ITpreneurs Privacy Policy for End Users

Last Modified: April 2021

ITpreneurs is committed to protecting your privacy and ensuring you have a positive experience  on the ITpreneurs Portal and in using ITpreneurs Services.

This Privacy Policy explains how ITpreneurs Nederland B.V. (“ITpreneurs”, “We”, “Us”, “Our”,  “Portal”, and/or “Shine”) collect, use and store personal information when you visit our websites,  or when you use our Products and Services. It also explains the specific ways we use and  disclose that information.

This policy may be updated from time to time, and our websites will indicate when the policy has  been updated. You may access the current version at any time by clicking on the “Privacy  Policy” link in the footer on our websites. If you do not agree to this Privacy Policy, please do not  use the ITpreneurs Portal “Shine”.

Unless otherwise defined in this Privacy Policy, the capitalized terms shall have the same  meaning as used in the other documents in the ITpreneurs Portal Terms and Conditions.

1. ITpreneurs Collects Data

1.1. We may collect personal information from sources including:

○ Directly from your Organization, where we process your personal information as a Data  Processor on behalf of your Organization, who is a Data Controller;

○ Through our website;

○ Through Third-Party Services Providers;

○ As part of us executing our services on behalf of Training Providers operating on the  Portal who require your personal information in order to fulfil services to you, like for  example schedule your exam.

○ Through Third-Party sources such as social media platforms, and our joint marketing  partners.

1.2. ITpreneurs Collects the Following Information. The types of personal information we  may collect include:

1.2.1. Contact information, such as name, email address, business address, and  telephone number.

1.2.2. End User information, such as name, email address, native language, time  zone

1.2.3. Account information, such as username and password.

1.2.4. Payment Services information, such as your banking details and billing  address.

1.2.5. Verification information pertinent to your organization, such as VAT number,  electronic signature, company registration identifier, and certificate of

incorporation.

1.2.6. Accreditation information pertinent to your organization or yourself, relevant for  purchasing Items that may only become available upon your accreditation or  registration with ITpreneurs.

1.2.7. Communication information, when you are communicating with other users on  the Portal, we collect information you share. This also includes you providing  feedback or ratings on the ITpreneurs Portal.

1.2.8. Fulfillment information, this includes the information we need in order to fulfil  services to you, or other information we need in order to complete the fulfilment  of Items. Fulfillment information may include information from you, or

information about the locations we are required to deliver Items to.

1.2.9. Other information. You may otherwise choose to provide us information when  you fill in a form, conduct a search, complete a survey, update or add

information to your Account, respond to emails from us, participate in

promotions or loyalty programs, or use other features on ITpreneurs.

1.3. Information you voluntarily provide to us. When you sign up for, and use ITpreneurs  Products and Services, consult with our Customer Solutions Team either by phone or  using a virtual conference application, send us an email, you are voluntarily giving us  information that we collect. That information may include either your or your End Users’  name, email address, IP address, phone number, credit card information, physical  address, as well as details including gender, location, purchase history, and other  demographic information. By giving us this information, you consent us to this  information being collected, used, disclosed, stored by us, as described in the End User  License Agreement and in this Privacy Policy.

1.4. Information we collect automatically. When you use ITpreneurs Products and  Services or browse one of our websites, we may collect information about your  visit to our websites, your usage of the Services, and your web browsing. That  information may include your IP address, your operating system, your browser  ID, your browsing activity, and other information about how you interacted with  our Websites or other websites. We may collect this information as a part of log  files as well as through the use of cookies or other tracking technologies. Our use  of cookies and other tracking technologies is discussed in our Cookies Policy. View here.

1.5. Information from your use of the Service. We may receive information about how  and when you use Products and Services, store it in log files or other types of files  associated with your account, and link it to other information we collect about you. This  information may include, for example, your IP address, time, date, browser used, and  actions you have taken within the application. This type of information helps us to  improve our Services for both you and for all of our users.

1.6. Information from End User’s use of the Service. We use the Personally Identifiable  Information that we collect from YOu when You access any online products including  exams hosted on the ITpreneurs Portal. This is meant for processing purposes,  including but not limited to tracking attendance, progress, and completion. We may also  share Your Personally Identifiable Information and performance in a given Course with  your Organization or with the Training Provider who has a contractual agreement with  Your Organization for accreditation and fulfillment of a contract

2. How ITpreneurs uses information.

2.1. We use, store, and process information about you to provide, understand, improve, and  develop the Platform, and to create and maintain a trusted and safe environment. 2.2. Information from You may be shared with other users on the Platform, or with Third Party Service Providers that perform certain services on our behalf, in connection to  fulfilling services to you

2.3. Training Providers and other Third-Party Service providers may have access to  personal information needed to perform their functions but are not permitted to share or  use such information for any other purposes unless this is specifically required by law,  or in order for Training Providers or other Third Party Service Providers to comply with  accreditation or registration requirements.

2.4. We may use and disclose Personal Information only for the following purposes: 2.4.1. To send you System Alert messages. For example, we may inform you of  temporary or permanent changes to our Services, such as planned

outages, new features, version updates, releases, and changes to our

Privacy Policy.

