CONSTRUCTOR ACADEMY PRIVACY NOTICE

With this privacy notice, we, Constructor Academy AG, a company duly registered under the laws of Switzerland, with a registered office at Lintheschergasse 7, 8001 Zurich, Switzerland, and registration number CHE-246.121.247 ("we" or "us"), aim to elucidate how we collect and process personal data from our customers using our website and services. Constructor Academy AG is an integral part of the Constructor Group and is affiliated with Constructor Learning AG, a company duly registered under the laws of Switzerland, with a registered office at Rheinweg 9, 8200 Schaffhausen, Switzerland, and registration number CHE-422.961.341, and Constructor Academy GmbH, a company duly registered under the laws of Germany, with a registered office at Landsberger Str. 110, c/o Acronis Germany GmbH, 80339 München, Germany, and registration number HRB 263701 (collectively referred to as "Affiliates"). Together, Constructor Academy AG and its Affiliates offer educational programs, courses, and related services ("Services") to professionals. The data protection regulations are an integral component of our Terms and Conditions. Capitalized words hold the same meaning as defined in the currently effective Terms and Conditions. Our Privacy Notice encompasses information about the data we collect in connection with our services and details how our website automatically gathers information.

1. what this privacy notice covers

This Notice is applicable to Visitors, Constructor Academy's Prospective Clients, Clients, and Partners ("individuals" or "you") in the course of utilizing our services or visiting our websites, including the academy.constructor domain (website). This Notice pertains to personal data, as defined below in Section 2, which we collect to provide you with services. It is important to note that this Notice does not extend to anonymized, de-identified, or aggregate information if it does not qualify as personal data. The rights detailed in this Notice outline the scope of control you have over our use of your data. The use of personal data collected through our services is restricted to the purposes of delivering the services for which you have engaged us, as outlined in this Notice, and otherwise subject to your consent. Some information provided to us may, either independently or when correlated with other information accessible to us, uniquely identify you. Should you disagree with the policies and practices articulated in this Notice, we kindly request that you refrain from using our services, visiting our website, and abstain from providing your information to us. Under the General Data Protection Regulation (EU) 2016/679 (GDPR), our role may vary between Data Controller and Data Processor (including Data Subprocessor) depending on the nature of the processing of your personal data. Further details on our distinct roles are expounded upon in the subsequent sections. If you are a prospective or current employee of Constructor Academy, be aware that this Notice does not pertain to you. For information regarding your privacy rights and our privacy practices, please consult Our employment guide.

2. what personal data we process and how

Personal data refers to information related to an identified or identifiable natural person. An identifiable natural person is someone who can be directly or indirectly distinguished, particularly through an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. Personal data explicitly excludes any anonymized and depersonalized data where identity is absent or has been eliminated and is irrevocably unrecoverable. The following delineates the categories of information, encompassing personal data, that we may collect or share for a business purpose, as permissible by law and contingent upon the services you receive: (a) Information provided voluntarily by you: Contact information: This category encompasses details such as your name, business email address, phone number, photograph, billing information, physical address, as well as information related to communication services such as Telegram, Zoom, WhatsApp, Skype, and similar platforms. It also includes call recordings and any information you input into open text fields in help/contact forms. Depending on the services you utilize, you may choose to supplement your profile with additional information, including a display name, profile photo, educational background, diplomas, job title, and other relevant details. Content information: This pertains to information that you may opt to post, send, receive, or share within our services. Examples of content information encompass the content viewed in the services, training interactions, files and links uploaded, and aggregate insights derived from this information. Customer support information: This includes a summary of the issues you are experiencing and any additional documentation or information that would aid in resolving a submitted issue. Notably, we do not collect payment information, such as credit card details, but delegate the management of such information to our payment providers. (b) Information automatically collected: Analytics information: This category covers data collected when you visit and interact with any of our services. This information includes the features you use, links clicked, type, size, and filenames of attachments uploaded to the services, frequently used search terms, and interactions with third-party integrations and others on the services. Device information: This encompasses details about your connection type and settings, operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash activity. Such information is collected through cookies, web beacons, and similar technologies. (c) Information received from other sources: From time to time, we may receive information about you from:

Other users
Third-party providers
Our affiliates
Professional social networks and publicly accessible websites
Third-party integrations established with Constructor Academy
Business partners

We collect this information only where these third parties are legally permitted or required to share your personal information with Us. In instances mandated by law, we promptly inform you of such information collection.

