PRIVACY POLICY

General Provisions

This privacy policy regulates the principles regarding the collection, processing, and storage of personal data. Personal data is collected, processed, and stored by the data controller CodeSensus OÜ (hereinafter the data processor). A data subject within the meaning of the privacy policy is a client or other natural person whose personal data is processed by the data processor. A client within the meaning of the privacy policy is anyone who uses the services of the Lesson Learned environment (hereinafter the Environment). The data processor follows the principles of data processing set out in legal acts, among other things, the data processor processes personal data lawfully, fairly, and securely. The data processor is able to confirm that personal data has been processed in accordance with the provisions of legal acts.

Collection, Processing, and Storage of Personal Data

The personal data that the data processor collects, processes, and stores has been collected electronically, mainly through the Environment and email. By sharing their personal data, the data subject gives the data processor the right to collect, organize, use, and manage personal data for the purpose defined in the privacy policy, which the data subject directly or indirectly shares with the data processor when using services in the Environment. The data subject is responsible for ensuring that the data they provide is accurate, correct, and complete. Knowingly submitting false data is considered a violation of the privacy policy. It is recommended that the data subject inform the data processor of changes in their contact details (especially email address) to ensure proper communication and provision of services, including the transmission of payment information. The data processor is not responsible for damages caused to the data subject or third parties due to the submission of false data by the data subject or failure to notify of changes in data. CodeSensus OÜ is the data controller of personal data, CodeSensus OÜ forwards the personal data necessary for making payments to the authorized processor Polar Software Inc.

Processing of Clients' Personal Data

The data processor may process the following personal data of the data subject: First and last name; Email address; User account data. The legal basis for processing personal data is Article 6(1)(b) and (f) of the General Data Protection Regulation: b) processing is necessary for the performance of a 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; f) processing is necessary for the purposes of the legitimate interests pursued by the controller. Processing of personal data according to the purpose of processing: Ensuring the functioning of the Environment's services (retention period - until the closure of the user account or explicit deletion request by the data subject) and customer management (retention period - until explicit deletion request by the data subject or until the end of the legal obligation). The data processor does not transfer clients' personal data to third parties, except in cases provided by law or if it is necessary for the provision of the service (e.g., for payment processing). In processing and storing the personal data of the data subject, the data processor implements organizational and technical measures that ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.

Rights of the Data Subject

The data subject has the right to access and review their personal data. The data subject has the right to receive information about the processing of their personal data. The data subject has the right to supplement or correct inaccurate data. The data subject has the right to request the deletion of their personal data if there is no legal basis for processing it or if the data subject wishes to close their account. The data subject can exercise their rights by contacting the Environment's customer support at info@lesson-learned.xyz. The data subject has the right to file a complaint with the Data Protection Inspectorate to protect their rights.

Final Provisions

These data protection terms have been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), the Personal Data Protection Act of the Republic of Estonia, and the legislation of the Republic of Estonia and the European Union. The data processor has the right to partially or fully change the data protection terms, notifying the data subjects of the changes through the Environment.