Privacy Policy

This Policy explains:

• how we collect and process your personal data;
• your legal rights as to your personal data.

Please, note!

In order to use our services (the website), you must agree to these terms and conditions.

Definitions

You may find the vocabulary of the definitions we use in the end of this Policy.
If you are under 18, please stop using our Site.

You may contact us if you have any questions or concerns not addressed to in this Policy.

We are available by email or by phone.

Data Controller

We are:

E-mail address: hello@qamadness

We collect:

• your name;
• your contact information.

We do not use automated decision-making nor profiling.
We do not normally collect nor process your data on your health, biometrics, trade union membership, political opinions and other sensitive topics.

Personal Data We Collect and Why

1. Information you to provide us with

Application:

• First name and family name
• Contact information (email, mobile phone, telegram username)

We collect the personal information about you in order to contact you, understand your needs and provide you with the Services. We do not collect it in order to sell or resell your personal data, raw or processed, to third parties. We treat the information as true data about you. We use these data in order to facilitate the communication with you and us to answer your questions in regard to our services. Please, do not mention in the “Enter your question” form any information you do not want to be publicly available.

We work with qualified contractors all over the world. That is why we may disclose this information to our contractors from third countries for the purposes listed above. We do not sell, share or disclose in any other way and for other reasons than described above any of personal data collected.

2. Information created when you use our Site

When you use our Site, we may collect information created by the software, protocols, networks and devices you use to access the Site (including, but not limited to identifiers, logs, and metadata). We use this information to make the functionality of our Site available to you, to enhance our Site, and answer any question or queries you may have.

More information on how we handle autogenerated personal data is available in our Cookies Policy.

3. Information about you obtained from other sources

Third parties’ Websites

We collect and process data that Data Subjects voluntarily have made publicly available. We may obtain this data from third party services or websites as social media. The main purpose to collect it is to observe our client base and provide better services to our clients according to their needs. We use such information to enhance and develop our Site or terms and conditions under which we provide services and run the Site.

We do not run any automated decision-making devices or software including those based on all the data aggregated.
We do not use personal information we collect for profiling.

We do not normally collect nor process any kind of sensitive data, namely race and ethnic origin, religious or philosophical beliefs, political opinions, trade union memberships, biometric data used to identify an individual, genetic data, health data, data related to sexual preferences, sex life, and/or sexual orientation unless such data are manifestly made public by you.

We do not receive any personal data on you when you visit the links placed on Site or use the services accessible via API. All the data you fill in there or provide our partners with is under their responsibility and is collected, used and disclosed pursuant to their privacy policies. Please, check their privacy policies before accepting their services.

We will additionally ask for your consent in case we need your data for the purposes not described in this Policy provided that we are not legally compelled to collect or disclose the information about you.

Cookies help us identify your device and enhance your user experience, so we may be sure your application or web version of the site works properly.

You may opt out, i.e. refuse to be tracked by cookies. We do not guarantee that the Site will work properly in this case.

Cookies and Third-Party Technologies

Cookies

Cookie is a small piece of data sent by the web-server to be stored by your device. Cookie may contain your unique identifier (see Information created when you use our Site) and typically serve to improve your experience of Internet surfing: for instance, due to cookies, you are able to browse pages you have once visited quickly, to set your unique options in “settings” menus, as well as monitor your way through the webpages in order to aggregate precise information about your navigation and preferences, so the site owners may analyze the information and offer you a better service and relevant ads in the future.

You may learn more about cookies we use here: Cookies Policy.

We do not disclose your personal data unless we are legally compelled to do so or you consented to such disclosure.

Be aware that we will process your data in accordance with this Policy as far as we retain ownership over the Site.

Winding-Up, Bankruptcy or Company Purchase

In case our company is sold, is in the process of the merger or acquisition with another company, or is subject to winding-up regardless the cause, we ensure the respect for your privacy by applying this Policy to the personal data we have collected up to the moment of transfer of controllership over our company or its cease of activity and the following sale of assets if the latter takes place.

We will warn you about the next steps we are to pursue to protect your privacy if such an occasion arises.

In general, our grounds for processing are:

• the necessity to fulfill our obligations under our contract or in order to make steps to form the contract with you or on your behalf;
• the obligation to fulfill our legal obligations imposed by the laws and/or state authorities;
• work on the enhancement of the user experience, safety, security and other legitimate interests we may pursue;
• your consent.

Grounds for Processing

We promise that we use the personal data we’ve obtained from you or on your behalf in a way that does not outweigh your rights and freedoms.

Despite this, we must comply with the GDPR requirements to the legal grounds for processing. The GDPR allows us to collect and process your personal data on the grounds as follows:

The processing is necessary to provide you with the Services and features available through our Site

To achieve this purpose, we may need Your information (such as name and email) and the data about your device, location in compliance with Google Privacy Policy. We will ask you about your consent where we need your data for marketing or other purposes that override our legal interests as to the maintaining the Site and making it available to you, and no other legal basis may justify the processing of the personal data.

