We understand that privacy and the security of your personal information is extremely important. This policy sets out what we do with your information and what we do to keep it secure. It also explains where and how we collect your personal information, as well as your rights over any personal information we hold about you. This Policy explains how we do this and tells you about your privacy rights and how the law protects you.
When we refer to "Zenler", we mean the Zenler or New Zenler entity that acts as the Controller or the Processor of your personal information, as explained in detail in the "Identifying the Data Controller and Data Processor" section below.
This Privacy Policy applies to Zenler’s online course platform (the "Services") when interacting with the platform (eg. When you are student/lead/subscriber to a Zenler Site that uses the Zenler application or services), zenler.com, newzenler.com ( the "Website") and other interactions (e.g, when you create an account with Zenler, purchase or signup for a Zenler product or service, sign up to our newsletter, signup to updates, open a support ticket, when you contact us by email or phone or contact us via social media ) you may have with Zenler. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Zenler’s business.
This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Zenler platform ("Third Party Services"), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the "Customer Agreement"), including the processing of any personal data including files or any other content submitted through Services accounts (collectively, "Student Data"). The Zenler Site (e.g., Course Instructor, author, educator, online course creator or another entity or person) that entered into the Customer Agreement ("Customer") controls their instance of the Services (their "Zenler Site") and any associated Student Data. If you have any questions about specific Online School settings and privacy practices, please contact the Customer whose Zenler Site you use. You can use the contact link on your online school or email support@zenler.com to get the contact information of your Zenler Site instructors and administrator(s). If you have received an invitation to join a online school but have not yet created an account, you should request assistance from the Customer that sent the invitation.
This policy also applies to entities( "Affiliate(s)" ) that directly or indirectly controls, is controlled by, or is under common control with the subject entity. "Control" for purposes of this definition means direct or indirect ownership or control of more than fifty percent (50%) of the voting interests of the subject entity.
Data protection law in certain jurisdictions especially in the EU differentiates between the "Data Controller" or "Controller" and "Data processor" or "Processor" of information. In general, Customer is the controller of Student Data. In general, Zenler is the processor of Student Data related to users/students/leads/visitors who use Zenler Site and the controller of Customer Data and Other Information.
Zenler may collect and process Student Data and data about Zenler Customer ("Customer Data") in a different ways:
Students, leads or individuals ("Students") granted access to a Zenler Site by a Customer routinely submit Student Data to Zenler when using the Services. Zenler collects, on behalf and upon instructions of Customer, information relating to Student Data and this may include:
Zenler also collects, generates and/or receives Customer Data when a customer signs up at Zenler Website and create a Zenler Site using Service or order a Zenler product or service or start adding content and this may include.
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this.
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment such as Stripe and Paypal and delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources such as European Commision EU VAT database.
We may receive personal data about you from various third parties and public sources as set out below [Customer can choose to permit or restrict Third Party Services for their Zenler Account]. Typically, Third Party Services are software that integrate with our Services, and Customer can enable and disable these integrations for their Zenler account. When a Third Party Service is enabled, Zenler is authorized to connect and access Other Information made available to Zenler in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services. Third party integrations may include
-Zapier.com
-MailChimp.com
-Google.com
-Facebook.com
-Sendgrid
-Segment.io
-Intercom.io
-Affiliates: Zenler may share Other Information with its corporate affiliates.
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data when legally permitted. The most common uses of your personal data are:
Student Data will be used by Zenler in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Zenler is a data processor of Student Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Zenler Site, enrol to products and configure settings, access, modify, export, share and remove Student Data and otherwise apply its policies to the Services.
Zenler uses Customer Data and Other Information in furtherance of our legitimate interests in operating our Services, Websites and business.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at support@zenler.com
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at support@zenler.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
If you are a Student, we are processing your data as Data Processor of the Customer that invited you to signup at Zenler Site, so we suggest that you read carefully the own privacy policies that such Customer might have established for the use of your data as a Student.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations(PECR), we may send you marketing communications from us if
Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing us at support@zenler.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
We may have to share your personal data with the parties set out below:
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
This is applicable only to users allowing Zenler to connect to their account via the Google API. Zenler's use and transfer of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at support@zenler.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or if you want a copy of our standard data processing addendum, incorporating Model Clauses.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at support@zenler.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Zenler and Zenler Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy
By providing us with your data, you warrant to us that you are over 13 years of age.
We have appointed a Data Protection Officer internally who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Lead using the details set out below.
You can contact Zenler at any time if you have any questions about this Privacy Policy or Zenler’s practices, or if you are seeking to exercise any of your statutory rights.
You may contact us at support@zenler.com or at our mailing address below:
Zenler LtdEmail: support@zenler.com
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us by email on support@zenler.com first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at support@zenler.com OR update your profile in your Zenler or Zenler Site account.