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Privacy policy

Privacy Notice

Effective as of May 25, 2018

Here at StudentShare Ltd., a private limited company (registry code HE 364715 TIC 10 364715I; registered office address: Aglantzias, 21 COMPLEX 21B, 2nd Floor, Flat/Office 1, Aglantzia, 2108, Nicosia, Cyprus) we respect your privacy and we are committed to processing personal data of our users/customers in a secure and manner in line with our legal obligations.

This Policy explains how StudentShare Ltd. will use any personal data that we may collect about you when you use our website https://brainbasket.net/ (hereinafter the “Website”).

1. What data we collect

Our Privacy Policy governs the use and storage of your personal data. You can see our Privacy Policy on the website which detail our processing.

StudentShare Ltd. is a Controller of the personal data you (data subject) provide us. We may collect the following types of personal data from you within the following website:

- contact details such as your email address and phone number;

- data that identifies you such as your IP address, login information, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be, operating system and version;

- your birthday details in order to send you special discount offers;

- only 4 last digits of your credit/debit card, merchant unique ID or receipt ID or your payment email account to complete payment transactions for our services via our secure payment processors accounts;

- data on how you use the website such as your URL clickstreams (the path you take through the website), goods/services viewed, page response times, download errors, how long you stay on webpages, what you do on those pages, how often, and other actions.

2. Why we need it

StudentShare Ltd. collects your personal data in order:

- Provide services;

- Keep the website running;

- Improve the website;

- for customer support;

- for marketing purposes (with your consent)

StudentShare Ltd. will not sell or provide your data to any third party where you have not provided your consent to do so. All other data is processed in accordance with the General Data Protection Regulation (GDPR) 2018 and other applicable laws.

3. How StudentShare Ltd. collects personal data:

StudentShare Ltd. collects data when you interact with its website, especially when

- you browse any page of the website;

- StudentShare Ltd. calls you;

- you use the website;

- you receive emails from StudentShare Ltd.;

- you chat with StudentShare Ltd.for customer support;

- you connect integrations;

- you opt-in to marketing emails.

4. What we do with it

Your personal data is processed by StudentShare Ltd., located in Cyprus. Hosting and storage of your data takes place within the European Economic Area (EEA) but our current organizational and administrative structure requires to transfer some part of your data to non-EEA countries, namely - in Kyiv, Ukraine and this data will be processed by the Company’s Research and Development Department. The employees and contractors of the Company’s Research and Development department are bound by the respective agreements, Company’s internal policies and Information Security Policy. All the activities with personal data outside the EEA are performed at the secured premises. Any such transfer of data will only be in connection with the services that StudentShare Ltd. provides and will ensure that the data is protected to a level which meets the requirements of EU law.

By providing your data to us you agree to this transfer taking place.

No third party providers have access to your data, unless specifically required by law, there is a legitimate interest, where you have consented with us to do so, or in order to fulfil our services to you.

5. How long we keep it

StudentShare Ltd. will delete your personal data from the databases no later than 6 years from the last time you used the website according to the effective legislation of the Republic of Cyprus.

6. What are your rights?

You have the right to access to any data that we hold relating to you. Requests must be made in writing and proof of identification is required to protect your data and to ensure it is not disclosed to unauthorised parties.

Should you believe that any personal data we hold on you is incorrect or incomplete, you have the ability to request to see this data, rectify it or have it deleted.

In the event that you wish to complain about how we have handled your personal data, please contact in writing to StudentShare Ltd. We will then look-into your complaint and work with you to resolve the matter.

To look threw the detailed scope of your rights, please, read our Privacy Policy below.

If you still feel that your personal data has not been handled appropriately according to the law, you can contact the Commissioner for Personal Data Protection in Cyprus (http://www.dataprotection.gov.cy) and file a complaint with them.

Privacy Policy

Effective as of May 25, 2018

1.Purpose and Scope

StudentShare Ltd., a private limited company (registry code HE 364715 TIC 10 364715I; registered office address: Aglantzias, 21 COMPLEX 21B, 2nd Floor, Flat/Office 1, Aglantzia, 2108, Nicosia, Cyprus), hereinafter referred to as the “Company”, strives to comply with applicable laws and regulations related to Personal Data protection in countries where the Company operates. This Policy sets forth the basic principles by which the Company processes your personal data, and indicates the responsibilities while processing personal data.

The Company does not knowingly attempt to solicit or receive information from children under 18 years of age.

The Company acknowledges and understands that you are aware of and care about your own personal privacy interests, and the Company takes that seriously. This Privacy Policy describes the policies and practices with regard to the collection and use of your personal data, and sets forth your privacy rights. The Company recognizes that data privacy is an ongoing responsibility, and, therefore, the Company will from time to time update this Privacy Policy and its privacy practice as the Company undertakes new personal data practices or adopt new privacy policies.

