This application, as developed by our company (hereinafter “SQLearn”), acknowledges and respects to the fullest possible extent the right of its users to protect their Personal Data under the strict implementation of the European Regulation 2016/679 and Law 3471/2006. This policy document describes the collection and processing of user data when using the services provided via this application. The user of our services must read carefully the terms and conditions for the protection of his / her personal information listed here.Based on the legal framework for data protection, SQLearn is the “controller” of the data you provide to our company, if any, while using this application. You, respectively, are the “data subject”.

The purpose of our policy is to explain to you in the simplest possible way the following:

• What data we process, for what purpose and on which legal basis.
• For how long we store your data.
• Who is the recipient of your data.
• What are your rights and how can you exercise them.
• What legal interests do we pursue.
• What applies to personal information collected through cookies.

What is considered Personal Data

By law, Personal Data is any information that pertains to an identified or identifiable natural person (“data subject”), such as name, email address, VAT number, etc. Identifiable is defined as a natural person whose identity can be verified, directly or indirectly, in particular by reference to an identifying element such as name, ID number, location data, online identity (IP address, e-mail etc.) or one or more factors specific to his physical, genetic, psychological, economic, cultural or social identity.

What is Personal Data processing

Personal Data Processing is any operation or series of operations performed with or without the use of automated media, on Personal Data, such as the collection, filing, organization, structure, storage, customization, modification, retrieval, information search, use, transmission to third parties, dissemination, association, combination, restriction, deletion and destruction of Personal Data.

Which Personal Data we collect and for what purpose

As a rule, our company only collects and processes user’s Personal Data only when he or she provides it directly and at his or her own discretion, so the use of this application does not necessarily mean that we process your Personal Data.

In other words, when you use the SQLearn’s application, none of your Personal Data is collected by our side without your prior consent and knowledge.

The purpose of collecting Personal Data is for statistics and analysis in order to develop and improve the application.

Legal Basis for processing of Personal Data

The legal basis for the lawfulness of processing of your Personal Data, if it may occur, is your consent prior to the use of the application by your side.

In case you are willing to purchase licenses regarding our Products, the legal basis for the lawfulness of processing of your Personal Data is the performance of the contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

SQLearn contact form

We provide you with the opportunity to contact us through a contact form. The necessary contact details are the name and the email address. We process your information based on your consent, which you provide to us with your positive action before sending your message in order to provide a response. You have the right to revoke your consent at any time, without prejudice to the legality of the consent-based process of your Personal Data prior to its revocation.

Sending an email or submitting a contact form is not by itself sufficient reason neither to include you in our database nor to retain your data for marketing purposes.

Recipients of the data

The Personal Data of our application’s users, if there are any as defined above, are not transmitted to third parties for marketing purposes. We use third-party services (as “processors”) for very specific and absolutely necessary services, such as in case of other content providers who exclusively gain access to those Personal Data required for the provision of services requested by your end. Only respected and distinguished organizations have been selected to become our content providers making sure that secure and of high quality services are being provided to all parties involved. In exceptional cases we may be required to share Personal Data with judicial or police authorities, we will do so under strict terms and conditions imposed by all applicable laws and regulations.

If you have any questions about our policy, please do not hesitate to contact us at (+30) 210 7778877.

Processing your transaction

If you request something from us through our application or ever through visiting our website, e.g. product or service, callback, or specific marketing material, we will use the information you provide to satisfy your request. To this end, we may share your information with other parties involved, e.g. other departments of our company, our trading partners, financial institutions, shipping companies, postal or government authorities (eg Customs authorities). We may also contact you about a transaction in the context of customer satisfaction research or market research purposes.

Time and place of data retention

The Personal Data of the users, if there are any as defined above, are collected and maintained for as long as is required and are subsequently deleted. In any case, in order to set the storage period, we always keep in mind the principle of limiting the storage period, while always ensuring that they are kept secure. If you wish to delete your Personal Data at any time you can send a message via the contact form to SQLearn, your message and details will be deleted within 2 months since our last contact.

Your Personal Data, if there are any as defined above, is stored into Company’s system, hosted on a server that uses resources from Amazon’s data center infrastructure. The management of the server is implemented with the appropriate methods, solely by strictly restricted personnel of the Company itself, without the mediation of third parties.

Data Security

In order to protect the Personal Data of the users of our application, we use secure connection (https: //) and data security measures to prevent the risk of loss, misuse, unauthorized access and disclosure of your personal information such as use of encryption when transferring certain sensitive data.

What all the aforementioned mean in practice:

IF THE COLLECTION AND PROCESS OF YOUR PERSONAL DATA IS EXCEPTIONALLY REQUIRED FOR THE PROVISION OF SERVICES UPON YOUR PRIOR REQUEST AND PERMISSION, WE DO SO UNDER THE FOLLOWING TERMS AND CONDITIONS:

• We collect and process your data only for specified, express and legitimate purposes.
• We collect and process only the data that is essential for the purposes we set.
• We make every effort to keep your data accurate, giving you, where appropriate, the ability to edit / delete them.
• We maintain your data for the time required for the purposes we set.
• We make every effort to safeguard the security of your data from unauthorized or illegal processing and accidental loss, destruction or damage.