How we use your personal data and which legal basis we rely on

We collect and process personal data for a variety of purposes, including:

Type of Personal Data	Purpose of Use	Legal Basis
Contact Information	To send you an order confirmation and invoice you accordingly To process payments To administer your account To provide the services to you To respond to customer service requests To give you access to a Constructor Academy Community and connect with other users To manage instructor information	Performance of a contract with you
Contact Information	To establish and manage our relationship with you For safety and security to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of service policies	Our legitimate interests
Contact Information	To send you marketing communications and newsletters To conduct surveys and evaluate customer satisfaction To interact with or use third-party tools or integrations	Our legitimate interests, or, if required under applicable law, to the extent you have provided your consent
Contact Information	To manage registrations at our events (e.g. conferences, webinars) and customer participation Recording calls for training and quality assurance purposes	Your consent to process your data
Contact Information	To comply with legal obligations, including the cases where we need to respond to requests by government or law enforcement authorities To protect our legitimate business interests and legal rights	To comply with a legal obligation
Customer Support Information	To resolve technical issues, to respond to requests for assistance To manage cancellations and refunds	Performance of a contract with you
Customer Support Information	To analyse bug/crash information	Our legitimate interests
Customer Support Information	To improve the services	Our legitimate interests or your consent
Analytics Information	To troubleshoot and to identify trends, usage, activity patterns, and areas for integration and improvement of the service To monitor suspicious or fraudulent activity and to identify violations of terms of use or agreements	Our legitimate interests
Analytics Information	For research and development of our service	Our legitimate interests or your consent
Device Information	Display content based on your interests For advertising purposes To develop and improve our websites	Our legitimate interests, or, if required under applicable law, to the extent you have provided your consent

3. children’s privacy

We do not knowingly collect or solicit information from minors. Children, as defined under the applicable data privacy laws, may only access or use our services with their consent and under the supervision of a parent or legal guardian who agrees to be bound by this Notice. If you are a parent or legal guardian of a child, you agree to be fully responsible for the acts or omissions of such user in connection with access to and use of the services.

4. how long we keep your personal data

We retain personal data about you that is necessary to fulfill the purpose for which that information was collected, consistent with applicable laws. We generally retain information regarding our services for a year from the date of our last interaction, account closure, etc., in compliance with our obligations under applicable laws, or for a longer period if required to do so according to our regulatory obligations or where we believe it is necessary to establish, defend, or protect our legal rights or those of others. When we destroy your personal data, we do so in a way that prevents that information from being restored or reconstructed.

