Privacy policy

PRIVACY POLICY

Introduction

Personal Information Xplorafory Test collects

• Personal Information you provide to us
  
• Personal Information we automatically collect
• When you use the Services

How and on what grounds do we use your Personal Information?

• Personal Information we collect directly from you on our Website or Events
• Personal Information we collect directly from you as part of the administration of our Services
• For any other purposes about which we notify customers and users

How do we share and disclose Personal Information to third parties?

• Vendors, consultants, and other service providers
• Business transfers
• Protection of Xplorafory Test and others
• Disclosures for national security or law enforcement
• For how long do we store your Personal Information?
• Security

Your privacy rights

• What choices do I have?
• Marketing communications

How can I exercise my privacy rights?

International data transfers

Information for users in the European Economic Area (“EEA”) or in the United Kingdom (“UK”)

• Right to have personal data deleted (“Right to be forgotten”)
• Right to be informed
• Right to receive access to your personal data (“Subject access”)
• Right to access, and request a transfer, of your personal data to another recipient (“Data portability”)
• Right to rectification
• Right to restrict processing
• Right to object against our processing of your personal data
• Right to object to an automated decision that significantly affects you
• Right to withdraw one’s consent
• Additional right available to you in France, Spain, and Italy: Post-mortem right to your personal data
• Right to lodge a complaint

Additional information for California consumers – The California Consumer Privacy Act

• Personal Information disclosed for business purposes:

The CCPA rights

• Right to opt-out of sale
• Right to request disclosure
• Right to request deletion
• Right to non-discrimination

How do we handle your requests?

California and Delaware “Do Not Track” disclosures

Children

Linked websites

Changes to this Notice

Klarna

Contact us

Introduction

Xplorafory Test AB (“Xplorafory Test”, “we,” or “us”) offers an online educational platform. This Privacy Notice (“Notice”) covers the personal information that Xplorafory Test collect through , events hosted by Xplorafory Test, applications, products, and services owned or controlled by Xplorafory Test. In this Notice, personal information means information that (either in isolation or in combination with other information) enables you to be directly or indirectly identified (“Personal Information”).

This Notice aims to inform you about how we collect, use, disclose and store Personal Information in our role as a controller of Personal Information when you:

Interact or use our Website, including when you download materials from our resources page or participate in our courses.

Register and/or attend our events, conferences, or webinars (collectively “Events”).

Provide your Personal Information for the purposes of administering our services and managing our relationship with you in any manner (collectively the “Services”) e.g. setting up an account or collecting your Personal Information to process an invoice for accounting purposes.

Personal Information Xplorafory Test collects

Personal Information you provide to us:

From Websites or Events: We may collect Personal Information that you choose to send to us or provide to us through online forms or if you register for any Events. If you contact us through the Websites, we will keep a record of our correspondence.

From the Services:  We receive and store the Personal Information you provide directly to us. For example, when setting up new users, we collect Personal Information, such as name, e-mail address, postal address, phone number etc. We may collect and store media, documents, or other information you provide to us. We collect commercial information or such as records of the purchased Services.

Personal Information we automatically collect:

When you use the Websites:

When you visit our Website, we collect Internet or other electronic network activity information through the use of cookies and other trackers. Depending on your tracking preferences, the information we collect may include but is not limited to your device’s Internet Protocol (“IP’) address, referring website, what pages your device visited, and the time that your device visited our Website. We may also rely on analytics and tools used to prevent spam and other security risks related to the use of abusive automated software. You can choose your preferences with regards to the cookies and other trackers by accessing the preference centre on our Websites. Visit our Cookie Notice for more information on the types of cookies and other trackers we use on our Website.

When you use the Services:

Internet or other electronic network activity information may also be collected when you use the Services:

Usage information – we keep track of user activity in relation to the types of Services our users use, the configuration of the user’s computers, and performance metrics related to their use of the Services.

Log information – we log information about our users when they use one of our Services, including their IP addresses.

