PRIVACY POLICY

Version: 0.1
Date: 12th of February 2022

These are the principles of personal data controller protection, represented by Algorithmics, Mikhail Ipatov, with its registered office at Avenue De-Budé 9 1202 Genève, Switzerland, registered in the Trade Register under CHE-395.591.624 (hereinafter referred to as "me", "we", "us" or "our").

By using our platform, websites, services, products, and software (“Services”), you understand and agree to the collection and use of your and your child’s information in accordance with this privacy policy. Our privacy policy applies to all visitors, users, clients, and other natural persons who access our Services (“you” or “your”) provided we execute the function of the data controller with respect to your and your child’s personal data.

This policy applies to the extent it does not contradict our service agreement with you. In case of any discrepancies, privacy and confidentiality clauses of our service agreement prevail over the provisions of this privacy policy.

PLEASE READ THIS POLICY ATTENTIVELY.

1. WHO ARE WE

IN SHORT: We are a Swiss based company and we operate as a franchisee of Algorithmics International School through their Cyprus legal entity Ruffel Holding Ltd with reg. number ΗΕ 397064 (hereinafter "Algorithmics International"), who developed an interactive platform for children who are interested to receive after-school programming сlasses. Together with Algorithmics International, we are the administrators of your personal data. We collect and process personal data concerning our clients in accordance with the General Regulation on Personal Data Protection (Regulation (EU) No. 2016/679 of the European Parliament and of the Council on the General Regulation on Personal Data Protection (hereinafter "GDPR")).

Algorithmics International has developed an interactive platform for children whose parents are interested that their children receive after-school programming classes (“Platform”) and attracted us, as a franchise, to provide such classes in certain regions of Switzerland on the basis of a franchise agreement. Algorithmics International grants us access to the functionality of the Platform, administers the Platform, provides us with all information that we need to start and operate a business, supports us in the course of our business’ launch, check the quality of our Services, and does other things that franchisees typically do with respect to their franchise network.

We therefore mainly obtain and process two kinds of personal data of our clients: (1) when they provide us with their personal data as well as with the personal data of their children or (2) when Algorithmics receives additional data directly from our client in certain limited cases and introduces it into the Platform. 

This privacy policy explains how we collect, use, share and protect the information in relation to our Services. We process the personal data of EU data subjects in accordance with the GDPR and the other applicable privacy legislation.

1. HOW TO CONTACT US

IN SHORT: You can find our contacts below. We are Algorithmics International representatives in certain regions of Switzerland. In the case of any doubt, contact us at hello@algorithmics.school

You may contact us using the following contact details:

• e-mail: hello@algorithmics.school
• telephone number: +41715610034

1. WHAT INFORMATION DO WE COLLECT

IN SHORT: We collect personal data that you provide to us such as your and your child’s name, age, country, and contact information. We get some personal data when you and (or) your child use our Services. We also collect some information when Algorithmics receives additional data directly from you and introduces it into the Platform.

1. What data do we collect

Data you disclose to us

When you contact us, we get access to the following your and your child’s personal data:

• your name
• your address
• your contact phone number
• your contact e-mail address
• your date of birth
• your child’s name
• your child’s gender
• your child’s age
• your child’s contact phone number
• your child’s contact e-mail address
• other information with respect to you and/or your child that you provide to us

Data we get when and (or) after you use the Services 

When you enter into an agreement with us, we additionally get access to the following data with respect to you and/or your child:

• your child’s individual progress with our Services 
• pages you or your child viewed
• the features you or your child use
• error reports
• links you or your child click on to leave or interact with the Platform
• other applications your child use on his or her device
• other information with respect to you and/or your child that you provide to us

When you enter into an agreement with us, Algorithmics may get in contact with you directly in a limited number of cases and receive the following data with respect to you and/or your child:

• your and your child’s feedback with respect to Platform
• your and your child’s feedback with respect to Services that we provide or have provided to you, including your impression as to the quality of these Services
• your and your child’s feedback as to our compliance with Algorithmics’ standards and policies

1. What data do we collect automatically

We also collect the following data:

• Internet Protocol (IP) address when you or your child log into the Services and respective log information and error messages
• browser type that you or your child use when you access our websites
• type of device (personal computer/notebook, mobile device), respective unique device identifiers, such as device Media Access Control (MAC) address, precise location data, device motion data, or both, if you or your child grant permission to do so in your device settings
• time of access to our websites 

1. What data do we receive from cookies

We will also receive information from cookies. We have a special policy for cookies and for your convenience represented on our website in the footer as “Cookies Policy”. 

