taking care of the privacy of our users, making this document (the “Policy“) available to inform about the policies and procedures related to the treatment of information and personal data that it collects from users through the site. Apex Learning’s web and/or virtual platforms (hereinafter jointly, the “Platform“).
Apex Learning is committed to ensuring all data collected is protected across all aspects of our organization, as per the General Data Protection Regulation (GDPR) as it applies in the UK, tailored by the Data Protection Act 2018.
Users who access our services through the Platform, agree to be bound by the provisions of this Policy, accept that their personal information be collected through questionnaires, records, and electronic forms, among others granted and/or virtually required on the Platform, and authorize Apex Learning to use and process all the information provided to Apex Learning. It is worth mentioning that this Policy is an integral part of the Terms and Conditions in (LINK UPDATE)
Apex Learning reserves the right to modify the Privacy Policy, which will be communicated via email with reasonable anticipation of its entry into force.
Definitions
Without prejudice to the terms defined in various sections of this document, the terms used here with the first capital letter and that are not defined differently will have the meaning attributed to them below and may be used in masculine, feminine, or neutral, as well as singular or plural, indistinctly and according to the context:
- Cookie: It is the data file that is stored on the user’s device when the user has access to the site.
- Responsible for Treatment: Natural person or legal entity that collects, stores, conserves, uses, blocks, or deletes personal data of Users on behalf of Apex Learning, by virtue of a legal relationship that binds them with it and defines the scope of performance.
- User and/or Users: That natural person, a natural person with a business, or a legal person who registers on the Platform to acquire the products and/or services offered on the Platform.
- Platform : Includes: (i) the Internet website www.Apex Learning .com and, (ii) the corresponding applications for mobile devices. The Privacy Policy applies only to the information that Users provide us through the Platform.
- External Servers: We use other companies, agents, or contractors to provide external services. For example, payment processing and other payment forms provide customer service and analyze and improve data (including information regarding our users’ interaction with our service).
- Personal Information: Allows to identify and/or make the user identifiable; such as their names, surnames, ID number, telephone number, and email, among others, that Apex Learning deems appropriate to request, in order to be able to provide the services and/or products offered on the Platform appropriately.
- General Information: By itself, it does not allow the user to be identified, but it may be required by Apex Learning to provide its services.
From now on, it will be understood that the expression “Personal Data” will refer to Personal Information and General Information provided by Users.
What information do we collect?
If the user wishes to access the Platform’s services, they must register by completing the registration form with their Personal Information; including their phone number, email address, full name, username, a password.
Likewise, we collect information from the user related to (i) content shared within the Platform, (ii) course data (behavior and use of the product, comments, and projects created), (iii) payment data, and (iv) data about shopping. Apex Learning may request other Personal Data that it deems appropriate at the time.
Without prejudice to the above, for security reasons, Apex Learning does not collect or store: (i) confidential data of the cardholder (such as all credit card numbers or card authentication data), ( ii) data of the instructors, (iii) data about the user’s accounts in other services, unless they are connected to the Apex Learning account.
We use different international gateways to be able to charge for the Courses, which process all this information by accepting the Privacy Policy, you agree to share your information with the payment gateways indicated above. We do not have access to credit card details or information within a PayPal account.
We give the user the option to add more information to their profile. The user can include a profile photo, a brief description, the country and city where he comes from, his date of birth, and a cover image.
What do we use user data for?
Apex Learning will use the information it collects to (i) present the Platform and its contents; (ii) provide and coordinate with the user the information of the services they request; (iii) notify the user of changes to the Platform; (iv) allow the user to participate in interactive functions of the Platform; (v) provide support to the user; (vi) validate the integrity of the information provided; (vii) update and consult contact details and other relevant information; (viii) answer the user’s inquiries and requests; (ix) manage User preferences regarding their accounts, (x) carry out statistical studies necessary to enhance Apex Learning services and improve the User experience; as well as trends and traffic, and keep track of purchases and usage data. (xi) guarantee compliance with the information security protocols; among other purposes related to the service provided by Apex Learning to the user; and (xii) facilitate the technical operation of the services, including troubleshooting, the security of the services, and the prevention of fraud and misuse.
Unless otherwise indicated in this section of our Policy, we will not share your Personal Information with any third party without your authorization, unless it is necessary to execute the contractual relationship and for the updates that may be given on the Platform.
Likewise, the User’s Personal Data will be used, including, but not limited to, in the following cases:
System Administration: We may use User Personal Data for the purposes of administering our systems, assisting in diagnosing problems with servers, monitoring the performance and traffic of our systems, and gathering demographic information.