The processing is necessary to fulfill our legal obligations

Applicable laws depending on the relationship between you and our company may affect:

• the scope of personal data we collect,
• ways we process your personal data in,
• our ability to keep the confidentiality of your data and avoid their disclosure,
• duration of the planned retention, etc.

Where processing is necessary to protect the vital interests of individuals or public policy, we cannot refuse to provide the copies of your personal data we have collected or may have access to within the functionality of the Site to the authorities and enforcement agencies in case of receipt of their legitimate decision or demand to do so.

Also, we may be obliged by law to provide the aggregated information to the state statistics bodies or to state historical archives.

The processing is necessary to secure our or third parties’ legitimate interests

We may use the personal data we collect and process (including yours) in order to maintain and enhance our user’s safety and security, enabling or administering our business (quality control, consolidated reporting, customer service), transfer of ownership and so on.

Also, we will report to the police or other competent enforcement agencies in case we discover fraud or any other violations of the applicable law or suspicious behavior or actions committed on behalf of your account.

Partly we are processing your data for the legitimate interests of third parties, too (e.g. our contractors), provided that such proceeding shall not outweigh your rights and freedoms.

Pursuant to and as limited by your consent

We need your consent in order to:

• collect and process your data pursuant to the purposes specified in Personal Data We Collect and Why;
• transfer your personal data to our processors and partners engaged in the processing of personal data whether they are incorporated outside the EU or not.

Among the purposes we list above, we rely on your consent when we use your personal data (for instance, your experience of interaction with our Site as caught and stored via the cookies) for optimizing and enhancing the operation of the Site, developing new features and services inspired by your experience and feedback (including when it is collected as a part to the aggregated data), and providing you with relevant advertising materials as long as it is allowed by your device or browser’s personalization and privacy settings.

You must be at least 18 years old to use our Site.

Please report any cases related to the use of our Site by minors.

Your Age

We do not intend nor knowingly collect and process personal data of minors. We do not ask data as your age and legal capacity as it is not necessary to provide our customers with answers to their questions.

By using or accessing our Site, you acknowledge that you are at least 18 years old and have all rights to enter into an agreement with us as to the receipt of Services and use of Site, as well as you give us the consent to collect and process your personal data for the purposes we mention in this Policy.

We appreciate your awareness as to the presence of minors (i.e. any persons under 18) among our Site users. If you know that we process personal data of individuals under 18 years old, please inform us by sending email at [email protected].

We usually retain your data for six months.

We may keep your personal data longer in case we have serious legal grounds to do so.

In the end of six months’ period we will delete your personal data unless we have serious reasons not to do so.

Retention of Personal Data

We will store and process your personal data as long as we cooperate with you under the contract. After the contract is over we will delete your personal data from our databases and request our processors to delete your personal data, too within a year.

However, where you access other web sites and\or services using our Web Site, they may retain your personal data for a longer period. To learn for what period they are to store your personal data, please check the respective web site’s/service’s privacy policy.

After expiry of a year retention period we are to delete your personal data, unless its storage is justified by legal obligation or our legitimate interest to do so (i.e., your account has been previously noticed or suspected in participation in the fraudulent schemes, botnet, etc.).

You may request deletion of your personal data at any time by sending us an email at [email protected]. Executing your request, we will delete any data that is not mandatory to be retained. Sometimes we may be unable to delete your personal data (for instance, in case of unsettled or unresolved dispute or claim, or in case we suspect you in being associated with a crime or other violation of applicable law, e.g. fraud, unsafe behavior, security incident). Upon the resolution or settlement of claim, conclusion of a criminal or administrative proceeding, or learning that our suspicion is unjustified, we will delete your personal data.

Be careful while accessing links you are provided with within the Site!

Any data you disclose behind the link is collected and processed by the owner of the site available at the link you have previously accessed. Do not forget to read their Privacy Policy first.

We must disclose your personal data in case a state authority will ask us to, provided the appropriate decision is put in place.
Sometimes we may disclose your data to third parties. But in this case we use NDAs, standard clauses and other tools to safeguard your privacy.

Data Sharing and Disclosure

We may share the personal information we collect about you. Here we provide you with the list of our partners and third parties we share your personal data with.

Our subcontractors, service providers and business partners

We may grant access to your personal data, in full or in part, to our subcontractors and service providers.

Our subcontractors and service providers may include, for example:

• subcontractors that actually provide services (processors),
• cloud services providers,
• marketing and advertising platform providers,
• data analytics providers,
• development services suppliers,
• vendors assisting us in enhancement of the safety and security of our Site,
• auditors, accountants, lawyers and other professional service providers.

We may pass your personal data to the contractors in Ukraine who act as QA specialists, if it’s necessary for providing services. To protect your personal data we sign DPA and NDA with all our contractor outside EU.

State authorities, enforcement agencies, courts

We may be legally obliged to disclose your personal data to the competent state authority, enforcement agency or a court in case we receive a mandatory request for such disclosure from them.

As we warned you earlier, we may be proactive and address the competent authority in case we suspect a violation of law to be committed in association with your account or persona via our Site.