1. What data we must have

We may not be able to provide you with the best and tailored service if we do not collect and process the above personal data. 

We must have the following data in all cases, so that we could provide you with the Services.


• Name, age, and contact details of Clients and their legal representatives

• Information about a Client received during the provision of services to the Client by the Partner, including data on working in the Program

• Photographic and/or video images

You should not enter into an agreement with us if you don’t want us to get access to this data.

You, however, may opt-out that Algorithmics contact you directly albeit we don’t recommend doing that because in this case, we may not guarantee that you are receiving services satisfying all standards that Algorithmics imposes on us. 

1. HOW DO WE USE YOUR INFORMATION

IN SHORT: We use your and your child’s personal data for a variety of business purposes. Below we explain how and for which purpose we use that information. 

We indicate the specific legal basis of processing grounds we rely on next to each purpose listed below.

Identify you and your child. We will use the information to get an understanding of a person who entered into an agreement with us and of a person who uses the Platform and consumes our Services. This information is necessary to conclude the Contract.

Contact you and your child. We will use the information to communicate with you and your child; to request feedback regarding the Platform, our Services and our compliance with Algorithmics standards and policies; to answer your requests; to provide you with any support and assistance that you or your child may need. We need this information for our legitimate business interests and based on your consent. 

Provide you and your child with personalized service. We will use this information to provide you with the Services that you have accessed or requested or the services that are the most suitable for your child; to personalize your and his or her experience; to make statistical analysis (including with the use of special web instruments, such as Google.Analytics); to provide technical support to you and your child. We need this information for our legitimate business interests and based on your consent.

Keep the results of your child’s individual progress with our Services. We will use information to provide you and your child with regular updates on the progress your child has with our Services; to take steps to identify areas for his or her further improvement; to provide you with tailored feedback; to make statistical analysis (including with the use of special web instruments, such as Google.Analytics); to propose you the services that are the most suitable for your child and other customers. We need this information in order to provide you with the Services.

Assist in improving the Platform and improve the quality of our Services. We will use the information to assist Algorithmics to improve, test, and monitor the effectiveness of its Platform and improve the quality of our Services; to propose and/or develop new services and features that we may propose to you and other clients; to make statistical analysis (including with the use of special web instruments, such as Google.Analytics); to monitor metrics such as a total number of visitors, traffic, and demographic patterns; to assist Algorithmics to protect and improve the security and safety of its Platform; to protect and improve the security and safety of you, your child and other customers, Algorithmics, other business partners, and others. We need this information for our legitimate business interests.

Other business reasons. We will use this information to enforce our terms, conditions and policies, to respond to legal requests and prevent harm. We may also use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and evaluating and improving our marketing efforts. We need this information for our legitimate business interests.

Where our legitimate business interests are mentioned this includes, depending on purpose, assisting Algorithmics in building a client-tailored Platform, ensuring our compliance with Algorithmics standards, extending the list of client offerings, increase of the overall information security of the modern society, extending the spectrum of professions' choice available for children in Switzerland. 

We may use both manual and automated systems, such as machine learning and artificial intelligence, to process Your and your child’s personal data.

Your and your child’s personal data will not be used for any automated decision-making, including profiling. We do not sell, trade or otherwise transfer users' personal data to any third parties for commercial purposes, or if it is in our other legitimate interest.

1. WILL WE SHARE YOUR INFORMATION WITH ANY THIRD PARTIES?

IN SHORT: Yes, but we only do this either with your consent, or to comply with laws, to protect your and our rights, or to fulfil business obligations. 

There are several situations when we can share your and your child’s personal data, namely:

Compliance. We may disclose your and your child’s personal data where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests and Legal Rights. We may disclose your and your child’s personal data where we believe it is necessary to enforce, remedy, or apply our terms of service and other agreements; for debt collection; to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the rights, property or safety of any person (including Algorithmics International, other Algorithmics International franchisees, you or your child) and illegal activities, or as evidence in litigation in which we are involved. 

Third-Party Service Providers. We may share your and your child’s personal data with third-party vendors, service providers, advertising companies, contractors, agents or other business partners who perform services for us or on our behalf and require access to such information to do that work and only to the extent they need such info to do that work as processors of personal data. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity, arrange for joint sales, promotions, and events, enable us to operate our business or offer you certain products, services or promotions. Some of those third-party service providers may use information about your or your child’s visits to our websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. Unless described in this policy, we do not share, sell, rent or trade any of your and your child’s personal data with third parties for their promotional purposes. 

