Privacy Policy

We respect your privacy and are committed to protecting your privacy by complying with this privacy policy (“Policy”). Personal Data is any data that can directly or indirectly identify you as a person. This Policy describes the types of information (“Personal Data”) that we may collect from you or that you may provide on the tuees.de website (“Website” or “Service”) and any of its related products and services (collectively, the “Services”) and our practices for collecting, using, maintaining, protecting and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Data and how you can access and update it.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and Mysoly AI BV (“Mysoly AI BV”, “we”, “us” or “our”). If you are entering into this Policy on behalf of a business or other legal entity, you represent that you are authorised to bind that legal entity to this Policy, in which case the terms “User”, “you” or “your” shall refer to that legal entity. If you do not have such authorisation or do not agree to the terms of this Policy, you must not accept this Policy and you may not access and use the LMS Portal. By accessing and using the LMS Portal, you acknowledge that you have read, understand and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies we do not own or control or to individuals we do not employ or manage.

Our Privacy Policy may be updated from time to time and we will notify you of any material changes by posting the new Privacy Policy in the Privacy Policy section on the Site and revising the “Update Date” at the bottom of this policy.

Who We Are?

We are an IT company registered with the Chamber of Commerce the Netherlands (KvK: 91979293). We specialize in developing scalable SaaS solutions for e-learning, including multilingual Learning Management Systems (LMS) and various language-related projects.

Our experienced team excels in Data Management and Software Development, integrating advanced AI solutions to enhance the effectiveness and innovation of our projects.

At Mysoly, we conduct all our operations in full compliance with the EU General Data Protection Regulation (GDPR), the data protection regulation 2016/679/EU. We are committed to upholding the highest standards of data protection and will not knowingly engage in or permit any actions that could lead to a violation of Data Protection Laws.

Important Definitions

Data Controller: A natural or legal person who determines (alone or jointly or in common with other persons) the purposes for which and the manner in which any personal information is or will be processed.

Data Processor: Any natural or legal person who processes data on behalf of the Data Controller.

Data Subject: Any living individual who uses our Service and is the subject of Personal Data.

Personal Data: Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (Article 4/1 GDPR).

GDPR: EU-GDPR (No. 2016/679)

Law: EU-GDPR (No. 2016/679), GDPR Implementation Act (Implementation Act) (Uitvoeringswet Algemene verordening gegevensbescherming – UAVG) – 2018

Collection of Personal Data and Which Personal Data Is Collected

You only need to use your e-mail address to access the LMS Portal and benefit from the services we offer. You do not need to provide any other personal information that discloses your identity or can identify you when using the portal.

When you create a user account, we receive and store all information that you knowingly provide to us when you fill out any form on the LMS portal. Where required, this information may include the following:

  1. For Portal Users: For users who access the user portal page and utilise our services. Information we collect:

Personal Data Category

 

Description

Personal data:

In order to use the LMS portal features (e.g. access content), you need to create a user account and for this process we only ask for your e-mail address. Apart from this, we keep your name, surname, password, registration date, nationality, telephone number, gender, date of birth, address, professional position (Student, Lecturer, Administrator, etc.), status (Active/Passive), which we do not require for subscription but which you yourself have provided for the LMS portal at your request.

Account details:

After the account creation process is complete, we assign you a unique ID number. We also store the hash value of your password.

Device and Browser information:

We keep your IP address, browser type and version, device type (web/mobile) information.

Course Enrolment and Progress:

Assigned class(es), courses of the class(es), progress of the courses (start date, last entry date, completed courses))

User Logs:

We keep all activities related to creation, editing and deletion (from creating/changing courses to changing personnel information))
  1. For Companies: For companies using the LMS Portal infrastructure.

Personal Data Category

Description

Company Information:

If you want to use the LMS Portal platform within your own organisation, we will collect your company name, company logo, telephone number, e-mail address, website name, address and subdomain address for this membership.

Students and Instructors:

User lists

Licence Information:

We keep track of how many users there are, their subscription details and which package they are subscribed to.