2. Company’s website

The Company controls and manages https://brainbasket.net/ – hereinafter the “Website”) which may collect particular data for its business purposes.

3. Definitions of legal bases for the processing

Consent - your clear agreement to the processing of your personal data for a specific purpose.

Contract - the reason why the processing is necessary based on a contract you have with the Company, or because the Company has asked you to take specific steps before entering into that contract.

Legitimate Interests - the reason why the processing your data is necessary which is based on the legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests. These legitimate interests are:

- gaining insights from your behaviour on the Website;
- delivering, developing and improving the Website;
- enabling the Company to enhance, customise or modify the Website and services;
- determining whether marketing campaigns are effective;
- enhancing data security

4. Consent rule

If you have given consent to the processing of your data you can freely withdraw such consent at any time by emailing the Company to support@brainbasket.net.

If you do withdraw your consent, and if the Company does not have another legal basis for the processing of your data, then the Company will stop the processing of your personal data.

If the Company has another legal basis for the processing of your data, then the Company may continue to do so subject to your legal interests and rights.

5. Company’s responsibilities

If you are a registered user or a visitor to the Website the Company acts as the ‘data controller’ of personal data. This means that the Company determines how and why your data are processed.

6. Your responsibilities

Read this Privacy Policy carefully.

If you provide the Company with personal data about other individuals, the Company will only employ that data for the special reason for which it was provided to the Company. By sending the data, you confirm that you have the right to dispose to process the data on your behalf in accordance with this Privacy Policy.

Treat your personal data confidential and secure.

7. Collected data

The Company collects data when you interact with its Website, especially when:

7.1.1. you browse any page of the Website;

7.1.2. the Company calls you;

7.1.3. you use the Website and receive services;

7.1.4. you receive emails from the Company;

7.1.5. you chat with the Company for customer support;

7.1.6. you connect integrations;

7.1.7. you opt-in to marketing emails.

The Company collects the following categories of data:

7.1.8. The Company collects the following categories of data:

  • contact details such as your email address and phone number;
  • data that identifies you such as your IP address, login information, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be, operating system and version;
  • your birthday details in order to send you special discount offers;
  • only 4 last digits of your credit/debit card, merchant unique ID or receipt ID or your payment email account to complete payment transactions for our services via our secure payment processors accounts;
  • data on how you use the website such as your URL clickstreams (the path you take through the website), goods/services viewed, page response times, download errors, how long you stay on webpages, what you do on those pages, how often, and other actions.

The recipients of the collected data are the highest management level of the Company, its employees and contractors, and other third party service providers mentioned below.

The Company stores your billing data, such as 4 last digits of your credit/debit card, merchant unique ID or receipt ID or your payment email account exclusively in order to receive acknowledgment on successful payment transactions for our services from our secure payment processors accounts according to the rules and regulations of such payment processors. The Company shall not transfer your billing data to any third parties.

8. Purposes and legal basis for the processing

The Company processes the data for:

8.1.1. Providing Services:

  • Details: the Company needs to provide services accessible via the Website.
  • Legal basis: Consent; Contract; Legitimate Interests.

8.1.2. Keeping the Website running:

  • Details: managing your requests (like orders), login and authentication, remembering your settings, processing payments, hosting and back-end infrastructure.
  • Legal basis: Contract; legitimate Interests.

8.1.3. Improving the Website

  • Details: testing features, interacting with feedback platforms and questionnaires, managing landing pages, heat mapping the Website, traffic optimization and data analysis and research, including profiling and the use of machine learning and other techniques over your data and in some cases using third parties to do this.
  • Legal basis: Contract; legitimate Interests.

8.1.4. Customer support

  • Details: notifying you of any changes to the service, solving issues, any bug fixing.
  • Legal basis: Contract; Legitimate Interests.

8.1.5. Marketing purposes (with your consent only)

  • Details: sending you emails and messages about new functions, goods and services, and content.
  • Legal basis: Consent.

8.1.6. Preventing fraud

  • Details: evercookies. Evercookies are a javascript API available that produces extremely persistent cookies in a browser which help us identify that no user creates additional account
  • Legal basis: Legitimate Interests.

9. Your rights

You may choose not to provide the Company with personal data. If you choose to do so, you can continue to visit the Website and browse its pages, but the Company will not be able to provide its services and process transactions without personal data.

You may turn off cookies in your browser via settings. You can block cookies on your browser refusing cookies. You may delete cookies. If you turn off cookies, you can continue to use the Website and browse its pages, but the Website and certain services will not work properly.

You may ask us to refrain from using your data for marketing. You can opt out from marketing by emailing us at support@brainbasket.net.