5. cookies, tracking information and social media widgets

When you initially visit our website, you will be prompted to either consent to or reject the use of cookies and the collection of data through cookies and similar tracking technologies. We refrain from utilizing cookies until you explicitly provide consent or opt-in through the Cookie Preferences option available here. The following types of cookies are employed on our website: Strictly Necessary Cookies: These cookies are indispensable for the functioning of websites (including subdomains) within our website and services. They cannot be disabled within Constructor Academy's services. Typically, we set strictly necessary cookies in response to actions that constitute a request for services, such as configuring privacy preferences or completing forms. You have the option to configure your browser to block or notify you about these cookies, although this may impact certain parts of the website or services. Functional Cookies: These cookies enable the website to offer enhanced functionality and personalization. While some functional cookies are set by Us, others are set by third-party providers whose services are integrated into the website. Failure to allow functionality cookies may result in the impaired functioning of the website relying on these cookies. The information collected by these cookies may be anonymous and is not used to track your browsing activity on other websites. Performance Cookies: These cookies enable Constructor Academy to track visits and traffic sources to measure and enhance website performance. Performance cookies assist Us in understanding the relative popularity of various website pages and how visitors navigate the site. The information collected by these cookies is aggregated and anonymized. Disabling performance cookies prevents Us from monitoring website visits, hindering our ability to improve services and user comfort. Targeting Cookies: Our advertising and marketing partners may set targeting cookies based on the parts of the website you visit. These cookies enable our partners to build a profile of your interests and display relevant advertisements on the website. Targeting cookies may involve the processing of personal data under certain privacy laws. Rejecting targeting cookies may result in fewer targeted advertisements on the website. These cookies solely assess your interactions with our website. In compliance with applicable law, we may incorporate visible and invisible image files in our newsletters and other marketing emails. Retrieving these image files from our servers allows Us to determine if and when you opened the email, aiding in measuring and understanding your use of our offers for customization. This feature can usually be disabled in your email program, often as a default setting. In addition to cookies, we, along with our marketing partners, affiliates, or analytics/service providers, utilize technologies like beacons, tags, scripts, and similar methods to analyze trends, administer the website, track user movements, and gather demographic information about our user-base. Reports may be generated based on the use of these technologies on both individual and aggregated levels. We may collaborate with third parties to display advertising on our website or manage advertising on other sites. These third-party partners may use technologies, such as cookies, to collect information about your activities on our website and other sites for personalized advertising. Please refer to the privacy statements of these companies for details on how your personal data is processed. Our website features social media components, such as the Facebook Like button, and widgets, like the 'Share This' button, or interactive mini-programs that operate on our websites. These features may collect your IP address, the specific page you are visiting on our website, and may set a cookie for proper functionality. Social media features and widgets are either hosted by third parties or directly on our website. Refer to the privacy statements of these companies to understand how your personal data is processed.

6. how we share your personal data

We only disclose your personal data:

At your request
To the extent required by law
To our business partner with your consent
To our business partner based on our contractual liability
To our service providers for the business purpose(s) described below

Our employees process your data within the scope of their job responsibilities, following the principle of necessity. Our employees are located worldwide. If you have any questions or would like to know from which countries your data can be accessed, please contact us. We may share personal data listed in Section 2 of this Notice:

With your consent: We may disclose your personal data when you provide consent and intentional direction. For instance, when you request content or register for an event, you consent to receiving marketing communications from Us and our third-party partner or co-sponsor of that content or event. Consent for children younger than 16 years old (or lower as required by law) must be given by the parent or guardian. You may always opt-out of receiving marketing communications by unsubscribing or submitting a privacy rights request. Please contact us.
Related to legal proceedings: We will share your information, including personal data, to respond to investigations, court orders, legal processes, or to investigate, prevent, or act regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, violations of Constructor Academy's Terms of Service, or as otherwise required by law. If we are required by law or an order of a court of competent jurisdiction to disclose your information, we will promptly notify you of this requirement, if permitted by the court or applicable law, so that you may seek a protective order or other appropriate relief.

With service providers or data sub-processors: We may share personal data with our service providers, who help Us provide the services, such as cloud storage, security, application communications, customer support, backup, and data analytics. Please refer to the complete list of our sub-processors to know more. Processing of personal data by such third parties is governed by data processing agreements we have in place.

Complete list of our sub-processors

Introduction to Subprocessors

At Constructor Academy, delivering excellence in our services is of paramount importance. To achieve this, we engage with a meticulously selected group of subprocessors. These entities play a crucial role in supporting various facets of our operations, encompassing infrastructure services, as well as customer support and notifications. Our commitment to privacy and security is unwavering, as evidenced by our rigorous due diligence process prior to engaging any subprocessor. Each subprocessor is bound by a meticulously crafted agreement delineating their responsibilities, ensuring the utmost protection of your data without compromise. These agreements provide privacy assurances on par with the high standards upheld at Constructor Academy. Listed below, you will find a comprehensive roster of our esteemed subprocessors, accompanied by concise descriptions of their contributions to enhancing our services. Should you have any additional inquiries or concerns regarding our subprocessors, please do not hesitate to contact us.