We reserve the right to implement any tools and techniques to reveal the impersonation, fraud and other crimes, and report them immediately to the appropriate state authorities and enforcement agencies, including the personal data associated with the activities which, at our own discretion, are suspicious and may raise concerns about their association with the violation of applicable laws.

Your consent

We will notify you of the purposes and scope of the disclosure and ask for your permission in case your personal data is to be shared with a third party not mentioned in this Policy.

Our home is Lithuania.

We use cloud services demonstrating their compliance with the latest standards of data privacy and security.

Cross-border Transfer of Data

Our headquarters is in Lithuania. We process and store your personal data using the Google Spreadsheets and Hubspot web hosting services. The servers are situated in the US and are certified under the Privacy Shield Program. You may check data security and privacy compliance of these services here:

Google: https://policies.google.com/privacy?hl=en-US
HubSpot: https://legal.hubspot.com/privacy-policy

The cloud service provider and its headquarters are as follows:
HubSpot, Inc.
25 First Street, 2nd Floor
Cambridge, MA 02141 USA
E-Mail: [email protected]
Nicholas Knoop is Hubspot`s data protection officer and he can be contacted via [email protected].

We implement suitable security measures to protect your privacy and increase the level of your safety and security of your personal data we use to provide you with the Services.

Some data may be accessed and processed within the territory of Ukraine. In order to secure the adequate level of protection, we implemented the Standard Model Clauses in the relationships with the engaged contractors based in Ukraine, so they are bound to preserve at least the same level of personal data protection as it is granted by the law applicable to us.

You are free to enjoy your rights under the GDPR which are as follows:

• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to object to processing;
• right to data portability.

We do not charge fees for answers or processing of your complaints.
Remember that you may withdraw you consent at any time.

Your Rights

Rights under the GDPR

The GDPR reserves a scope of rights you may enjoy as to personal data protection. The list of rights protected by the GDPR is as follows:

• right of access (i.e. you may ask us to send you a copy of the data about you that we collected);
• right to rectification (i.e. you may ask us to correct the outdated or false data, or complete the data which is missing or incomplete);
• right to erasure (i.e. you may ask us to delete the personal data we retain, provided that the GDPR allows you to do so);
• right to restriction of processing (if processing may be restricted under the GDPR);
• right to object to processing (if the GDPR reserves your right to object as to certain kinds of processing or in certain circumstances);
• right to data portability (i.e. you may ask us to transfer a copy of your data to another organization or to you provided that the circumstances comply with the GDPR).

Please remember that we do not charge any fees in relation to exercising your rights protected by the GDPR. We typically do our best to answer you as soon as possible or within the reasonable period taking into account the complexity of the request, but in case we are processing a large amount of requests the answer may took us longer than you might expect.

You can send us the request via email [email protected]. Please verify that your request comprises the details:

• your name,
• contact information,
• right you want to exercise, and, where applicable,
• your personal data in our processing,
• reason/justification behind such request.

Right to Withdrawal of Consent

The GDPR reserves your right to withdraw consent to processing of your personal data.You may enjoy this right at any time you wish. Please remember, that the withdrawal of consent does not necessarily mean that the processing before the withdrawal is considered thus illegal.

You may withdraw your consent by sending us an email [email protected] or by filling in a special form of withdrawal. Before withdrawing your consent, take into attention the outcome such withdrawal may entail (e.g. termination of your Account, lose of access to your tickets or insurance agreement texts etc.)

We will verify your withdrawal of consent within 72 hours since the receipt of your request.

Our Data Protection Authority.

We would highly appreciate if you address us prior to lodging a complaint with the DPA. We are here to make your experience as pleasant as it shall be.

Data Protection Authority

In case you are convinced we are somehow infringing your personal data rights granted by the GDPR, you may lodge a complaint with the supervisory authority.

The Policy may be changed time to time.

Please read it regularly to ensure you are not missing anything.

Updates to the Privacy Policy

We may occasionally update this Policy. If we make significant changes, we will notify you of the changes on our Site or through others means, such as email. To the extent permitted under applicable law, by using our Site or our Services after such notice, you consent to our updates to this Policy.

We encourage You to periodically review this Policy for the latest information on our privacy practices.

In case you forget what the terms we use in this Policy mean, we have this short vocabulary.

Definitions

“We” means the company mentioned in Data Controller.

“You” means you as the user of the Site or as the Applicant.

“Visitor” means any person who enters and surfs the Site.

“Personal data” means any information relating to you and helping identify you (directly or indirectly), in particular by reference to an identifier such as your name, identification number, location data, an online identifier or to one or more factors which may enable a third person to identify you as a natural person.

“Data subject” means you and any living individual who is the subject of personal data held by us, including users of our Site and even our employees.

“Controller” means a 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.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Sensitive data” (also: Special categories of personal data) means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying you, data concerning health or data concerning your sex life or sexual orientation.

“Site” means the websites accessible at the links: https://www.qamadness.com/ and https://course.qamadness.com/.