As part of the procedure for the successful protection of the data we process, we implement a range of appropriate technical and organizational measures, adopt internal security policies, train properly our staff who are committed to confidentiality, while utilizing a range of technologies that ensure the security of your data. As required by the principles of information security and data protection, technical and organizational security measures are regularly monitored and, if necessary, updated and adapted to new best practices.

Information on managing newsletters

SQLearn regularly sends newsletters to its users, depending on their employment status. Sending a newsletter does not require you to create a profile but is sent to the email that you have voluntarily reported to us.

Administrators of the SQLearn application make every effort to maintain the proper functioning of the newsletters, but technical or organizational problems are always likely to arise. For any issues that arise as well as any relevant information regarding the operation of the newsletters, please contact us at (+30) 210 7778877.

Social media

SQLearn has official accounts on the following social media:

Facebook, Twitter, YouTube, LinkedIn.

Our Company encourages users to submit comments on posts and / or pages that we maintain on social media, in the context of an open dialogue with respect to different views.

SQLearn does not have a general obligation to control the content submitted by users of these media, however, it strives to ensure a secure online environment. As a result, the administrators of SQLearn’s social media have the right to remove any content deemed to violate the terms of use of the application, such as abusive, obscene, pornographic, threatening, advertising or intellectual property infringing or containing false statement regarding the user, while retaining the ability to exclude users who submit it.

If you believe that user content hosted on SQLearn’s web pages on social media may in any way offend you or violate our terms of use, please contact SQLearn’s administrators immediately.

Disclosure Required by Law

Please note that in some exceptional cases, it is possible to be requested disclosure of information by judicial or other government order, summons or warrant.

Links to sites that do not belong to us

Our application does not contain links to other applications or sites. In no way, do we are responsible for the Personal Data protection policies of other applications or websites nor for their content.

What are your rights

With regard to the protection of your Personal Data, you have the following rights:

(a) Right to access, ie the right to know whether Personal Data concerning you is being processed and what kind of processing;

(b) Right to rectification, ie the right to require correction of inaccurate Personal Data;

(c) Right to erasure, ie the right to request that Personal Data concerning you be deleted;

(d) Right to restriction of processing when the accuracy of the data is questionable, illegal or for any other reasonable ground;

(e) Right to data portability, ie the right to request that you receive data on structured, commonly used and machine-readable formats, and to transmit such data to another controller; and

1. f) Right to object to the processing of your personal data, unless there are serious, imminent and legitimate reasons for processing that override your interests, rights and freedoms.

For the exercise of the aforementioned rights as well as any questions or issues you may have regarding this matter, you may contact the SQLearn’s Data Protection Officer by emailing info@sqlearn.com or by post at our address or by fax at (+30) 210 7778877.

Finally, in the event of a data breach which may endanger the ability to exercise your rights and if this does not fall within one of the exceptions provided for in the Regulation, we are obliged to inform you without undue delay.

In this context, it should be noted that compliance with the legal framework for data processing and the exercise of your rights is a priority for SQLearn. For this reason, we have the right to request for additional necessary information in order to verify your identity before exercising your rights, such as e.g. in the case of a request to erase your data. In any case, our company is obliged to respond promptly to your request within a reasonable time. If it is necessary due to the complexity of your request and the number of pending requests, our response time may be extended, but in any case, we will inform you as soon as possible of this as well as the reason for the possible delay of its satisfaction.

If your claims are manifestly unfounded or excessive, especially because of their recurring nature, the Company may either charge a reasonable fee, taking into account administrative costs for providing the information or for communicating or executing the action requested, or refuse to respond to your request.

Minors

The content of our application and the services provided are aimed exclusively at people over 18 years of age and we do not knowingly collect any information about people below this age, if there are any as defined above. If you are under 18 you are not allowed to submit your information to us in any way.

As it is not technically feasible to effectively control your age at all times, we undertake to erase all relevant information immediately if it is reported and verified that the action of submitting personal information about minors has taken place. This deletion is without prejudice to the need to keep records in the event that our legal claims are substantiated, exercised or upheld, or upon being provided guardian’s consent.

Changes in policy and notification

Effective protection of your Personal Data requires systematic monitoring of our policies and procedures. At the same time, our desire to provide better services means that we are constantly striving to continually improve our practices and adopt new ones, always respecting your Personal Data.

Therefore, this Personal Data Protection Policy may be amended at any time without notice. Guided by the principle of transparency, we are committed to keeping you informed of any major changes in our policy. In any case, however, you should periodically review our policy as the use our services from your side involves acceptance by you.

Questions

If you have any questions about our Policy or how we process your data in general, you can contact us by email at info@sqlearn.com or by phone at 210 7778877 (Contact Hours: 10:00 – 18:00 Monday) to Friday).

Right of complaint

According to European Regulation 679/2016, you have the right, if you believe that your rights to the protection of your Personal Data are being violated, to file a complaint with the Hellenic Data Protection Authority (having its registered seat at 1-3 Kifissias Str. 115 23 Athens) or by phone 2106475600 or by fax 2106475628 or by emailing complaints@dpa.gr.