Infrastructure subprocessors:

Entity Name	Purpose of Processing	Location of Subprocessors	Additional Details
Google Cloud Platform	Cloud data hosting provider	USA	Google Cloud privacy policy
G Suite (Google Apps)	Office productivity tools	USA	Google privacy policy
Microsoft	Office products	Germany	Microsoft privacy and data access
Digitalocean	Cloud hosting	USA	Digitalocean privacy policy
Heroku	Cloud hosting	USA	heroku privacy policy

Platform subprocessors:

Entity Name	Purpose of Processing	Location of Subprocessors	Additional Details
YouTube	Video hosting service	USA	Google privacy policy
Google Tag Manager ("GTM")	Tag management system	USA	Google privacy policy
Google Analytics	User Tracking and Analytics system	USA	Google privacy policy
Atlassian	Work/Project Management Tools	USA	Privacy policy
Notion	Collaboration tool	USA	Privacy policy
Accredible	Service to issue certificates to students	USA	Privacy policy
Discord	Communication	USA	Privacy policy
Whatsapp	Communication	USA	Privacy policy
Alemira	LMS for delivering courses	Switzerland	Privacy policy
WildiX	Internet mobile operator in Germany	Estonia	Privacy and cookie policy
Vimeo	Video hosting service	USA	Vimeo privacy

Customer support subprocessors:

Entity Name	Purpose of Processing	Location of Subprocessors	Additional Details
Facebook Pixel (Ads)	User Tracking and Analytics service	USA	Facebook privacy policy
Linkedin	Social network for communication	Ireland	Linkedin privacy policy
Xing	Social network for communication	Germany	Xing privacy policy
HubSpot	CRM platform for marketing automation	USA, Ireland	hubSpot privacy policy
Zoom	Communication and events handling service	USA	Zoom privacy statement
Hotjar	User experience optimization service	EU, USA	hotjar privacy policy
LinkedIn Insight Tags	Website visitor tracking	USA	LinkedIn terms and cookie policies

Business operations subprocessors:

Entity Name	Purpose of Processing	Location of Subprocessors	Additional Details
Stripe	Payment collection and processing	Ireland	Privacy policy
Paypal	Payment collection and processing	Ireland	Privacy policy
Printzessin	Printing agency for Christmas cards	Germany	Printzessin privacy policy

Affiliates and Service Expansion

In certain cases, based on the geographic location of our valued Customers or their Authorized Users, as well as the specific Services provided, Constructor Academy may enlist one or more of its trusted Affiliates to act as Subprocessors in delivering a portion or the entirety of the Services.

Updates

As Constructor Academy continues to flourish and adapt to meet the evolving needs of our community, our selection of subprocessors may undergo changes. We are committed to keeping you informed about any new subprocessors, in accordance with the terms outlined in our Agreement. Regular updates will be posted on this page. We encourage you to revisit this section frequently to stay abreast of any developments.

Merger, acquisition, sales: If we are involved in a merger, acquisition, restructuring, or sale of all or a portion of its assets, equity, or similar transaction, personal data may be transferred to the acquiring person or entity. We will use reasonable efforts to direct the acquiring person or entity to use your personal data in a manner that is consistent with our Privacy Notice.

7. HOW WE PROTECT YOUR INFORMATION

The security of your personal information is of utmost importance to us. We adhere to generally accepted security standards and have implemented commercially reasonable security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access. Third-party products and services may be used to secure or store your information. Depending on your place of residence, you may have a legal right to be notified in the event of a security breach. We may, subject to applicable law, transfer your information outside the country where you are located, and to jurisdictions with differing information protection standards (e.g., your information may be stored on servers located in other countries). We will employ appropriate safeguards governing the transfer and usage of your personal information. Please refer to Section 9 for further details. We will never request your account credentials. It is imperative that you do not share your Constructor Academy’s Constructor Platform account information, including your username and password, with anyone else. We strongly recommend using a unique password for your Constructor Platform account that is not associated with other websites. Regularly check your Constructor Academy’s Constructor Platform account to ensure that your personal data has not been tampered with or altered. Only use the services within a secure environment. If, at any point, you have reason to believe that your interactions with the services are no longer secure, please notify Us immediately at privacy@constructor.org.

