Privacy Policy

The course provider ("Tutor" or "we"/"us") process personal data in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, General Data Protection Regulation ("GDPR"), and any other Swedish laws and regulations applicable in the field of data protection. This Privacy Policy explains how we use the personal data that we collect from you when you use our Service as stated in our TERMS FOR THE PURCHASE OF ON-LINE COURSES. It also describes your rights toward us and how you can exercise your rights.

This Privacy Policy supplements the TERMS FOR THE PURCHASE OF ON-LINE COURSES whenever any of Tutor's customers ("data subjects") purchases on-line courses ("Services") and thereby provides Tutor with personal data that is or will be subject to data protection laws. Tutor shall be referred to as data controller.

Tutor will only process personal data to the extent necessary to fulfill the Services under the TERMS FOR THE PURCHASE OF ON-LINE COURSES and for purposes which are compatible with providing the Services. In this regard, Tutor is the controller of your personal data.

TUTOR'S PURPOSES AND LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA

"Personal data" means any information relating to an identified or identifiable natural person that, directly or indirectly in combination with other information, can be linked to a living, natural person. Personal data is a very broad term, and it includes the name, contact details and IP addresses of such person.

"Processing" of personal data means, including but not limited to, collecting, registering, organizing, structuring, and storing. Processing also means alteration, production, reading, listing, using, and disclosing personal data by transfer, disseminating, changing, removing as well as deletion of the personal data.

"Data subject" means an identified or identifiable person to whom personal data relates.

Tutor will only process personal data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others. Tutor may process personal data based on the following legal grounds in GDPR:

In the event Tutor foresees the need to process personal data for a purpose which, pursuant to applicable laws and regulations, should be based on consent (on grounds of Art. 6(1)(a) GDPR), Tutor will contact you in advance, to inform you about the processing for which your consent is required before the consent is collected and ask for your consent.
To fulfil an agreement with you or to respond to your request for customer service. The legal ground for this is that the processing is necessary for the performance of an agreement or contract to which the data subject is party or to take steps at the request of the data subject prior to entering into an agreement or contract (Art. 6(1)(b) GDPR).
To comply with legal obligations to report to authorities and third parties. The legal ground is that processing is necessary for compliance with a legal obligation to which the data controller is subject (Art. 6(1)(c) GDPR).
To satisfy a legitimate and justified interest of Tutor in processing your personal data, such as marketing our products and services by contacting potential and existing customers via email, newsletters, or letters, in order to inform them about Tutor's services, offers, events and products. The legal ground for this is that the processing is necessary and that Tutor has a legitimate interest (Art. 6(1)(f) GDPR) that is not overridden by the fundamental interests and freedoms of the data subjects.

DIFFERENT CATEGORIES OF THE DATA SUBJECT'S PERSONAL DATA

When you visit one of our digital channels (for example our website, social media and video sharing sites, our mobile applications, online events, digital meetings, webinars, online training etc.), as well as when you contact us via email or our website's chat function, we may collect information about you, such as your name, address, postal address, email address, phone number, identification data and information regarding your use of Tutor's products and services. In some cases, we may process your personal identity number. Tutor may also collect your personal data from other public sources and external partners from other countries. Personal data that may be collected and processed by Tutor could include:

your name, email address, postal address, name and contact details of your employer, telephone number, banking information and payment details, IP address, picture, personal settings;
cookie files stored on your computer or your telephone (or other digital device which you may use to visit our digital channels) for the purpose of identifying your browser and to recognize your settings and preferences. You will have the right to refuse Tutor's processing of personal data using cookie files; and
other information regarding your use of Tutor's products and services, which we may collect from our surveys and other means of communication with Tutor.

Please note that when you enter your personal data in connection with using the services of our payment providers, you must read and accept the payment provider's terms and conditions, which can be found here: stripe.com/privacy.

PROCESSING AND TRANSFER OF YOUR PERSONAL DATA

The Data subject has through this Privacy Policy been informed about the fact that personal data will be stored in a database for the purposes described above. If Tutor engages co-operation partners, Tutor shall ensure that any personal data is afforded equivalent protection as prescribed in this Privacy Policy and in accordance with the GDPR. Tutor may also transfer personal data to others within Tutor's business operation, coordinators, co-operation partners and providers, as well as third parties, including but not limited to suppliers, cloud service providers, consultants, and authorities. Tutor shall, however, only transfer personal data if Tutor has a legal ground under the GDPR to do so.

Tutor may also transfer personal data to a third country, i.e. a country outside the EU/EEA, or to international organizations according to applicable laws and data regulations. Tutor and third parties may be based anywhere in the world, which could include countries that may not offer the same legal protections for personal data as the EU/EEA. Tutor will comply with local data protection requirements and its internal global privacy standards and Tutor will apply the necessary safeguards under the applicable law of the country transferring the data for such transfers.

The personal data will be, dependent on the purpose for which it is collected, archived, confidentially erased, or anonymized in accordance with the rules of archiving when it is no longer necessary. Personal data will be stored during the time it is necessary for Tutor to fulfil its obligations and for the purposes set out above. Tutor will bring necessary measures to provide the personal data with protection against unauthorized access and loss thereof.

In the event a personal data incident incurs, Tutor shall notify the Data subject as soon as possible and in any event within 72 hours of becoming aware of the incident. A personal data incident means a security incident that leads to an accidental or unlawful destruction, loss or alteration, unauthorized disclosure or unauthorized access to the personal data transferred, stored, or otherwise processed. As personal data will be transferred over the internet, it is important for data subjects to be aware of the associated risks.

If the personal data incident leads to a high risk to the rights and freedom of a data subject, such data subjects must also be contacted without delay.

Subject to applicable data protection legislation, Tutor shall not be liable for any damages arising from the processing of personal data. In any event, Tutor shall not be liable for indirect damages. Notwithstanding anything said in this clause 3.6, Tutor is not seeking to exclude liability for gross negligence and wilful misconduct, nor any other mandatory terms and conditions stipulated by Swedish and European law.

THE DATA SUBJECT'S LEGAL RIGHTS

Data subjects have the right to object to Tutor's processing of the personal data such as, for example, when processed in connection with direct marketing. Data subjects also have the right to request deletion, restriction, and rectification of the personal data. If consent is withdrawn, or if the stored personal data is incorrect or irrelevant, Tutor must delete, restrict, or correct such personal data.

Data subjects have the right to request information about Tutor's processing of personal data. If a request is made electronically, Tutor shall provide the information in an electronically readable form which is structured and commonly used. Any request from data subjects shall be answered within a reasonable period by Tutor.

Tutor shall, upon request, provide information about the purpose of the processing, what personal data is being processed, recipients of the personal data and, if possible, for how long the personal data will be stored. Upon request, Tutor shall also provide information about the possibility to request deletion, rectification, or alteration of the personal data, as well as how to lodge a complaint to Tutor or the competent supervisory authority. Furthermore, Tutor shall upon request provide information about the origin of the personal data, the existence of profiling and automatic decision-making, and any transfers to third countries. If requested, Tutor shall also provide the data subjects with a copy of the processed personal data.

Data subjects have the right to transfer the personal data to another data controller (data portability), as well as to lodge a complaint regarding Tutor's processing of personal data. Complaints shall be submitted to Tutor and/or the competent supervisory authority according to the contact details in clause 5 below.

This Privacy Policy may be updated at any time and the latest updated version may always be found on Tutor's website: app.havenhub.life

CONTACT INFORMATION

Tutor's email address for contact is: info@havenhub.life.