WHAT IS THIS NOTICE ABOUT?
At KNOWLAXY OOD (“KNOWLAXY”, “Us”, “We”) we provide a wide range of services via our website www.knowlaxy.com (“the Website”). Please check our Terms of Service for further information on our services and how to use them as this Privacy Notice is part of our Terms of Service.
The Website is a medium for sharing knowledge and educational materials created by our users and
other contributors. Such materials are available publicly and free of charge to both our Registered and
Unregistered Users.
In the course of operating our Website, we may come into contact with and process information about our Registered and Unregistered Users and other natural persons, such as visitors of our Website, parents or legal guardians of Registered Users who are minors, persons submitting complaints about intellectual property infringements or enquiries regarding our services etc.
This notice (“the Notice”) provides information to all visitors of our Website and our Registered and Unregistered Users (collectively “You”, “Your”) on how we collect, store and use your personal data in regard to your use of the Website.
Please take your time to review this Notice and regularly check our Website for any updates to it.
As per the General Data Protection Regulation 2016/679 (“GDPR” or “the Regulation”), effective as of 25 May 2018, you, as a natural person, are a subject of personal data.
“Personal data” encompasses any information which does or might, directly or indirectly, identify you, as a specific person. We act in the capacity of controller in regard to the personal data we process as we determine the purposes and means of the processing of personal data. Personally Identifiable Information can include information such as your name, email address, IP address, and device identifier, among many other things. It is your responsibility to ensure the accuracy of the personal data which you provide us with.
Our identification and contact details are provided in the end of this document.
We reserve our right to change and update this Privacy Notice at any time. We may also notify data subjects in case we make some substantial updates.
WHAT PERSONAL DATA DO WE COLLECT?
For all visitors and users (both Registered and Unregistered) of www.knowlaxy.com:
(1) When you access our Website, we collect data on:
− Your dynamic IP address which is a type of online identifier,
− and
− Information on your choice in regard to cookies (you can read more about cookies on our Website at https://knowlaxy.com/cookies-policy).
(2) When you communicate with us: e-mail, post or courier correspondence, correspondence by filling-in our Website contact form, and other communication received and sent by us when you address us with any requests or enquiries regarding our services or complaints for intellectual property infringements.
For Registered Users of www.knowlaxy.com:
Upon submission of your initial registration form as a Registered User at our Website, we collect and process:
− Your e-mail address,
− Your gender,
− Your date of birth,
− Your User name and password (we recommend that you choose a user name different from your real name),
− Your token – a unique key KNOWLAXY creates internally and attributes to your account; it is used for the creation of your account, for resetting your password and other similar purposes,
− Other data you have freely and unilaterally chosen to provide us with,
Please note: if you do not activate your registration within 72 hours after receiving our e-mail containing the activation link, all data submitted by you in our registration form will be deleted.
in the course of your use of our services as a Registered User, in addition to the information collected upon your initial registration, we may also collect and process:
− Audio, video, photographic and/or text materials which you choose to upload to the Website /to the extent such materials contain personal data/,
− Your PayPal account (intended for transferring donations, if any)
− Your comments in our fora,
− History of the materials on the Website you view which shall not be used for profiling but may yet indicate some personal preferences of yours,
− Оther Registered Users you communicate with via the Website,
− Other data you have freely chosen to provide us with, such as the description item which you might fill in with any information
FOR PERSONS WHO ARE NOT OF FULL LEGAL AGE, BUT WISH TO REGISTER AT THE WEBSITE:
If you are minor of age, you cannot register at our Website on your own. However, if your age is 16 or more, pursuant to art. 8, para 1 of the GDPR, you can register on your own. If you are below 16 years of age, your registration may be finalised only if your parent or legal guardian explicitly confirms to us that they agree with your registration.
If you wish to register as a Registered User of www.knowlaxy.com, you can complete a child registration form. In this form, you provide us with the following information:
− Your names,
− User name and password (we recommend that you choose a user name different from your real name),
− Your gender;
− Your date of birth;
− Your statement that you are minor of age,
− Information about your parent or guardian:
− Your parent or guardian’s names,
− Whether this is your parent or guardian,
− E-mail address of your parent or guardian – we need it to send them an e-mail asking them if they agree that you register with our Website.
