Politique de confidentialité

With this information, PhiAcademy GmbH (hereinafter “PhiAcademy“ or “we“) informs you about the processing of your personal data (“Data“) as well as your Data protection claims and rights:

1. Which Data are processed and from which sources do they come from?

We process the Data that we receive from you as user of our PhiCert Web platform (hereinafter “PhiCert“).

Those Data include:

• Master Profile Data: e.g. name, city and country of residence, e-mail address, telephone number, brand/course certified in, company details; certificates including Student’s Data
• Student Certificate Data: e.g. name, street, city and country of residence, e-mail address, telephone number, training/course Data
• Newsletter: name, e-mail
• Hotjar (depending which service is used): device’s IP address (stored in an de-identified format); device screen resolution; device type (unique device identifiers), operating system, and browser type; geographic location (country only); preferred language used to display the Hotjar enabled site; mouse events (movements, location and clicks); keypresses; referring URL and domain; pages visited and the date and time when website pages were accessed

If you are a Master, we receive your Profile Data from the following sources:

• PhiAcademy d.o.o.: Our parent company PhiAcademy d.o.o., Belgrade, Bulevar Oslobodjenja 137, has so far processed the Data of Masters. With the new PhiCert platform all Master Data will now be consolidated and processed together to offer a Master easier and more comprehensive access to his or her Data. For this purpose, the Master Profile Data will be transmitted based on the legitimate interest of our group in the fulfillment of internal administrative purposes, which lie in the provision of PhiCert, from PhiAcademy d.o.o. to PhiAcademy GmbH.
• Craftmaster App: Our affiliate company Craftmaster GmbH, Gartengasse 4, 1050 Vienna, operates the "Craftmaster App", where users can create a social network profile, Master can offer and hold courses and Students can book and complete these courses. If a Master offers a course via the Craftmaster App, his or her Data will be transferred to PhiCert in order to create a PhiCert Profile. This enables the Master to apply for and manage the certificates of his or her students. For this purpose, the Craftmaster App automatically transmits the Master Profile Data to PhiAcademy.
• From you: When you receive an invitation email from PhiCert, and you enter your details to create a PhiCert profile. PhiAcademy receives your Data directly from you or from our affiliates PhiAcademy d.o.o. and Craftmaster GmbH. These companies transmit the Data either because of the fulfillment of a contractual obligation towards you or because of the legitimate interest of our group in the fulfillment of internal administrative purposes, which lie in the provision of PhiCert.

If you are a Student, we receive your Certificate Data from the following sources:

• PhiAcademy d.o.o.: Our parent company PhiAcademy d.o.o., Belgrade, Bulevar Oslobodjenja 137, has so far processed the certificate Data of Students. With the new PhiCert platform all certificate Data will now be consolidated and processed together to offer the user easier and more comprehensive access to his or her Data. For this purpose, based on the legitimate interest of our group in the fulfillment of internal administrative purposes, which lie in the provision of PhiCert, the Student Certificate Data will be transmitted from PhiAcademy d.o.o. to PhiAcademy GmbH.
• Craftmaster App: Our affiliate company Craftmaster GmbH, Gartengasse 4, 1040 Vienna, operates the "Craftmaster App", where users can create a social network profile, Masters can offer and hold courses and Students can book and complete these courses. If a Student successfully completes a course using the Craftmaster App, he or she will receive a certificate from PhiAcademy in the name of the respective Master as part of this course. For this purpose, the Craftmaster App automatically transmits the Students Certificate Data to PhiAcademy.
• Your Master: If you successfully complete a course with a Master, you will receive a certificate from us as part of your course. For this purpose, the Master has to enter your Students Certificate Data in PhiCert.

2. For what purposes, duration and on which legal basis are Data processed?

We process your Data in accordance with applicable data protection law and for specific purposes and for a specific period. The purposes, duration and legal basis of the processing are listed below. If we collect Data from you for other purposes, we will inform you separately before collecting and processing that Data.

2.1 PhiCert Master Profile

2.2 Student Certificates

2.3 Newsletter

2.4 Marketing

2.5 Facebook Customer List Audiences

We use the Facebook Customer List Audiences feature from Facebook Ireland Limited to measure the effectiveness of our advertising.

Facebook’s customer list custom audiences feature enables us to create an audience using data such as email addresses and phone numbers ("Audience"). When using this feature, your data is locally hashed on our system before we upload and pass it to Facebook ("Hashed Data") to be used to create an Audience.

The Court of Justice of the European Union (CJEU) invalidated the EU-US Privacy Shield, a legal mechanism for transatlantic data transfers, in July 2020. To keep your data safe Facebook relies on Standard Contractual Clauses (SCCs) to transfer data to countries outside the EU/EEA, including the United States.

Additional information about the tool can be found here: https://www.facebook.com/legal/terms/customaudience

2.6 Google Customer Match

We use the Google Customer Match feature from Google Ireland Limited to increase the effectiveness of our advertising. Through the usage of Google Customer Match we can reach and re-engage with you in order to show relevant advertisements.

Google Customer Match feature enables us to create an audience using data such as email addresses and phone numbers. Google does not receive actual email addresses. Google’s system transforms the contact information we have into hashed codes using the secure hashing algorithm SHA256, a one-way hashing mechanism that is not unencrypted by Google.