You can exercise the following rights by sending us an email at support@brainbasket.net.

9.1.1. You have the right to access information about you, especially:

- the categories of data;
- the purposes of data processing;
- third parties to whom the data disclosed;
- how long the data will be retained and the criteria used to determine that period;
- other rights regarding the use of your data.

9.1.2. You have the right to make the Company correct any inaccurate personal data about you.

9.1.3. You can object to the Company using your personal data for profiling you or making automated decisions about you. The Company may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behaviour).

9.1.4. You have the right to the data portability of your data to another service or Website. The Company will give you a copy of your data in readable format so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you.

9.1.5. You have the right to be “forgotten”. You may ask erasing any personal data about you, if it is no longer necessary for the Company to store the data for purposes of your use of the Website.

9.1.6. You have the right to lodge a complaint regarding the use of your data by the Company. You can address any complaint to the Commissioner for Personal Data Protection in Cyprus (http://www.dataprotection.gov.cy).

In the context of the right to access information the Company shall provide you with the information within one month of your request unless there is a justified requirement to provide such information faster.

10. Security

We have security and organizational measures and procedures to secure the data collected and stored. We have security policies and data processing agreements with all our employees and contractors who are obliged to follow and maintain appropriate technical and organisational measures. We have internal Information Security Policy.

Connections to the Website are encrypted using 256-bit SSL with integrity assured by the SHA2 ECDSA algorithm.

We use servers that comply with strict international data security standards, including ISO 27001.

We use servers that are certified under PCI DSS Level 1, ISO/IEC 27001:2013, SOC 1 type II.

You acknowledge that no perfect security infrastructure exists, no data transmission is guaranteed to be 100% secure, and there may be some security risks.

You are responsible for your login information and password. You shall keep them confidential.

In case if your privacy has been breached, please contact the Company immediately on support@brainbasket.net.

11. Location of the processing of personal data

The personal data collected by the Company is processed at the Company’s offices in Nicosia. The Company is international and can have foreign branches and departments. The Company’s Research and Development department is based in Kyiv at secure premises. The employees and contractors of the Company’s Research and Development department are bound by the respective agreements, Company’s internal policies and Information Security Policy.

Our servers for storing the data are located in Germany.

12. Retention period

The Company will delete your personal data from the databases no later than 6 years from the last time you used the Website according to the effective legislation of the Republic of Cyprus.

13. Transfer of your personal data

The Company has departments outside the EEA, especially the Company’s Research and Development department is based in Ukraine, Kyiv, therefore, some data the Company collects from you will be processed in Ukraine. Ukraine has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR.

The Company relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, the Company collects and transfers to Ukraine personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of the Company in a manner that does not outweigh your rights and freedoms. The Company endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with the Company and the practices described in this Privacy Policy. The Company also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.

14. Cookies

Cookies are pieces of data that a Website transfers to a user's hard drive for record-keeping purposes.

The Company uses cookies to provide proper functionality on the Website and aggregate traffic data (e.g., what pages are popular). The Company may use evercookies with reference to Legitimate interest only.

The Company uses the following types of cookies:

  • Strictly needed cookies. These cookies are necessary for the Website to work correctly. They will allow you to move our Website and use its capabilities. These files do not identify you as a person. If you do not agree to use this type of file this may affect the proper work of the Website or its components.
  • Cookies related to performance, efficiency, and analytics. These files help us understand how you interact with our Website by providing information about the areas visited and the amount of time spent on the Website, as well as showing problems in the operation of the Internet resource, for example, error messages. This will help us to improve the work of the Website.
  • Cookies related to analytics. These files help us to measure the effectiveness of advertising campaigns and optimize the content of Websites for those who are interested in our advertising. This type of cookies shall not be used for Your identification. All information that is collected and analyzed is anonymous.
  • Advertising cookies. These cookies record information about Your online activities, including visits to our Website, as well as information about the links and advertising that you have chosen to view. The Company uses such files to collect data about your activity on the Internet and determine your interests, which allows the Company to provide advertising that suits your interests and on which you have given your consent.

The Website capture limited data (user-agent, HTTP referrer, last URL requested by the user, client-side and server-side clickstream) about visits to the Website. The Company may use this data to analyze patterns and to perform system maintenance. You have several options how to manage cookies on your device. All browsers allow you to block or delete cookies from your device. You may consult the privacy features in your browser to understand what you should do if you need to manage cookies.

15. Contact details of the Data Controller

StudentShare Ltd.

Registry code HE 364715,

Aglantzias, 21 COMPLEX 21B, 2nd Floor, Flat/Office 1, Aglantzia, 2108, Nicosia, Cyprus

Email: dpo@brainbasket.net



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