Information collected by cookies and other similar technologies – we use various technologies to collect information, including saving cookies to users’ computers.

Customer feedback – While using the Services, you may be asked to provide feedback (e.g., in the software directly or after receiving help from our support team). Providing this feedback is entirely optional.

For further information please visit the Xplorafory Test Cookie Notice.

How and on what grounds do we use your Personal Information?

Personal Information we collect directly from you on our Website or Events:

We will use the Personal Information we collect through our Website:

To administer our Website, our Events, and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes.

To improve our Website to ensure that content is presented most effectively for you and your device.

For trend monitoring, marketing, and advertising.

For purposes made clear to you at the time you submit your Personal Information, for example, to fulfill your request to participate in a course, to provide you with access to one of our webinars, or to provide you with information you have requested about our Services.

As part of our efforts to keep our Website secure.

To maintain student records.

Our use of your Personal Information may be based on our legitimate interests to ensure network, information security, and business performance improvement. Our direct marketing purposes are based on your consent (for example when you sign up to our newsletter, contact us directly, provide us your business card, agree to receive communications after an Event, and similar circumstances). We may also rely on our legitimate interests to improve business and marketing practices or contact you to offer similar Services or products that you may have bought from us or negotiated with us.

Personal Information we collect directly from you as part of the administration of our Services:

We may use the Personal Information we collect from you in connection with the Services we provide for a range of reasons, including to:

• Set up a user account.
• Provide, operate, and maintain the Services.
• Process and complete transactions, and send related information, including transaction confirmations and invoices.
• Manage our users’ use of the Services, respond to inquiries and comments, and provide customer service and support.
• Send users technical alerts, updates, security notifications, and administrative communications.
• Investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities.

For any other purposes about which we notify customers and users:

We use your Personal Information in this context based on the agreement that we have in place with you or our legitimate interests, typically, either for security purposes or business practice improvement (e.g., the prevention and investigation of fraudulent activities).

Provision of Personal Information in these instances may be necessary to enable our proper execution of the agreement between you and us. Failure to provide Personal Information may cause some services to become unavailable. Personal Information will be deleted based on the terms of our agreement that we have in place with you.

How do we share and disclose Personal Information to third parties?

We share and disclose information, including Personal Information, about our customers in the following limited circumstances:

Vendors, consultants, and other service providers:

We may share your Personal Information with third-party vendors, consultants, and other service providers we employ to perform tasks on our behalf.  These companies include (for example) our payment processing providers (e.g., Klarna), website analytics companies (e.g., Google Analytics), tools used to prevent spam and other security risks related to the use of abusive automated software (e.g., Google reCAPTCHA), online activities, product feedback or help desk software providers (e.g., Salesforce), CRM service providers (e.g., Salesforce), email service providers (e.g., SendGrid) and others. If Xplorafory Test receives your Personal Information in the United States and subsequently transfers that information to a third party agent or service provider for processing, Xplorafory Test remains responsible for ensuring that such third party agent or service provider processes your Personal Information to the standard required by the applicable privacy laws, including the GDPR. These transfers will typically be based on our legitimate interests or agreed upon in the agreement between you and us.

For further information please see International data transfers section below.

Business transfers:

We may choose to buy or sell assets and may share and/or transfer customer information, including Personal Information, in connection with the evaluation of and entry into such transactions and based on our legitimate interests. Also, if we or our assets are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be one of the assets transferred to or acquired by a third party.

Protection of Xplorafory Test and others:

We reserve the right to access, read, preserve, and disclose any Personal Information as necessary to i) comply with a law or a court order, ii) enforce or apply our End user agreement s with you and other agreements, or iii) protect the rights, property, or safety of Xplorafory Test, our employees, our users, or others.

Disclosures for national security or law enforcement:

Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements, based on our legitimate interests or legal obligations.

For how long do we store your Personal Information?