- Communication and Advertising: We will use Personal Data to periodically send the user to his email address advertisements, and offers and send him advertising about the products offered on the Platform. In case the user expresses his consent to the sending of unsolicited advertising material, he will click on the check box “I expressly accept the sending of advertising and/or commercial material by Apex Learning “, which is located at the end of the Policy. Without prejudice to this, in case you accept the sending of advertising, but after that, you want to withdraw the consent, the user may request that the sending of advertising be omitted through email info@apexlearning.com.
- Service Providers: In case we decide to request the services of third parties in which the User’s Personal Data is involved (for example, security services, payment gateway, data management and storage, call centers, among others), we will transfer the Data User’s personnel that are necessary for the providers to carry out their services, either to national or international service provider companies. In this case, the latter is obliged to maintain the confidentiality of the information they have or could have access to, including their employees or suppliers. It should be noted that Apex Learning will not be responsible for the obligations that correspond to the Service Providers.
- Other types of disclosure : Without prejudice to any provision to the contrary, contained in this Policy, we reserve the right, and the user hereby expressly authorised us, to share their Personal Information or General Information: (1) in response to subpoenas, court orders or legal or administrative processes of any nature, or to establish, protect or exercise our legal rights or defend against lawsuits, administrative proceedings and investigations of any nature; (2) if we believe it is necessary to investigate, prevent or take action regarding potentially illegal activities, fraud, or situations that involve potential threats to the safety of any person or property; (3) if we believe it is necessary to investigate, prevent or take action regarding significant abuse of the Platform’s infrastructure, denial of service attacks, or attempts to compromise the security of the information); and (4) if we were acquired or merged with another entity, and in the cases of corporate reorganisations.
- Surveys: We can send to your email and/or through text messages or any other available means, surveys on the services we provide through the Platform, and/or on any other topic of interest to guarantee the improvement of our services.
By virtue of the aforementioned, Apex Learning transfers Personal Information at the national and international level of the Users for the purposes detailed in this point, for which the Users give their informed, prior and express consent.
Rights of Users
Users may access, rectify, oppose, and cancel their Personal Data (“Arco Rights”), as well as the other rights granted by law, which may be exercised by request addressed to the following email: info@apexlearning.com.
The procedure of Apex Learning before the exercise of the Arco Rights by the user is subordinate to the provisions and terms established by the Normative Framework for the Protection of Personal Data.
Notwithstanding the foregoing, Apex Learning may keep certain information of the user requesting the cancellation, in order to serve as evidence against a possible claim against Apex Learning for responsibilities derived from the processing of said information. The duration of said conservation may not exceed the legal limitation period of said responsibilities.
Treatment by third parties
Whenever Apex Learning entrusts the processing of personal data to a third party or allows third parties access to its data banks for the provision of a specific service (“), Apex Learning will take into account the following specifications:
- Any processing of Personal Data carried out by a third party other than Apex Learning must be regulated in an agreement with the (“Agreement with the “), in which it is expressly established that the treatment of Personal Data will be carried out following the instructions of Apex Learning and under the regulation of the Data Regulatory Framework. Likewise, Apex Learning will establish that only the Personal Data will be processed for the purposes authorized or established in the contract so that the Treatment Manager will not use them for a different purpose, nor will they improperly communicate them to other people.
- The Agreement must stipulate the security measures that the Treatment Manager will be obliged to implement, such as the protection of Personal Data, and the return or destruction of Personal Data, once the order has been completed.
- The Agreement must establish that, in the event of non-compliance by the Treatment Manager, the offender will respond to Apex Learning and the authorities for any unauthorized treatment or use of Personal Data.
- If the Person in Charge of Treatment needs to subcontract with third parties the services that he was obliged to offer, he must have the prior authorization of Apex Learning, and this will only proceed as long as the subcontractor assumes the same obligations as the Person in Charge of Treatment.
- The Agreement must also establish confidentiality obligations regarding the information accessed by the Treatment Manager, keeping said obligations in force even after the term of the contract has expired.
Incorporation of Personal Data in a Data Bank
In accordance with the provisions of the Regulatory Framework for the Protection of Personal Data, Apex Learning informs the Users of the Platform that the User’s Personal Information will be incorporated into the data banks owned by Apex Learning.
The data banks will be stored by means of External Servers, and the data conservation time will be according to the purpose of their storage. Without prejudice to this, Apex Learning is hereby authorized to keep certain information after the fulfillment of the purpose; In order for it to serve as evidence against a possible claim against Apex Learning for responsibilities derived from the treatment of said information.
In that sense, through this Policy, the user gives his express consent for the inclusion of his Personal Information in the aforementioned data banks.
About security measures
Apex Learning guarantees the protection of the User’s Personal Data and avoids its alteration, loss, treatment and/or unauthorized access, taking into account the nature of the stored data and the risks to which they are exposed, all in accordance with the provisions of the Regulatory Framework for the Protection of Personal Data.