Once you complete your child registration form on our Website, we will send an e-mail to your parent or guardian to ask for their consent that you may be registered with the Website. If they do not explicitly consent to your registration within 72 hours after we send the e-mail, we will delete your request as well as any data you provided to us with it.
For Registered Users who are minor of age, in addition to the data provided with the registration form, we will also store and process:
− The parent or guardian’s statement of approval of the minor’s registration with the Website and of
our Terms of Service;
− Token – a unique key KNOWLAXY creates internally and attributes to the child’s account; it is used for
the creation of the account, for resetting the password and other similar purposes,
in the course of your use of the Website as Registered User who is minor of age, in addition to the information collected upon initial registration from you and your parent or guardian, we may also collect and process:
− Audio, video, photographic and/or text materials which the User chooses to upload to the Website /to the extent such materials contain personal page 4 of 9 data/,
− Your comments in our fora,
− The materials on the Website you view,
− Other Registered Users you communicate with via the Website,
For Registered Users who win prizes in our competitions:
− Personal identification number, social security number or date of birth;
− Bank account details;
For Registered Users who make donations in favour of KNOWLAXY:
− Registered User’s identification data stored as a part of their Registration with the Website;
− Data about the donation – amount donated, frequency of donation – one time or monthly,
manner of transfer (via credit/debit card or PayPal account), donation id (information about the
person who donates, the amount and the purpose of donation – created internally by KNOWLAXY);
Please note that KNOWLAXY does not process any payments, nor does it receive or store in any way your
credit/debit card or bank account details. We exchange with PayPal the donation ID and receive from PayPal confirmation that your donation has been successful.
All donations are processed via PayPal. Please note that all PayPal transactions are subject to the PayPal Privacy Policy (alternatively known as PayPal Privacy Statement) available at https://www.paypal.com/us/webapps/mpp/ua/privacyfull)
HOW DO WE COLLECT AND USE YOUR DATA?
Most of the information we collect is provided directly by you on the following legal basis:
Prior to entering into а contract between you and Knowlaxy at your request or for the performance of a contract to which you are a party
– Such contracts are:
- The Terms of Service of Knowlaxy;
- Registration as a Registered User with the Website;
- Any other contract between you and Knowlaxy, such as donation you choose to make in favour of Knowlaxy;
– for the performance of our legal obligations, as this might be required by specific laws:
E.g..: our obligations under accountancy or tax laws, or when we are required to provide information to court or other state authorities under any applicable law;
– Our legitimate interests, unless they are overridden by your interests or fundamental rights and freedoms which require protection of personal data:
e.g..: for marketing (pursuant to recital 47 of the GDPR, the processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest), exercise or defense of legal claims, to send you notifications on subjects you have subscribed to, or otherwise asked to keep you informed of, to inform you of other services we provide or offers that may interest you, to improve the quality of our services, for statistical analysis and market research, to recognize when or how our
customers re-engage with the services we provide, to improve our services so content is delivered more
efficiently
– Your explicit informed consent:
- When you send us enquiries about our services or complaints for intellectual property infringements;
- Dispatch of our newsletter which might include advertisements from our partners and from us;
Note: you can opt-out of receiving such advertisements at any time by sending us an e-mail at
support[at]knowlaxy.com or by following the “I opt out” link in the advertisement e-mail. Once you opt out, we will no longer use your personal data for the purposes you no longer consent to. Please note you would still receive informative e-mails regarding your account, such as account verification or change of password e-mails, security or technical notifications, notifications on changes or updates to our services or Website.
As you browse our website we may use automatic data collection technologies to collect certain limited information about your device, browsing actions and usage patterns. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services. For more information on this matter please refer to our Cookies policy.
We also receive personal information about you indirectly, from third parties:
If you are a minor Registered User of the Website:
We may receive information about you from your parent or legal guardian (e.g., if you are their child or ward, your bank account details if you win a prize in one of our competitions, etc.);
If you are a parent or legal guardian of a minor who wishes to register at the Website:
We may receive information about you from your child or ward (your names, e-mail address and your capacity – parent or legal guardian to the child);
Automatic machine generated data:
e.g., your IP address;
Participants in a video or audio material uploaded by a Registered User on our Website:
We receive your data from the Registered User. By uploading any material containing a third party’s personal data, each Registered User declares and warrants to us that such data was lawfully obtained and also that it may legally be publicly disclosed. If someone has uploaded a video of you or disclosed your personal information in our fora, you should contact the uploader and ask to remove the video/comment. If you are unable to do so or it implies stress on you, you may request us to remove it for you. If you have any concerns, please contact us at info[at]knowlaxy.com
Any registered user is solely responsible for his or her own submission of videos and the consequences of publishing them or posting comments in our fora.