We store your Personal Information for different time periods depending on the category of Personal Information. Some information may be deleted automatically based on specific schedules, such as marketing information. Other information e.g. account information, may be retained for a longer period of time based on the agreement you have with us. We also store your information/records about courses taken for the purpose of recreating diplomas or accreditations for 10 years. Finally, we may further retain information for business practices based on our legitimate interests or legal purposes, such as network improvement, fraud prevention, record-keeping, or enforcing our legal rights.

Security

We use appropriate technical, organizational, and administrative security measures to protect any Personal Information we store from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

No company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user’s Personal Information at any time. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

Your privacy rights

What choices do I have?

You can always opt not to disclose information to us, but keep in mind that some information may be needed to register with us or take advantage of some features of our Services or products.

Marketing communications:

You can opt-out of receiving certain promotional or marketing communications from us at any time by using the unsubscribe link in the emails communications we send, or by filling out this request form. Please note that if you have an account with us and you opt out of receiving promotional and marketing related communications from us, we may continue to send you non-promotional communications, e.g. service-related emails.

Cookies:

You can change your preferences with regards to the cookies and other trackers at any time by clicking on the persistent cookie icon at the bottom of the screen on our Website.

How can I exercise my privacy rights?

If you would like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), you can either click the “Exercise your Rights” link or fill out this request form. We will examine your request and respond to you as quickly as possible. Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual and may also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We remind you that you have a right to lodge a complaint with a supervisory authority should you feel unsatisfied with our treatment of your Personal Information. For more information, you can visit the Information Commissioner’s Office website at www.IMY.se

California residents: California residents have specific rights under the California Consumer Privacy Act (‘CCPA’). For more information and to exercise your rights, please see the section titled The California Consumer Privacy Act below.

Residents of the European Economic Area or the United Kingdom: If you are a resident of the European Economic Area or the United Kingdom, please see the section titled Additional Information for users in the European Economic Area and the United Kingdom below for further information about your privacy rights.

International data transfers

Personal Information you submit on our Website or through the Services may be sent to Country and processed by us there or in other countries, or stored and processed on our service providers’ cloud servers. The CookiePro Service is hosted in Microsoft Azure’s data centers in Germany.

We will always protect your Personal Information in accordance with this Notice wherever it is processed. Xplorafory Test does not voluntarily or actively transfer or disclose our users’ Personal Information to the government or law enforcement authorities (the “Authorities”) and/or otherwise grant any Authorities access to your Personal Information.

Information for users in the European Economic Area (“EEA”) or in the United Kingdom (“UK”):

Xplorafory Test may transfer Personal Information from the EEA or the UK to the United States, including Personal Information we receive from individuals residing in the EEA or the UK who visit our Website and/or who may use our Services or otherwise interact with us. Please note that the term Personal Information used in this Notice is equivalent to the term “personal data” under applicable European and UK data protection laws for individuals located in the EEA or the UK. When Xplorafory Test engages in such transfers of Personal Information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR), or ii) Standard Contractual Clauses issued by the European Commission. The European Commission has determined that the Standard Contractual Clauses provide sufficient safeguards to protect personal data transferred outside the EU or EEA. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. Xplorafory Test continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.

You have several rights under the GDPR related to you having control of your personal data and to receive information directly from us on how we process personal data about you. In the following, you can read about your rights. If you want to know more or come in contact with us to exercise your rights, the easiest way is to contact us using the contact details in the end of the Notice.

Right to have personal data deleted (“Right to be forgotten”).

In some cases, you have the right to have us delete personal data about you. For example you can request us to delete such personal data that we (i) no longer need for the purpose it was collected for, or (ii) that we process based on your consent and you revoke your consent. There are situations where Xplorafory Test is unable to delete your data, for example, when the data is still necessary to process for the purpose for which the data was collected, Xplorafory Test’s interest to process the data overrides your interest in having them deleted, or because we have a legal obligation to keep it. You also have the right to object to us using your personal data for certain purposes such as direct marketing, which you can read more about in this list of your rights.