Transfer of rights and obligations. We may share or transfer your and your child’s personal data If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company. In such a case we may need to share information with that company and its advisors. Furthermore, our rights and obligations may pass to our legal successors, who would then become the controller of your personal data.

Affiliates. We may share your information with our affiliates, in which case we will require them to honour this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

1. HOW, WHERE AND FOR HOW LONG DO WE STORE PERSONAL DATA

IN SHORT: We keep your and your child’s data to the extent we need to fulfill the purposes outlined in this policy unless the law requires otherwise. We aim to protect your and your child’s data with the use of a system of organizational and technical security measures. 

We do not retain your and your child’s personal data any longer than it is required for attaining the purposes for which it was collected. Your and your child’s personal data will be deleted or blocked as soon as the purpose for its storage ceases to apply, provided the deletion of the same is not in breach of any statutory storage obligations.

Please draw your attention that the advantage of the Algorithmics Platform is that you can always see your child’s progress with our Services irrespective of the time elapsed from the completion of the respective Service (including in case of termination or completion of your agreement with us). We will therefore store your and your child’s personal data to the extent we must satisfy your potential request to see child’s progress with our Services. If for whatever reason we are not able to store that data (e.g. you terminated the agreement with us or we discontinue as Algorithmics International franchisee) Algorithmics will continue storing your and your child’s personal data to the extent needed to address your potential request to see child’s progress with our Services.

We will also continue keeping your and your child’s personal data to the extent necessary for either of the following purposes:

• to send you a newsletter, marketing and promotional communications (this you can change at any time)
• for legal and regulatory compliance purposes
• for general Services improvement purposes

You can be assured that we always process your personal data, or your child's personal data, only for the necessary time and up to a reasonable extent. The retention period of your specific personal data, or your child's personal data, is determined according to the following logic:

• for the duration of the agreement between us
• for the time strictly necessary to protect our rights and for the time strictly necessary to determine, exercise or defend legal claims (up to 4 years)
• for the duration of our possible other legitimate interests
• for a period specified by law (up to 10 years)

We will permanently delete or de-identify the above information in accordance with our standard data retention practices once all the above purposes cease to be applicable.

We will also permanently delete or de-identify your and your child’s personal data once you specifically ask us to delete it, unless we are required to collect such data to fulfill our legal obligations or unless it is in our legitimate interest.

It may happen that we are unable to fully delete or de-identify your information due to technical or other operational reasons (for example where information has been archived and stored in back-up systems). Where this is the case, we will take reasonable measures to securely isolate information from any further processing and store it until such time as we are able to delete or de-identify it.

Algorithmics International requests that we take and we have taken appropriate technical and organizational measures by using the latest technologies to protect your and your child’s personal data against loss or unlawful processing but there cannot be a 100% guarantee that would safeguard your and your child’s personal data a from unpermitted disclosure or leakage.

While we will do all reasonable efforts to protect your and your child’s personal data, the internet itself is not a secure means of transmission. Your internet connection is at your own risk. This is your responsibility that you and your child access Services with the use of a secure internet connection. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to e-mails between you, us and Algorithmics, at all times. 

1. WHAT RIGHTS DO YOU HAVE

IN SHORT: You have certain rights with respect to your and your child’s personal data that we collect and process. 

You have a variety of rights granted to you pursuant to GDPR. Below we outline the main of them in brief albeit there are others that we did not list. Should you need more detailed guidance, please contact us or an independent GDPR specialist on your rights.

Right of consent withdrawal. You have the right to withdraw from us your consent to process your and your child’s personal data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. If we are not required to collect such data in order to fulfill our legal obligations, or if it is not in our legitimate interest, we will delete or otherwise process your data. For more details on this right please read article 7 of the GDPR.

Right of access. You have the right to obtain from us confirmation as to whether your and your child’s personal data are being processed, and, where that is the case, access to that personal data, the information concerning how we process it and some other information. For more details on this right please read article 15 of the GDPR.

Right to rectification. You have the right to obtain from us the rectification of inaccurate your and your child’s personal data. You also have the right to have incomplete personal data completed. For more details on this right please read article 16 of the GDPR.

Right to erasure (‘right to be forgotten’). You have the right to obtain from us the erasure of your and your child’s personal data, and we will erase that personal data without undue delay, unless we are required to collect such data to fulfil our legal obligations, or unless it is in our legitimate interest. For more details on this right please read article 17 of the GDPR.

Right to restriction of the processing. You have the right to ask us to restrict the processing of your and your child’s personal data. For more details on this right please read article 18 of the GDPR.