2.4.2. To communicate with you about your user account on the Portal and  provide customer support.

2.4.3. To enforce compliance with our End User License Agreement and  applicable law. This may include developing tools and algorithms that

help us prevent violations.

2.4.4. To protect the rights and safety of our Training Providers and third  parties, as well as our own.

2.4.5. To provide information to representatives and advisors, including  attorneys and accountants, to help us comply with legal, accounting, or

security requirements.

2.4.6. To transfer your information in the unlikely event of a sale, merger,  consolidation, liquidation, reorganization, or acquisition. In that event, any  acquirer will be subject to our obligations under this Privacy Policy,

including your rights to access and choice. We will notify you of the

change either by sending you an email or posting a notice on our

Website.

2.5. Data Collected by Training Providers

2.5.1. End Users data shall not belong to ITpreneurs and shall not be used by  ITpreneurs for marketing, communication or other commercial purposes,  except in situations where You may require support to access or use

Items available from ITpreneurs.

2.5.2. We shall at all times comply with relevant European data privacy  directives that are applicable to Leapest. We value your information, and  take reasonable measures to protect your information.

2.5.3. We reserve the right to view or remove your content for any reason at our  discretion. Reasons may include quality assurance, accreditation

requirements, contractual requirements or legal requirements (for

example if we believe or have received evidence that your use of Shine is  unlawful, unauthorized, or otherwise may result in a liability to us or

anyone else).

3. Training Providers responsibility related to data collected through the ITpreneurs  Platform

3.1. In agreeing to use the Shine platform, ITpreneurs Customers and Your Organization  represent and warrant that their use of Shine will comply with all applicable data privacy  laws. They are responsible for determining whether their use of the Portal is suitable in  light of regulations like HIPAA, GLB, EU Data Privacy Laws, or other laws.

4. General use of Portal data

4.1. If You no longer want any personal data to be stored by Shine, and your account is  managed by Your Organization, you have to inform Your Organization. If an End User  contacts ITpreneurs to remove his/her personal data, we will pass on the request to  Your Organization who acts as the Data Controller within a reasonable time. It is the  responsibility of Your Organization to act on the request. In all other cases ITpreneurs  will remove your personal data within a reasonable time.

4.2. ITpreneurs will retain personal information we process on behalf of our Customers for  as long as needed to provide our services, or to comply with our legal obligations,  contracts, resolve disputes, prevent abuse, or enforce our agreements. There are  several trainings and certifications that you might take on Shine that require us to keep  your data in our records as part of the service agreements and regulations with  accrediting bodies, under which ITpreneurs operates. In such cases, it wouldn’t be  possible for us to delete your personal data without the specific written guidance  received from accrediting organizations.

5. Third-Party Services Providers

5.1. We use a variety of third party service providers to help us provide services related to  the Platform. Service providers may be located inside or outside of the European  Economic Area (“EEA”).

5.1.1. For example, service providers may help us: (i) verify or authenticate your  identification, (ii) check information against public databases, (iii) assist us  with background checks, fraud prevention, and risk assessment, or (iv)

provide customer service, fulfillment, or payments services. These

providers have limited access to your information to perform these tasks  on our behalf, and are contractually obligated to use it in a manner

consistent with the ITpreneurs Privacy Policy.

5.2. ITpreneurs Payment Services. ITpreneurs may contract with other companies to  provide payment services and facilitate your use of the Platform. We provide these  companies with only the information they need to perform their services and work  closely with tem to ensure your privacy is respected and protected. These companies  are prohibited by contract from using this information for their own marketing purposes  or from sharing this information with anyone other than ITpreneurs.

We use a Third Party payment processor to process payments made to us. In  connection with the processing of such payments, we do not retain any personally  identifiable information or any financial information such as credit card numbers.  Rather, all such information is provided directly to our Third Party processor depending  on your location, whose use of your personal information is governed by their  respective privacy policies. Your credit card data is tokenized and is not being retained  by ITpreneurs.

5.3. ITpreneurs Fulfillment Services. ITpreneurs may share your personal information to  provide fulfillment services and facilitate your use of the Platform.We provide these  companies with only the information they need to perform their services and work  closely with tem to ensure your privacy is respected and protected. These companies  are prohibited by contract from using this information for their own marketing purposes  or from sharing this information with anyone other than ITpreneurs.

5.4. Cookies and other Analytic Tools. ITpreneurs may use “cookies” and other  technologies, such as Google Tag Manager, to gather information about your activities  on the Platform. These tools collect data to help us improve the functionality of our  website, make it more useful, and make it easier to use. By visiting our website, you  acknowledge that you accept and consent to our privacy practices, as well as the  privacy policies of the tools listed below. When Items are consumed through  ITpreneurs, anonymous network information may be transmitted back to us, such as  Item usage information. This information is transmitted back to us so we can determine  how users are interacting on the Platform, to assist us with improving ITpreneurs

offerings, and to correct any problems that may occur. Users can control the use of  cookies at the individual browser level.