Right to be informed.

You have the right to be informed of how we process your personal data. We do this through this privacy notice and by answering your questions.

Right to receive access to your personal data (“Subject access”).

You have the right to know if Xplorafory Test processes personal data about you, and to receive a copy (“data extract”) of such data, so-called subject access. Through the data extract you will receive information about what personal data Xplorafory Test holds about you, and how we process it.

Right to access, and request a transfer, of your personal data to another recipient (“Data portability”).

This right means that you can request a copy of the personal data relating to you that Xplorafory Test holds for the performance of a contract with you, or based on your consent, in a machine-readable format. This will allow you to use it somewhere else, for example to transfer your personal data to another controller/ recipient.

Right to rectification.

You have the right to request that we rectify inaccurate information or complete information about you that you consider is inaccurate or incomplete.

Right to restrict processing.

If you believe that your personal data is inaccurate, that our processing is unlawful or that we do not need the information for a specific purpose, you have the right to request that we restrict the processing of such personal data. You also have the possibility to request that we stop processing your personal data while we assess your request. If you object to our processing per your right described directly below, you may also request us to restrict processing of that personal data while we make our assessment.

Right to object against our processing of your personal data

You have the right to object to processing of your personal data which is based on our legitimate interest (Article 6(1)(f) GDPR), by referencing your personal circumstances. You can also always object to our use of your personal data for direct marketing purposes. When you let us know that you no longer wish to receive direct marketing from us, we will stop sending it to you.

Right to object to an automated decision that significantly affects you.

You have the right to object to an automated decision made by Xplorafory Test if the decision produces legal effects or significantly affects you in a similar way. Xplorafory Test do not use automated decisions in any part of its business.

Right to withdraw one’s consent.

As described in the Notice, where we process your personal data based on your consent or explicit consent, you have the right to revoke your consent at any time. When you revoke your consent we will stop processing your data for such purposes.

Additional right available to you in France, Spain, and Italy: Post-mortem right to your personal data.

You have the right to give, or designate a person authorized to give instructions relating to the retention, erasure and communication of your personal data after your death.

Right to lodge a complaint.

If you have complaints about Xplorafory Test’s processing of your personal data, you may lodge a complaint with Integritetsskyddsmyndigheten, which is the Swedish supervisory authority for Xplorafory Test’s personal data processing, or your national data protection authority.

Following invalidation of the EU-US Privacy Shield Framework in Case C-311/18 by the Court of Justice of the European Union, Xplorafory Test will no longer rely on the EU-US Privacy Shield as a mechanism of international data transfer until further notice.

Following the opinion of the Swiss Federal Data Protection and Information Commissioner (FDPIC) of 8 September 2020, Xplorafory Test will no longer rely on the Swiss-U.S. Privacy Shield as a mechanism of international data transfer until further notice.

Additional information for California consumers – The California Consumer Privacy Act

Under the California Consumer Privacy Act (the ‘CCPA’), California residents have certain rights regarding the Personal Information that businesses have about them. This includes the rights to request access or deletion of your Personal Information, as well as the right to direct a business to stop selling your Personal Information.

Personal Information disclosed for business purposes:

Xplorafory Test shares and has shared in the preceding 12 months personal information as necessary for specific “business purpose,” as defined by the CCPA (Cal. Civ. Code 1798.140(d)) and specified in the section “How do we share and disclose information to third parties?” This includes sharing personal identifiers, commercial information, internet or other electronic network activity with payment processing providers, customer relationship management, consulting, email, product feedback, and helpdesk services. While Xplorafory Test does not sell Personal Information in exchange for any monetary consideration, we do share Personal Information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). This includes sharing personal identifiers, commercial information, and internet or other electronic network activity with advertising networks, website analytics companies, and event sponsors. Xplorafory Test does not sell Personal Information of consumers who are under 16 years of age.