Files:

Photos, videos, audios and other files (pdf, World etc.) uploaded by portal users to create desr are kept.

Use and Processing of the Collected Information

Our role may also differ depending on the specific situation involving Personal Data. We act in the capacity of a data controller when we ask you to submit Personal Data necessary to enable your access and use of the LMS portal. In such cases, we are a data controller as we determine the purposes and means of processing Personal Data.

Where you submit Personal Data through the LMS portal, we act in the capacity of a data processor. We do not own, control or make decisions about the Personal Data submitted and such Personal Data is only processed in accordance with your instructions. In such cases, the User providing the Personal Data acts as a data controller.

We may need to collect and use certain Personal Data to make the LMS portal available to you or to fulfil a legal obligation. If you do not provide the information we request, we may not be able to provide you with the products or services requested. Any of the information we collect from you may be used for the following purposes:

  • To provide and maintain our service, including monitoring of LMS portal utilisation;
  • To communicate with you: Sending push notifications of updates to your e-mail address or informational mailings regarding functionalities, products or contracted services, including security updates;
  • Creating and managing user accounts;
  • Product and service updates ;
  • Responding to inquiries and providing support;
  • User feedback;
  • Improving the user experience;
  • Protection from abuse and malicious users;
  • Responding to legal claims and preventing harm;
  • For other purposes: We may also use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our services, and evaluating and improving our website, our services and your experience.

Note that we may be permitted to process information without having to rely on consent or any other legal basis until you object to such processing. In any case, we will be pleased to clarify the specific legal basis that applies to the processing and, in particular, whether the provision of Personal Data is a legal or contractual requirement or a necessary requirement to enter into a contract.

Disclosure of Data

We will not share any personally identifiable information with third parties.

We may also disclose Personal Data we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we have a good faith belief that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

The Company may disclose your data in the good faith belief that such action is necessary for the following purposes:

  • To comply with a legal obligation
  • Protect and defend the rights or property of the company
  • Prevent or investigate possible misconduct in connection with the service
  • To protect the personal safety of LMS Portal Users or the public
  • Protect against legal liability

It is important to note that these actions are taken with the utmost consideration of legal consequences and your privacy. Our adherence to the law is paramount and the decision to disclose Personal Data is carefully weighed against the need to protect the rights and safety of all parties involved. We are committed to ensuring that such disclosures comply with legal obligations and are conducted in a responsible and transparent manner.

Data Retention

We will retain your Personal Information for as long as your user account remains active and for 1 year following membership cancellation. We will retain and use it for as long as necessary to enforce our policy, resolve disputes and comply with our legal obligations, unless a longer retention period is required or permitted by law.

You have the right to request that we delete or assist you in deleting the personal data we have collected about you. Please note, however, that we may need to retain certain information where we have a legal obligation or legal basis to do so.

We may use any aggregated data derived from or combining your Personal Data after we have updated or deleted your Personal Data. In these cases we will anonymise your personal data so that it is no longer associated with you.

Cookie

Portal LMS does not collect and use cookies from our visitors. We respect the privacy of our users and ensure that they can use our website without cookies. This means that no tracking or data collection is carried out while our visitors browse our website.

Links to Other Sources

The LMS Portal contains links to other resources that are not owned or controlled by us. Please note that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware of when you leave the LMS Portal and to read the privacy statements of each resource that may collect Data.

Child Privacy

Our Services are not directed to children. We do not knowingly collect Personal Data from children. If we learn that a child has provided us with Personal Information, we will take steps to delete that information. If you learn that a child has provided us with Personal Data, please contact us at the contact details below to help us delete that information.

Data Security

Mysoly is committed to protecting your privacy. We rigorously adhere to the Data Protection Principles set by the European Union’s General Data Protection Regulation (GDPR) and the Netherlands’ GDPR Implementation Act (2018). Our Privacy Policy comprehensively details our practices regarding the collection, use, storage and disclosure of your Personal Data.