We use your personal data for the following purposes:
− to provide KNOWLAXY services and products on our Website;
− to respond to your enquiries about our services or complaints;
− to register you for participation in our competitions when you apply to them;
− to receive donations you choose to make in our favour;
− to make a quality review of the submitted videos and for pedagogical improvements as well;
− to send you advertising messages for other KNOWLAXY products and services;
KNOWLAXY does not knowingly send such messages to children.
– For the purpose of aggregated statistical analysis of how you and others use our website and our services, as well as developing and marketing those services.
− to perform our activities in compliance with the applicable accountancy, tax and other laws, professional requirements and regulations, including responses to requests from competent state authorities;
− in some situations we may have to process your data in regard to legal claims as this is explained in the How long do we keep your data section below, and for other purposes, indicated elsewhere in this notice.
In the event we would like to or have to use your personal data for purposes and in a manner which significantly differs from those we have notified you about, we will inform you accordingly and if necessary, require your consent.
WHO DO WE SHARE YOUR DATA WITH?
In order to achieve the abovementioned purposes for which we process your personal data we may need to share your personal data with various third-party service providers who act as data processors. Our website may use different analytics and marketing services, e.g. provided by Google Inc., Facebook Inc. or others via “cookies”. Cookies are text files placed on your computer/device. For more information about our use of cookies, please refer to our Cookies Policy. We may use both “session” and “persistent” cookies on this website.
When such technical option is possible we shall activate IP-anonymization in order to have your IP address truncated within the area of Member States of the European Union or other parties to the Agreement on the European Economic Area. However, unlike Google Inc., not all third party service providers allow such anonymization option.
In the course of our activities we may have to share some of your personal data with one or more of the following persons or entities:
- KNOWLAXY team members, including reviewers of materials uploaded by our Registered Users on their Website accounts – in order to approve their publication to the Website;
- The users of our Website who see your materials would become aware of the personal data you have chosen to share publicly; beware that content you share publicly might become accessible through search engines. Please note that the videos you upload may contain personal data and we make them available to the public as you implicitly instruct us to do by using our services.
- Our professional consultants and auditors;
- We may share your data with advertising companies to display relevant ads to you.
- Other suppliers and business partners we work with, when they need some of your data in order to perform their tasks, such as Google Ireland Limited, PayPal (Europe) S.à r.l. et Cie, S.C.A. (R.C.S. Luxembourg B 118 349)
- Bodies authorised under the applicable laws to require specific information, including personal data, such as – courts of justice, prosecutors, regulatory bodies, national security and public order authorities.
- We may disclose user data to report suspected crimes.
DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EU OR THE EEA?
As per the standards of the GDPR, an adequate level of protection of your personal data is guaranteed on the territories of the EU and the EEA. We store your information on servers located in the Netherlands, EU. We do not transfer or store your information outside the territory of Member States of European Union (EU) or of the European Economic Area (EEA).
Some of our partners or service providers may store or transfer information to a state outside the EEA when adequate protection measures are employed – for example the EU – US Data Privacy Shield for transfers to the USA. Please refer to our partners’ privacy policies for further information on how they handle personal data. The personal data? collected by us through our website may be sent to and stored on servers located in the United States, and other countries around the world (including outside of EEA). We ensure that legally required, appropriate contractual or other mechanisms are present prior to transfers of data outside of the EEA.
HOW LONG DO WE KEEP YOUR DATA?
As a rule, the period for which the personal data are stored is limited to a strict minimum.
We keep your data only for as long as this is necessary for the purposes of processing for which the data was initially collected and for any other permitted and related purpose or until a statutory term expires (e.g., for storage and processing of accountancy data and tax control – 11 years).
We retain your data (including videos) for as long as you have an account registered at our website. We may also retain videos deleted by you for a short period in case you made a mistake and request to reverse the deletion.