The CCPA rights

Right to opt-out of sale:

While Xplorafory Test does not sell personal information in exchange for any monetary consideration, we do share Personal Information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). We support the CCPA and wish to provide you with control over how your Personal Information is collected and shared.

You have a right to direct Xplorafory Test not to sell your Personal Information. Click here With respect to cookies, you can always customize your settings at any time. Please note that we may still use aggregated and de-identified Personal Information that does not identify you or any individual. We may also retain Personal Information as needed to comply with legal obligations, enforce End user agreement s, and resolve disputes.

Right to request disclosure:

You have the right to request disclosure about what categories of Personal Information Xplorafory Test has sold or disclosed for a business purpose about you and the categories of third parties to whom the personal information was sold or disclosed. You have a right to request disclosure of specific pieces of Personal Information. Below is a complete list of the Personal Information that you can include in your request.

• The categories of Personal Information that Xplorafory Test has collected about you.
• The categories of sources from which Xplorafory Test collected the Personal Information.
• The business or commercial purpose for collecting or selling Personal Information.
• The categories of third parties with whom Xplorafory Test shares Personal Information.
• The specific pieces of Personal Information Xplorafory Test has collected about you.
• The categories of Personal Information that Xplorafory Test disclosed about you for business purpose.
• The categories of Personal Information that Xplorafory Test has sold about you, as well as the categories of third parties to whom Xplorafory Test sold your Personal Information.

If you would like to exercise your right to request disclosure, please fill out this. Our privacy team will examine your request and respond to you as quickly as possible.

Right to request deletion:

You have the right to request that Xplorafory Test delete any Personal Information about you that Xplorafory Test has collected from you. Please note that there are exceptions where Xplorafory Test does not have to fulfill a request to delete Personal Information, such as when the deletion of information would create problems with completing a transaction or compliance with a legal obligation.

If you would like to exercise your right to delete, please fill out this request form. Our privacy team will examine your request and respond to you as quickly as possible.

Right to non-discrimination:

Xplorafory Test will not discriminate against you (e.g., through denying goods or services or providing a different level or quality of goods o/r services) for exercising any of the rights afforded to you.

How do we handle your requests?

We endeavor to respond to a verifiable consumer request within the required timeframes. If we need more time, we will inform you of the reason and extension period in writing. If you submit your privacy request electronically through our request form, we will deliver our written response to the verified email associated with the request. If you did not submit the request with us via the online webform, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain why we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

California and Delaware “Do Not Track” disclosures

California and Delaware law require Xplorafory Test to indicate whether it honors your browser’s “Do Not Track” settings concerning targeted advertising. Xplorafory Test adheres to the standards set out in this Notice and does not monitor or respond to Do Not Track browser requests.

Children

We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us their Personal Information, please contact us at.

Linked websites

For your convenience, hyperlinks may be posted on the Website that link to other websites (the “Linked Sites”). We are not responsible for, and this Notice does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the Websites. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read each Linked Site’s privacy notice to understand how the Personal Information about you is used and protected.

Changes to this Notice

We are constantly trying to improve our Website and Services, so we may need to change this Notice from time to time. We will alert you about material changes by, for example, placing a notice on our Website and/or by sending you an email (if you have registered your e-mail with us) when we are required to do so by applicable law. You can see when this Notice was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Notice.

EN:

“In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice“.

SE:

“För att kunna erbjuda dig Klarnas betalmetoder kan vi i kassan komma att dela dina personuppgifter i form av kontaktuppgifter och orderinformation med Klarna, för att Klarna ska kunna bedöma om du kan välja betalmetoderna, samt för att anpassa dem för dig. Dina personuppgifter som delas behandlas enligt Klarnas egen dataskyddsinformation.”

Contact us

Controller’s Contact Information:

Address:

Berguven 20
436 53 Hovås
Gothenburg, Sweden

Phone: +46 705 186 265

Email: info@xplorafory.com

If you have questions, requests, or concerns regarding your privacy and rights, please let us know how we can help.