Right to object. You have the right to object that we process your personal data on the basis of our legitimate interest on grounds relating to your particular situation to processing of your and your child’s personal data and we will no longer process that personal data unless we are able to demonstrate compelling legitimate grounds for such processing. Send us an objection to our contact e-mail and we will evaluate it immediately, within 30 days at the latest. For more details on this right please read article 21 of the GDPR.

Right to data portability. You have the right to receive from us your and your child’s personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. For more details on this right please read article 20 of the GDPR.

Right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority, in particular, in the member EU state of your habitual residence, place of work or of an alleged infringement of the GDPR, about our collection and processing of your and your child’s personal data. For more details on this right please read recital 141-143, article 12, 13, 15, 77 and others of the GDPR. For Switzerland, this supervisory body is the Office for Personal Data Protection.

You can always manage the privacy of your and your child’s personal data by updating your privacy settings, managing marketing and promotional communications from us or changing your browser settings to opt-out of cookies in your browser settings (if you however disallow some or all of the cookies, the Services may not work).  

We respond to all requests we receive from individuals in the EEA and Switzerland that are using the Services directed to the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.

To file a request or act on one of your rights, please contact us at the contact details provided above in section How to Contact Us.

1. DO WE PROCESS YOUR PERSONAL DATA OUTSIDE EEA AND SWITZERLAND?

IN SHORT: We store and process your and your child’s personal data in Switzerland and the EU. Algorithmics, who is the joint controller of your and your child’s personal data, stores your and your child’s personal data in Finland and processes it in the EU and Switzerland. We will ensure an adequate level of protection for your and your child’s rights and freedoms. 

We store and process your and your child’s personal data on our servers located in the EU and Switzerland. If we need to replace our server, we will find another location in the EU and Switzerland to continue storing your personal data in the EU and Switzerland.

Given certain ambiguity that still exists regarding our processing status with respect to your and your child’s personal data, we believe that we together with Algorithmics are the joint controllers of your and your child’s personal data. Taking account of this we have entered into a data processing agreement with Algorithmics to ensure our compliance with standard contractual clauses for data transfers between EU and Switzerland controllers and non-EU controllers.

Even if we transfer your and your child’s personal data to another receiver, then such receiver would be located in the EEA and Switzerland being, therefore, a legal entity to which GDPR would apply.

1. HOW ARE WE CONNECTED WITH THIRD-PARTY APPLICATIONS, WEBSITES AND SERVICES

IN SHORT: We are generally not connected. If you go from your webpage to third-party applications, third-party websites and third-party services, this policy does not apply, and you are covered by the policies of the third parties. Similarly, their policies do not work with our Services and you should carefully read our policy.

We are not responsible for the practices employed by any applications, websites or services linked to or from our Service, including the information or content contained within them. 

You need to remember that when you use a link to go from our Service to another application, website or service, our privacy policy does not apply to those third-party applications, websites or services. Your browsing and interaction on any third-party application, website or service, including those that have a link on our Services, are subject to that third party's own rules and policies.

1. HOW DO WE SAFEGUARD CHILDREN'S PRIVACY

IN SHORT: We do not intentionally collect data directly from children under 16 years of age without the permission of a person exercising parental rights with respect to a child.

Our Services are primarily consumed by children and we, therefore, need some personal data from them even if they are under 16. We, however, target our Services to persons exercising parental rights with respect to a child and therefore we aim at receiving information regarding children under 16 from their parent or guardian or from children but with parents or guardians’ consent.

We never knowingly enter in contract directly with a child and always seek for a person exercising parental rights with respect to him or them with the purpose that this person read and understand this policy and, further, contract with us, if he or she decides so.

If you are a parent or guardian and you are aware that your child has provided us with her or her personal data without you having knowledge of that, please contact us. If we become aware that we or Algorithmics International have collected personal data from a child under age 16 without verification of parental consent, we will take steps to permanently remove that information from our servers.

1. WILL WE CHANGE THIS PRIVACY POLICY

IN SHORT: Yes, we can change it. We will always keep an updated version of our privacy policy on our webpage versoix.alg.academy so you can always read it.

We will continually review our privacy policy to ensure that it accurately reflects the GDPR, our processing activities and where we process the personal data for a new purpose that was not indicated in the initial policy, then we will provide a notice of policy amendment to cover this.

We reserve the right to make changes or updates at any time. We will notify you of any changes by posting the new privacy policy on versoix.alg.academy. We recommend that you review this privacy policy periodically. If we make material changes to the way we process your personal data, we will provide you notice and if required by applicable data protection laws seek your consent to those material changes.