This commitment ensures that all personal data processed by Mysoly AI is handled in accordance with the highest standards of data protection and privacy as mandated by these regulations. We recognise the importance of your privacy and are committed to managing your Personal Information in a transparent and responsible manner.

We secure the information you store on servers in the cloud in a controlled, secure environment, protected from unauthorised access, use or disclosure. We maintain reasonable administrative, technical and physical safeguards to protect against unauthorised access, use, modification and disclosure of Personal Data under our control and custody. However, data transmission over the Internet or wireless network cannot be guaranteed.

Therefore, while we endeavour to protect your Personal Data;

  1. You should be aware that the Internet has security and privacy limitations that are beyond our control;
  2. The security, integrity and confidentiality of any information and data exchanged between you and LMS Portal cannot be guaranteed;
  3. Such information and data may, despite best efforts, be viewed in transit or tampered with by a third party.

The security of Personal Data depends in part on the security of the device you use to communicate with us, as well as the security you use to protect your credentials. Please take appropriate measures to protect this information.

Data Breach

In the event that we become aware that the security of the LMS Portal has been compromised or that Users’ Personal Data has been disclosed to unrelated third parties as a result of external activities, including but not limited to security attacks or fraud, we reserve the right to take reasonably appropriate measures, including but not limited to the following:

  1. Investigation and reporting, as well as notification and co-operation with law enforcement authorities.
  2. In the event of a data breach, we will use reasonable endeavours to notify affected individuals if we believe there is a reasonable risk of harm to the User as a result of the breach or if notification is otherwise required by law.

Changes and Adjustments

We reserve the right to change this Policy or its terms with respect to the LMS Portal at any time in our sole discretion. When we do so, we will revise the updated date at the bottom of this page.

An updated version of this Policy will become effective immediately upon posting of the revised Policy, unless otherwise stated. Your continued use of the LMS Portal after the effective date of the revised Policy (or any other action specified at that time) will constitute your consent to those changes. However, without your consent, we will not use your Personal Data in a materially different manner than was indicated at the time your Personal Data was collected.

Acceptance of This Policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the LMS Portal and submitting your information, you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorised to access or use the LMS Portal.

What are Your Rights as A Data Subject?

You have the right:

  • to clear information about what is done with your personal data (Article 13 and 14 GDPR);
  • to access to your personal data and certain information on processing activities and to receive a copy of the personal data undergoing processing (Article 15 GDPR);
  • to have your personal data corrected by us (Article 16 GDPR);
  • to have your personal data data deleted (Article 17 GDPR);
  • to obtain from us restriction of processing (Article 18 GDPR);
  • to have your personal data transferred to another party (Article 20 GDPR);
  • to object to data processing (Article 21 GDPR);
  • to active human involvement in automated decisions affecting you (Article 22 GDPR), however we do not use automated decision-making; and
  • to withdraw your consent at any time (Article 7 (3) GDPR).

If you would like to exercise any of your rights, please contact us via the contact information at the bottom of this privacy statement.

You have also the right to lodge a complaint with the Dutch Data Protection Authority via https://autoriteitpersoonsgegevens.nl.

Data Protection Officer (DPO)

We have appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Policy. If you have any questions about this policy or how we process your personal data, or if you would like to request access to your personal data, please contact the Data Protection Officer at support@mysoly.com. If you are not satisfied with our response to any query you raise with the Data Protection Officer, you may have the right to lodge a complaint with the data protection authority in your jurisdiction by contacting the data protection officer.

Contact Us

If you have any questions, concerns or complaints about this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:

  • By email: support@mysoly.nl
  • By phone number:  (+31) 06 87213354
  • By mail: De Huufkes 21, 5674TL, Nuenen, NL

We will endeavour to resolve complaints and disputes and will use all reasonable endeavours to comply with your request to exercise your rights as soon as possible and in any event within the timescales prescribed by applicable data protection laws.

Update Date

This document was last updated on 02 July 2024.