After your account is closed we may still retain certain logs for internal security purposes but we assure you that as soon as we no longer have a business reason (e.g. maintaining accurate accounting, financial, and other operational records; resolving disputes) for retaining the data, we will delete it. We shall never continue to store personal data after the expiry of the period permitted under the applicable law.
Our legitimate interests include storing certain personal information of yours until the expiry of applicable limitation terms (e.g., for situations governed by Bulgarian law – 5 years). We could not delete or anonymise your personal data if it is necessary in a court or administrative proceedings or if you have lodged a complaint with us.
HOW DO WE PROTECT YOU DATA?
We use a number of appropriate and reasonable physical, electronic and organisational measures to protect the data you have shared with us from prohibited access, usage or disclosure. By way of example, we have implemented anti-virus programmes, access control measures, strict implementation of the “need-to-know” principle, etc. We have adopted internal policies and procedures and have appointed an employee responsible for data protection.
However, data transfer over telephone and the internet may not be absolutely secure, despite the measures implemented. Owing to this, please note that no transmission of data over the internet or via the telephone can be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect personal information, neither we nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk. In no event shall Knowlaxy, its officers, directors, employees, or agents, be liable to you for any direct, indirect, incidental, special, punitive, or consequential damages whatsoever resulting from any content, including any mistakes or inaccuracies therein, personal injury or property damage, of any nature whatsoever, resulting from your use of our website, any unauthorized use of our servers and/or any and all personal information and/or financial information stored therein.
YOUR DATA PROTECTION RIGHTS:
In accordance with the General Data Protection Regulation, our customers have a right to information about their saved data, free of charge. Upon request, we will inform you in writing if and which personal data we have stored about you, in accordance with applicable law.
As per the GDPR and the data protection legislation, you have rights including:
Right of access to the personal data related to you.
Right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Right to erasure /”right to be forgotten”/ – You have the right to ask us to erase your personal information in certain circumstances.
Right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Right to object to processing – You have the right to object to the processing of your personal data (e.g., when we process your data on the grounds of our legitimate interest) in certain circumstances.
Right to data portability – You have the right to ask that we transfer the information you gave us to another organization, or to you, in certain circumstances.
Rights to complain – if you are unhappy with how we have used your data, you can complain to the Bulgarian Personal Data Protection Commission or the respective data supervisory authority in your Member State. However, we strongly recommend that you first get in touch with us in case of any complains as we always strive to resolve any matters timely and in good faith. The Bulgarian Personal Data Protection Commission address is: 2 Tzvetan Lazarov Boulevard, Sofia 1592, Bulgaria.
A list of all supervisory bodies in the EU Member States can be found here: https://edpb.europa.eu/about-edpb/board/members_en.
If you would like further information in relation to your rights or you wish to make a request or exercise your rights, you can do so:
Directly in our website using the contact form;
Via e-mail to: info[at]knowlaxy.com;
By post: to Sofia 1309, Krasna Polyana Region, Ilinden Housing Estate, block 12, entrance 2, floor 1, apt.1, BULGARIA
Please beware that any requests sent via post or courier would necessitate additional verification of your identity by presenting an identity document at our registered address or sending your request via e-mail signed with an electronic signature of a natural person.
You can exercise your rights free of charge. If the request is manifestly unfounded or excessive, we may charge a reasonable fee.
We will respond to you in a month after we receive your request. If we need extra time to respond or if we believe there are reasons why we should decline your request, we will let you know within the same deadline.
HOW TO CONTACT US?
The data controller who operates www.knowlaxy.com is KNOWLAXY OOD, a limited liability company registered and existing pursuant to the laws of the Republic of Bulgaria, with UIC 205522723 having its seat and registered address at Sofia 1309, Krasna Polyana Region, Ilinden Housing Estate, block 12, entrance 2, floor 1, apt.1, BULGARIA.
You can contact us:
via post at the aforementioned address or
directly or our website using the contact form, or
via e-mail at info[at]knowlaxy.com
You can contact our Data Protection Officer (DPO) via post at KNOWLAXY Ltd., Sofia 1309, Krasna Polyana, Ilinden, block 12, entrance 2, floor 1, apt. 1 or via e-mail at http://dpo[at]knowlaxy.com.