Apex Learning employs various security measures to prevent unauthorized access, misuse, or disclosure of technology and processes used in the industry. Notwithstanding this, Apex Learning is not responsible for illegal interceptions or violation of its systems or databases by unauthorized persons, as well as the improper use of the information obtained by those means, or for any illegitimate interference that escapes the control of Apex Learning and that it is not attributable to it.
Apex Learning is not responsible for possible damages that may arise from interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operational functioning of the electronic system, delays or blockages in the use of the Platform, motivated by causes unrelated to Apex Learning.
Likewise, Apex Learning does not assume any responsibility for possible damages, fines, or legal actions that could be caused due to the breach of the obligations of the External Servers hired for the Platform.
Additionally, the Apex Learning Platform may contain links to other websites. However, it does not assume responsibility for the content of the privacy policies and/or practices of other websites. When a User accesses a link that redirects him to another website, he must accept and abide by the privacy policy of the said website.
Cross-border data flow
The servers, providers and/or computers used by Apex Learning to provide its services may be located outside the country or under another government jurisdiction. The user authorizes Apex Learning to transfer, store, and process their Personal Data internationally (“Cross-Border Flow”) in accordance with the provisions established in the Normative Framework for the Protection of Personal Data, for which they express their prior, informed, free consent, express and unequivocal.
On the Veracity of Personal Data
Each user is responsible for the veracity, accuracy, validity, and authenticity of the information provided, and undertakes to keep it duly updated. Notwithstanding the foregoing, the user authorizes Apex Learning, if it considers it pertinent, to verify the veracity of the Personal Data provided, through information obtained from publicly accessible sources or entities specialized in providing said information.
Personal information requested by public authorities
Apex Learning undertakes not to disclose or share the User’s Personal Data, without the User having given due consent to do so, with the exception of requests for information from public authorities in the exercise of their functions and the scope of their powers; by virtue of court orders and/or legal provisions.
Cookies and other information
We use the user’s IP address to identify problems, administer the Platform, and identify patterns of traffic behavior. Cookies or similar technology are also used to be able to offer content according to your interests and to store your password so that the user does not have to enter it again each time he returns to the Platform. It is essential to mention that we use different types of cookies, and tools for data collection, profiling, and online advertising. In this sense, in order for you to have detailed information, we ask you to review Apex Learning’s Cookies Use Policy. (LINK UPDATED)
Consent
Users declare to have previously read and provided their free, express, unequivocal, and informed consent for Apex Learning to process their Personal Data; Likewise, they declare that they have been informed about what information is collected, the way in which it will be carried out and the purpose of collecting Personal Data.
Minors
Users declare to have previously read and provided their free, express, unequivocal, and informed consent for Apex Learning to process their Personal Data; Likewise, they declare that they have been informed about what information is collected, the way in which it will be carried out and the purpose of collecting Personal Data.
In the event that Apex Learning collects and processes the Personal Data of minors, necessary and indispensable for the development of the contractual relationship with the underage User; Apex Learning will inform the owner of the personal data and/or their legal guardian, about the purposes of the processing of Personal Data, in accordance with the provisions of article 14 of the Law on Protection of Personal Data.
Policy Update
Apex Learning expressly reserves the right to modify and/or update this Policy at any time, in accordance with the modifications or requirements of the regulation or due to adjustments inherent to the service made at Apex Learning’s criteria.
Any modification and/or update produced in this Policy will come into effect from its publication on the Platform.
Likewise, Apex Learning will make its best effort to notify Users of said modifications through their registered email or by publishing the Platform.
Assignment of contractual position
The user expressly authorizes the transfer of this Policy and the Personal Data in favor of any person who (i) is bound by this Policy; and/or (ii) that it is the new person in charge of the data banks that contain the Personal Data.
After the transfer has been produced, Apex Learning will not have any responsibility with respect to any event that occurs from the date of the transfer. The new data bank manager will assume each and every one of Apex Learning’s obligations established in this Policy regarding the treatment, safeguarding, and conservation of Personal Data.
Applicable law
The Privacy Policies are governed and interpreted in accordance with the laws in force in the United Kingdom, subject to the competence and jurisdiction of the Judges and Courts of the United Kingdom.
Contact
Apex Learning accepts all types of doubts, complaints, or comments regarding the Privacy Policies. Send us an email at info@apexlearning.com or write to us at the following address: Apex Learning Inc.
I declare that after having read the Privacy Policy, I expressly accept all the terms contained therein and also authorize Apex Learning to send me advertising and/or commercial material. As a sign of agreement, I proceeded to fill out the visiting user purchase form.