Privacy Policy

Mini Course Generator respects the privacy of its customers (clients) and their data subjects; and want you to understand how we collect, use, and share data about you. This privacy policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data. Unless we link to a different policy or state otherwise, this privacy policy applies when you visit or use the Mini Course Generator web application, APIs or related services (the "Services"). It also applies to representatives of prospective customers of our business and enterprise products.

By using the services as defined in the General Terms and Conditions, you agree to the terms of this privacy policy.

You shouldn't use the services if you don't agree with this privacy policy or any other agreement that governs your use of the services.

1. What data we get

Mini Course Generator collects and processes personal data of customer representatives directly dealing with Mini Course Generator for contractual engagements.

While availing Mini Course Generator application services, customers let Mini Course Generator process personal data of their end users although neither Mini Course Generator nor any sub-processor has direct access to any of their courses or personal data except in the case as mandated for help and support purposes for which the user gives explicit consent.

Mini Course Generator collects certain personal data from you directly, like information you enter yourself, data about your consumption of content, and data from third-party platforms you connect with Mini Course Generator. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.

1.1 Data you provide to us

We collect different data from or about you depending on how you use the services. When you create an account and use the services, including through a third-party platform, we collect any data you provide directly, including:

• Account data. In order to use certain features, you need to create a user account as an admin or learner. When you create or update your account, we process and store the data you provide like your email address, password, and account settings and assign you a unique identifying number.
• Profile data. You can also choose to provide profile information like a full name or company name.
• Shared content. Course content created by admins will be shared among learners. Parts of the services let you interact with other learners or share content including questions/answers in courses, course scores, learners' satisfaction score.
• Communications and support. If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, and other data about you like your name, email address, location, user ID, and any other related data you provide or that we collect through automated means. We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.
• Additional services. If you participate in other services like customer satisfaction surveys, Mini Course Generator and our sub-processor will be able to process your personal data like name and email addresses.

The data listed above is stored by us and associated with your account.

1.2 Data we collect through automated means

When you access the Services (including browsing content), we collect certain data by automated means, including:

• System data. Technical data about your computer or device like your mobile device used, operating system, internet provider, date and time of login and logoff, cookie IDs, IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types.
• Usage data. Usage statistics about your interactions with the Services, including content accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services.
• Approximate geographic data. An approximate geographic location, including information like country, city, calculated based on your IP address.

2. How we get data about you

Data is mostly fed by the admins/learners into the application and stored on our cloud servers. System data like user ID, mobile device used, operating system, internet provider, date and time of login and logoff, cookie IDs will be automatically collected from the end users and processed by the application. Personal data is also processed by our suppliers via their respective applications. We have a legal base either as a contractual requirement, legitimate interest or exclusive consent for the processing of personal data.

3. What we use your data for

We use your data to provide our services, communicate with you, troubleshoot issues, improve and update our services, analyze how people use our services, and as required by law or necessary for safety and integrity. We consider that the legal bases for the processing of your personal data as set out in this privacy notice are as follows:

• Our use of your personal data is necessary to perform our obligations under any contract with you; or
• Our use of your personal data is necessary for complying with our legal obligations; or
• Our use of your personal data is necessary for our legitimate interests or the legitimate interests of our sub-processors. Our legitimate interests are to: run, grow and develop our business; operate our website and provide our services; provide onboarding and support to customers; build relationships with suppliers and partners; for internal administrative and auditing purposes; or
• Consent, to send you certain communications or where you submit certain information to us, or where required to rely upon consent by privacy law.

4. Who we share your data with

With a legal basis for processing personal data like legitimate purpose, we share certain data about you with admins/learners, suppliers (sub-processors) performing services for us, Mini Course Generator affiliates. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data for other business purposes only if we have your exclusive consent. The list of sub-processors is provided in the separate DPA annex.

5. Security

We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it's important to protect your password and to contact us if you suspect any unauthorized access to your account. Mini Course Generator urges its admins and learners to enforce strong password policies. Mini Course Generator strongly urges its customer organizations to integrate SSO with the application for a better access management system.

Mini Course Generator takes appropriate organizational and technical security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. Mini Course Generator deploys industry-standard security solutions and measures for data privacy and security. Mini Course Generator complies with privacy laws like GDPR. Personal data is processed in EU and in case data gets processed by our sub-processor in a non-EU country, DPA with EU standard contractual clauses is in place.

These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Mini Course Generator, the services, or any information provided to us in connection with the data we collect through the services will be free from unauthorized access by third parties. Your credentials are an important part of our security system, and it is your responsibility to protect it.

6. Your rights

You have certain rights around the use of your data, including the ability to opt out of promotional emails, and collection of your data by certain third parties. You can update or terminate your account from within our services and can also contact us for individual rights requests about your personal data. You can choose not to provide certain data to us, but you may not be able to use certain features of the Services. You can access and update your personal data that Mini Course Generator collects and maintains as follows:

• To update data you provide directly, log into your account and update your account at any time.
• You can also delete your profile and personal data instantly.

To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the services, including administrative confirmations, order confirmations, important updates about the services, and notices about our policies.

Mini Course Generator processes data on behalf of its clients (controllers) and the requests from clients regarding rights of their end users will be addressed in line with GDPR guidelines. Mini Course Generator will only access your account upon your request for assistance. You will be asked to provide explicit consent for that. No employee of Mini Course Generator will access your account without prior permission; unless required to do so by law and in such cases, where legally permissible, Mini Course Generator shall inform you.

Mini Course Generator has the option to track and trace the results from your learners. These results will only be visible to the customer, not to anyone else. There is also the possibility to show the high-level aggregated results only. Mini Course Generator does have the right to analyze this data for general trends and figures, but not on a personal or customer level unless that customer has approved or requested that.

7. Retention of personal data

We keep your personal data for no longer than necessary for the purposes for which the personal data is collected and processed. We only retain the contractual agreement data and not the personal data of customer end users. The length of time we retain personal data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.

8. Cookie management

Session cookies are temporary bits of information which are deleted when you exit the application or the website. Session cookies are typically used to improve navigation and to collect statistics. Mini Course Generator portal and the application use session cookies.

Persistent cookies are more permanent bits of information that are stored and remain on your computer/phone until they are deleted by you. Persistent cookies delete themselves after a certain period of time but are renewed each time you visit the website.

9. Updates & contact info

When we make a material change to this policy, changes become effective the day they're posted. If any changes are made, we will notify you by revising the "Updated On" date at the top of this Agreement as and when required. We encourage you to review this Agreement whenever you can, in a timely fashion to stay informed about the changes.

9.1 Modifications to this privacy policy

From time to time, we may update this privacy policy. Unless stated otherwise, modifications will become effective on the day they are posted. As permitted by applicable law, if you continue to use the services after the effective date of any change, then your access and/or use will be deemed an acceptance of the revised privacy policy. The revised privacy policy supersedes all previous privacy policies.

9.2 Questions

If you have any questions, concerns, or disputes regarding our privacy policy, please feel free to contact Mini Course Generator at support@minicoursegenerator.com.