5.5. Our websites make use of Google Analytics, a web analytics service provided by  Google, Inc. (“Google”). The information generated by the cookie about your use of our  website (including your IP address) will be transmitted to and stored by Google on  servers in the United States. Google will use this information for the purpose of  evaluating your use of our website, compiling reports on website activity for website  operators and providing other services relating to website activity and internet usage.  Google may also transfer this information to third parties where required to do so by  law, or where such third parties process the information on Google’s behalf. Google will  not associate your IP address with any other data held by Google. Further information  about Google’s privacy policy may be obtained from

http://www.google.com/privacy.html.

5.6. Other Third-Party Service Providers. To best provide our services, we work with a few  other companies which will only have access to the information they need to provide the  service as agreed with ITpreneurs. Here is a list of the essential service providers we  work with, and their respective privacy policies to provide a great experience. 5.6.1. Adobe EchoSign for signing agreements electronically

(https://www.adobe.com/privacy/policy.html)

5.6.2. Amazon Web Services (AWS) for hosting ITpreneurs’s servers  (https://aws.amazon.com/privacy/)

5.6.3. Facebook for simple, optional social sharing

(https://www.facebook.com/policy.php)

5.6.4. LinkedIn for simple, optional social sharing

(https://www.linkedin.com/legal/privacy-policy)

5.6.5. Digify to control access and security of documents

(https://digify.com/privacy.html)

5.6.6. MailChimp for sending email updates

(https://mailchimp.com/legal/privacy/)

5.6.7. Typeform for online forms and surveys

(https://admin.typeform.com/to/dwk6gt)

5.6.8. Twitter for simple, optional social sharing (https://twitter.com/en/privacy)  5.6.9. Vimeo for video content (https://vimeo.com/privacy)

5.6.10. Zoom for virtual conference and customer support

(https://zoom.us/privacy)

5.6.11. This list may change over time, and we’ll work hard to keep it up-to-date. If you have any questions, please get in touch with us at

servicedesk@ITpreneurs.com.

5.6.12. QuestionMark – for conducting assessments –

https://www.questionmark.com/privacy/https://www.questionmark.com/pri vacy/

5.6.13. Freshworks for technical support (https://www.freshworks.com/privacy/)

6. Linked websites and Third-Party Services

6.1. ITpreneurs may provide links to other Third-Party websites and services whose  data protection practices are outside of our control, and therefore fall outside the  scope of this policy . We encourage you to review the privacy policies posted on  these (and all) sites you visit or services you use.

7. Protection of personal information

7.1. Safeguarding Your Information. ITpreneurs is committed to protecting the  Personal Information you share with us. We utilize a combination of industry standard security technologies, procedures, and organizational measures to help  protect your personal information from unauthorized access, use or disclosure.  We recommend that you take every precaution to protect your personal  information and Account information and also instruct your authorized personnel  in using the Portal appropriately.

7.2. Notice of Breach of Security. If a security breach causes an unauthorized  intrusion into our system that materially affects our Members or their End Users,  then we will notify you as soon as possible and later report the action we took in  response

7.3. Compliance with Law. ITpreneurs may disclose your information to courts, law  enforcement or governmental authorities, or authorized third parties, if and to the  extent we are required to do so by law or if such disclosure is reasonably  necessary: (i) to comply with legal process and to respond to claims asserted  against ITpreneurs, (ii) to respond to verified requests relating to a criminal  investigation or alleged or suspected illegal activity or any other activity that may  expose us, you, or any other of our users to legal liability, (iii) to enforce and  administer our Terms of Service or other agreements with Members, (iv) for fraud  investigation and prevention, risk assessment, customer support, product  development and debugging purposes, or (v) to protect the rights, property or  personal safety of ITpreneurs, its employees, its Members, or members of the  public.

7.4. Accuracy and Retention of Data. We do our best to keep your data accurate and  up to date, to the extent that you provide us with the information we need to do  so. If your data changes (for example, if you have a new email address), then  you are responsible for notifying us of those changes. Upon request, we will  provide you with information about whether we hold, or process on behalf of a  third party, any of your Personal Information. We will retain your information for  as long as your account is active or as long as needed to provide you with our  Services. We may also retain and use your information in order to comply with  our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.

7.5. Access. We will give registered users, access to any Personal Information we  hold about them within 30 days of any request for that information. Individuals  may request to access, correct, amend or delete information we hold about them  by writing to servicedesk@ITpreneurs.com. Unless it is prohibited by law or the  information is necessary for the performance of a contract to which the data  subject is party, we will remove any Personal Information about an individual,  from our servers at your or their request.

7.6. Compliance. Our servers are located in the European Union, so your information  may be transferred to, stored, or processed in the EU. While the data protection,  privacy, and other laws of the European Union may differ from those in your  country, we take many steps to protect your privacy. By working with ITpreneurs,  you understand and consent to the collection, storage, processing, and transfer  of your information by our facilities in the European Union and those third parties  with whom we share it as described in this policy.

8. Contacting us about privacy

If you have any questions or complaints regarding this Privacy Policy, you may contact:  Info@itpreneurs.com