Amendments to this privacy policy are effective only when they are posted on the link that we mentioned above.

***

COOKIES POLICY

Version: 0.1
Date: 11th of February 2022


This is the cookies policy of the Personal Data Administrator, Algorithmics, Mikhail Ipatov, with its registered office at Avenue De-Budé 9 1202 Genève, Switzerland, registered in the Trade Register under CHE-395.591.624.

By using our platform, websites, services, products, software (“Services”), you understand and agree to the collection and use of your and your child’s information in accordance with this cookies policy. Our cookies policy applies to all visitors, users, clients, and other natural persons who use our Services (“you” or “your”).


PLEASE READ THIS POLICY ATTENTIVELY.

1. WHO ARE WE AND HOW TO CONTACT US

Please read our privacy policy and our webpages to know who we are and what we do.

You may contact us using the following contact details:

• webpage: https://versoix.alg.academy/
• e-mail: hello@algorithmics.school
• telephone number: +41715610034

1. WHAT COOKIES ARE

We may collect information regarding individuals’ use of our Services using ‘cookies’, which are small text files that are saved by your browser or device when you access the Services. Often cookies may contain numbers and letters that uniquely identify a device but can contain other information. Cookies serve many different purposes, including helping remember an individual's preferences or allowing the Services to function. As part of the processing of cookies, personal data may be processed.

1. HOW WE USE COOKIES

We (and our third-party analytics providers, such as Google.Analytics) may use cookies:

• to identify the individual that has logged into the Services,
• to recognize the device, network, or browser over time or correlate IP addresses, mobile devices, and other technologies to determine if multiple devices may relate to the same user or account 
• to tell us how and when the individual interacts with Services,
• to monitor aggregate usage and web traffic routing for the Services, 
• to assess the effectiveness of our promotional campaigns,
• to provide the Services that the individual has requested, 
• to protect the individuals’ personal data and improve the security of our Services,
• to customize and improve the Services and advertising campaigns.

1. WHAT TYPES OF COOKIES WE USE

We may use persistent, permanent and session cookies. Unlike permanent and session cookies, persistent session cookies are deleted when an individual logs off from the Services and closes his or her browser. We may also use third-party cookies from companies such as hosting providers, messaging service providers, payment processors and others, with whom we cooperate for the purpose of advertising, analyzing, or improving the features of our Services. 

Cookies may also be divided into essential cookies (necessary to operation of our Services), functional cookies (increase the usability of our Services), performance cookies (needed to collect data on the performance of the Services) and advertising cookies (help us to display advertising tailored specifically to you).

Your consent is not required for the use of so-called necessary and analytical cookies, their use is in our legitimate interest for our Services to function properly. Even so, you can object to this processing by rejecting cookies in your browser settings or by writing to us at the contact address provided. The use of advertising cookies is possible only with your consent. You grant it to us through your browser settings and you can take it back at any time. However, this does not affect the lawfulness of the processing of personal data that we have carried out until then.

We may also employ and (or) our third-party providers may employ a software technology called ‘tags’ or web ‘beacons’ (a.k.a. pixel tags or clear gifs) or other similar technology, that help us better manage Services’ content and communications by informing us what content is effective and how it is used. These beacons (or other tracking technology) may be included in or associated with emails or other communications that an individual receives from us (or our partners) in order to help us track his or her response and interests and to deliver him or her relevant content and services. We may link information gathered by web beacons or other tracking technology to respective personal data. 

We use these specific cookies:
Cookies
Why do we use them?
How long before we delete them?
_ga     2 years
_gid    24 hours





You can find more info about cookies here [https://www.aboutcookies.org/].

1. HOW TO CONTROL COOKIES

Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. If you don’t accept cookies or don’t allow their use, you may not be able to access all portions or features of the Services.

1. WHO HAS ALSO ACCESS TO YOUR PERSONAL DATA?

We pass on your personal data to the following persons - processors of personal data:

• Google Analytics, operated by Google Inc., registered at 1600 Amphitheater Parkway, Mountain View, CA 94043, USA;
• Google Ads 
• Google Optimise
• Google Tag Manager
• AmoCRM
• Facebook Ads
• Instagram Ads
• LinkedIn Insight

1. WILL WE CHANGE THIS POLICY

We will continually review our cookies policy to ensure that it accurately reflects our approach to the use of cookies.

We reserve the right to make changes or updates at any time. We will notify you of any changes by posting the new cookies policy on versoix.alg.academy. We recommend that you review this cookies policy periodically. 

Amendments to this cookies policy are effective only when they are posted on the link that we mentioned above.


***