8. how we transfer your data

Your personal data may be transferred to, and processed in, countries other than the country in which you are based, where our affiliates, subsidiaries, partners, or our third-party service providers operate. Some of these countries might not be considered adequate by the European Commission and therefore may not offer an adequate level of protection and security. Consequently, we take measures to ensure that your information is safe and protected in compliance with applicable data protection laws. These measures include:

Reliance on standard contractual clauses: We use Standard Contractual Clauses to transfer your data outside the European Economic Area, United Kingdom, and Switzerland.
Implementation of organizational, contractual, and technical security measures: We have implemented organizational, contractual, and technical security measures with our third-party service providers to safeguard your data.
Establishment of intra-group data transfer agreement: Internally, within our group of companies around the world, we have established an intra-group data transfer agreement for the transfer of personal data.

9. your privacy rights

You may exercise specific choices regarding your personal data as permitted under applicable privacy laws. These choices are generally free of charge unless otherwise allowed by the law. We may request additional confirmation of your identity and reserve the right to limit our response to your requests in accordance with applicable law. Individual Privacy Rights Your privacy rights encompass: Right to be informed: You have the right to be informed about the collection and use of your personal data. This includes the right to request a copy of the standard contractual clauses, which should encompass completed and signed annexes, excluding any confidential information, business secrets, and personal data of third parties if we process your personal data based on such terms and conditions with other data processors. Right to access: You have the right to view and request copies of your personal data. If you have an online account or profile with Us, you may access your personal data through your account on the website or mobile app. Right to rectify or correct: You have the right to update the personal data that we have collected about you, directly or indirectly. This includes personal data collected by a service provider or contractor on our behalf. If you have an online account or profile with Us, you may update your personal data by accessing your account through the website and mobile app. Right to request erasure (right to be forgotten): You may request that we delete your personal data, subject to certain limited exceptions. For example, we may retain an archived copy of your records consistent with applicable law, to comply with legal obligations, or for other legitimate business purposes. We will use commercially reasonable efforts to honor your requests. Right to data portability: You have the right to request that we transfer data we have collected to another organization, or directly to you under certain conditions. Right to restrict processing: You have the right to request that we restrict the processing of your personal data under certain conditions. Right to withdraw consent: You have the right to withdraw previously granted consent to process your personal data. Right to object to processing: You have the right to object to our processing of your personal data, under certain conditions. Right to object to automated processing: You have the right to object to decisions being made with your information solely based on automated decision-making or profiling. We do not currently engage in automated decision-making or profiling. To exercise any of your above rights, you may submit your request at privacy@constructor.org. Constructor Academy service-related communications We may send a welcome email to clients for billing purposes, and at times may send service-related announcements. Clients may not opt out of service-related emails, as this is part of our services. Marketing communications You may choose to stop receiving our newsletter or marketing emails or texts by following the unsubscribe instructions included in each of these emails or texts, or you can contact us.

PRIVACY QUESTIONS AND CONCERNS

To speak with or file a complaint with our Data Protection Officer, please contact us. You may also lodge a complaint with your supervisory authority. If you are an individual located in the EU, UK, or Switzerland, please consult the following websites to determine the supervisory authority applicable to you:

10. third party links and applications

Our website contains links to other websites, and their privacy practices may vary from those of Constructor Academy. If you choose to submit information to any of those sites, please be aware that your information will be subject to the privacy policies specific to those sites. We strongly recommend that you carefully review the privacy notice of any website or application you visit.

11. publicly accessible parts of our website

Our website provides publicly accessible blogs and community forums. Please be aware that any information you share in these areas may be read, collected, and used by other users. If you wish to request the removal of your personal data from our blog or community forum, please contact us.

12. changes to our privacy notice

We reserve the right to amend this Notice at our discretion and at any time. We will do so by updating this Notice. Amended terms take effect upon being incorporated into this Notice, and your continued use of the website or association with your employer following the posting of any changes constitutes acceptance of any updated terms. If the changes materially affect the way we use your personal data in connection with services that we have already collected, we will notify you or your employer. You can always find the latest version of this Notice on our website: https://academy.constructor.org/privacy.

13. contact information

If you have any questions or comments about this Notice, the ways in which we collect and use your information, your choices, and rights regarding such use, if you wish to exercise your rights under the General Data Protection Regulation (GDPR), or if you want to contact our Data Protection Officer, please email us at privacy@constructor.org.

Effective from: 1.11.2023