The Court of Justice of the European Union (CJEU) invalidated the EU-US Privacy Shield, a legal mechanism for transatlantic data transfers, in July 2020. To keep your data safe Google relies on Standard Contractual Clauses (SCCs) to transfer data to countries outside the EU/EEA, including the United States.

Additional information about the tool can be found here:

• https://support.google.com/google-ads/answer/6334160?hl=en
• https://policies.google.com/technologies/partner-sites?hl=en
• https://policies.google.com/privacy

3. Who receives your Data?

Within PhiAcademy and our affiliated Craftmaster GmbH and PhiAcademy d.o.o., those employees will receive your personal information, who need them for the purposes outlined above. If we are legally obliged to do so, we will also transfer your Data to public bodies and authorities. In addition, companies commissioned by us (in particular IT or payment services and back office providers) will receive your Data if they need them to fulfill their respective tasks. These providers are obliged to treat your Data confidentially and to process them only to the extent necessary for their service provision. If these companies provide their processing activities outside the European Economic Area, they have a Privacy Shield Certificate or have undertaken to ensure an adequate level of data protection.

We will transfer your Data to the following recipients:

4. Cookies

4.1 Technically required Cookies

We use cookies on PhiCert, which are small files stored on your device (web browser). On your next visit to PhiCert using the same device, the information stored in cookies will subsequently be returned to PhiCer. We use the Data collected through these cookies to better represent PhiCert and to make our offers user-friendly, for example to evaluate the use of PhiCert. Some cookies remain stored on your device until you delete them. They allow us to recognize your browser on your next visit. Other cookies are only stored on PhiCert for the duration of your visit.

The following cookies are used:

All these cookies are technically necessary for the presentation of PhiCert. You can deactivate the setting of cookies in the settings of your browser. Please note that a general deactivation of cookies may possibly lead to functional limitations of PhiCert.

4.2 Google Analytics

Furthermore we use the Cookies of Google Analytics, a web analysis service provided by Google LLC (hereinafter "Google"). These cookies transmit data about your usage of PhiCert to a Google server in the USA. However, your IP address will be shortened by Google prior to transmission and the transmitted data can no longer be associated with your person. Google will use this information to evaluate general usage data of PhiCert and to compile reports on PhiCert activities. If you want to prevent the use of Google Analytics cookies, you can either do this through your browser settings or you can install the browser plug-in available under the following https://tools.google.com/dlpage/gaoptout. For information about how Google and its affiliates use data and storage practices, please visit Google's Privacy Policy, currently available at: https://google.com/privacy.html.

4.3 Facebook Audience Pixel

We also use the Facebook Audience Pixel analysis tool from Facebook Ireland Limited to measure the effectiveness of our advertising. The pixel collects information about the use of PhiCert and transmits that information to Facebook's servers in Ireland. This information may also be cross-checked with other Facebook information or our information that we have about you. All data collected by this pixel is encrypted by Facebook using "hashes". Facebook Ireland Limited is located in the European Union. The Court of Justice of the European Union (CJEU) invalidated the EU-US Privacy Shield, a legal mechanism for transatlantic data transfers, in July 2020. To keep your data safe Facebook relies on Standard Contractual Clauses (SCCs) to transfer data to countries outside the EU/EEA, including the United States.

The collection of data by Facebook Pixel only takes place with your consent. This consent can be withdrawn by you at any time. The comparison of the data with the data stored by us is based on our legitimate interest in marketing and customer loyalty. Your Data will be processed until you object to this processing.

4.4 Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

The processing of data through the usage of Hotjar only takes place with your consent (§ 165 para 3 TKG 2021 in conjunction with Art 6 para 1 lit a GDPR). This consent can be withdrawn by you at any time. The withdrawal of this consent does not affect the lawfulness of processing based on the consent before its withdrawal.

The Court of Justice of the European Union (CJEU) invalidated the EU-US Privacy Shield, a legal mechanism for transatlantic data transfers, in July 2020. To keep your data safe Hotjar relies on Standard Contractual Clauses (SCCs) to transfer data to countries outside the EU/EEA, including the United States.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

The following Hotjar cookies are used:

Additionally, we use pixels and tags from the following third parties (which may in turn place cookies):

5. Are you obliged to provide Data?

Students are not obliged to provide any Data.

As a Master, it is necessary that you provide the Data we need to fulfill our contractual obligations to you. Those Data are marked with (*) as mandatory. Unless you provide those mandatory Data, we will generally be unable to provide our services.

6. Your rights in the context of the processing of your Data

You have the right:

• to request information about which of your personal Data we process (Article 15 GDPR);
• to rectify or erase your Data (Article 16 GDPR);
• to restrict the processing of your Data (Article 18 GDPR);
• to withdraw your consent (Article 7 GDPR);
• to object to the processing of your Data (Article 21 GDPR);
• to Data portability (Article 20 GDPR).

If you believe that we violate your rights under the GDPR or national data protection law when processing your Data, please contact us. This is the only way we can treat your concerns as quickly as possible. You also have the right to lodge a complaint with a supervisory authority (in Austria: www.dsb.gv.at).

7. Automated decision-making

We do not use automated decision-making or profiling according to Article 22 GDPR.

8. Who can you contact?

If you have any requests or concerns, you can contact us directly by e-mail or by post at the following address:

PhiAcademy GmbH
Gartengasse 8/8, 1050 Vienna
E-Mail: info@cert.phi-academy.com

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