Effective Date: 20th of October 2020
Data Controller Contact Information
EDUWEB CONSULTING LTD., with its principal office at 3507-9981 Whalley Blvd, Surrey BC, Canada V3T 0G6
This document governs the privacy notice of our website https://classtrack.com/
ClassTrack, (hereinafter "Service", “we” or “us”) treats everything that is related to personal data with respect and integrity. We are committed to safeguarding the privacy of our website, of our services as data protection is of a particularly high priority for the management of our company.
First, we need to define, and it is important for you to understand, the expression: "Personal Data". It generically represents any kind of information about a physical person, whose particularities can lead, directly or indirectly, to its identification. Here you have, by way of example, but not limited to: name and surname, geographical address, any identification number, political orientation, sexual orientation, email address, any location information and any other online identifier such as the device used to access the Internet, IP address, or cookie information.
With regards of your agreement on collection and use of personal data, we have taken all the necessary technical measures to provide you with this detailed agreement, so you can have a crisp clear experience, from the first to the last interaction with our website or our services.
Visitors and Users agree and accept that the use of our website is not possible without any indication of personal data.
Our data protection policy should be legible and understandable for the general public, as well as for our Users and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
• Data Subject or Data Principal - is any identified or identifiable natural person, whose personal data is collected and processed by us.
• Processing - is any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, etc.
• Restriction of processing - is the marking of stored personal data with the aim of limiting their processing in the future.
• Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person.
• Data Controller or Data Fiduciary - is the natural or legal person, public authority, agency or other body, which determines the purposes and means of the processing of personal data;
• Processor - is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
• Recipient - is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed. The processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
• Third party - is a natural or legal person, public authority, agency or body other than the ones above, who, under the direct authority of the controller or processor, are authorized to process personal data.
• Consent - is any freely given, specific, informed and unambiguous indication of data subject’s acceptance to the processing of their personal data.
The processing of personal data will be in line with these main international legislations:
• General Data Protection Regulation (GDPR), applicable in Europe;
• California Consumer Privacy Act (2018) and Privacy Act U.S.C. 552a (Privacy Act of USA);
• Personal Data Privacy Bill (2020) applicable in India.
We are able to sell our services worldwide. For the purpose of avoiding any compliance conflict with any terminology used by any particular legislation, in this document: “Users” are the “data subjects” or the “data principals” and ClassTrack is the “data controller” or “data fiduciary”
Our privacy notice tells you what personal data (PD) and non-personal data (NPD) we may collect from you, how we collect it, how we protect it, how we may share it, how you can access and change it, and how you can limit our sharing of it. Our privacy notice also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our website.
Automated individual decision-making and profiling
You will have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Filing a complaint with authorities
You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the General Data Protection Regulation. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.
For details about your rights under the law, visit https://goo.gl/F41vAV
● Website Visitor
You are a “Website Visitor” by definition when you visit our website www.kcard.online and any other eventual subdomains associated with our principal domain. As a website visitor, we use your information for our own purposes, primarily for improving the use of our website and to provide you with more relevant content.
You become a “User” if you create an account on our website/app in order to buy one of our products or services. If you are a User, our primary purpose of using your personal data is for providing the service and the services to you. We retain your personal information for a limited time and for limited purposes, such as to make it easier for you to re-join our service in the future or to wish you offers for services that we think you may be interested in.
Types of Personal Data we collect
a) Personal Information
When you access the website, register a User Account or avail the Services, we may ask you to voluntarily provide us certain information that personally identifies you or could be used to personally identify you (“Personal Information”). Personal Information includes (but is not limited to) the following categories of information: first and last name, gender, physical address, contact number, email or other contact information and other relevant data as desired by us. Questions or comments submitted by visitors may also be regarded as Personal Information.
Please do not supply any other person's personal data to us, unless we prompt you to do so.
b) Non-Personal Information
We may additionally collect and track Non-Personal Information about your website visit including the domain name and the name of the web page from which you use our Services, how much time you have spent on each of our web pages, the Internet Protocol (IP) address associated with your computer, tablet or mobile phone, operating system and platform, pages viewed, information searched for or requested for and other relevant statistics. We will use this information for the purposes of improving the performance and operations of our website and Services. If you send ClassTrack a message, this message can be stored to process it, to compile statistical information, to improve our services and support, or to get in touch with you. Further communication between you and a Care Provider made via email will have no connection to ClassTrack.
Upon acquisition of our services, we will ask for your full name and a valid e-mail address, which will be included in our mailing list, for future maintenance, updates, and eventual marketing promotions. In addition, we will ask you to provide us with secure payment data, which will be used for processing the order. This particular set of data will be legally processed by our payment processor, and will not be stored by us.
Purpose of collection
Our commercial purpose, by reference to the subject matter of our business, is provision of ticketing for events services, and also intermediation services between data subjects and/or other adjacent or complementary third-party service providers, and the new rules of personal data protection (GDPR, CCPA, PDPB, etc.) are part of this context.
To improve our services.
We always want to offer you the best online experience and for this we can collect and use certain information about your behavior and preferences when using the website, or we can conduct market research directly or through partners.
To improve your marketing activity
We want to keep you informed about the best offers for the products / services you may be interested in. In this sense, we may send you any type of message (such as: email / SMS / phone / mobile push / web push / etc.) containing general and thematic information about products or services, information on offers or promotions, as well as other commercial communications.
To defend our legitimate interests
There may be situations in which we use or transmit information to protect our rights and our commercial activity. These situations may include:
- measures to protect the website and platform Visitors and Users against cyber-attacks;
- measures to prevent and detect fraud attempts;
- transmission of information to the competent public authorities;
- other risk management measures.
We therefore commit ourselves:
- to protect the privacy of your data, which is a top priority for our company’s management;
- to use this data for the sole purpose of providing you with a personalized experience on our website as well as on the online platforms that we promote our products and services (Facebook and Google, etc.).
We may process data about your use of our website and services, or the User’s website ("usage data"). The usage data may include your IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services.
We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
We may process information contained in any inquiry you submit to us regarding services and/or services ("inquiry data"). The inquiry data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
We may process information relating to our User relationships, including User contact information ("User relationship data"). The User relationship data may include your name, your employer, your job title or role, all your contact details, and information contained in communications between us and you or your employer. The User relationship data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our services ("transaction data"). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
“Automatically Collected" Information: The website collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files, and it is collected regardless of your quality: Website Visitor or User.
Note: no personal information is collected through the service (plugin) itself. Kmajor only collects purchase codes, website URL, plugin version and WordPress version strictly for providing services.
Collected may be:
• the ISP,
• the operating system used by the accessing system
• the website from which an accessing system reaches our website (so-called referrers)
• the sub-website
• the date and time of access to the website
• an Internet Protocol address (IP address)
• screen Resolution
• locale Preferences
• web page visited before you came to our website
• information you search for on our website
• date and time stamps associated with transactions
• system configuration information and other interactions with the website.
• social networking information (if we are provided with access to your account on social network connection services);
• any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to:
• deliver the content of our website correctly;
• optimize the content of our website as well as its advertisement;
• ensure the long-term viability of our information technology systems and website technology;
• provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack;
In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person's personal data to us, unless we prompt you to do so.
Obviously, the access to our website for website visitors is free; however, we inform you that for the use of the website via mobile device the charges and the standard tariffs provided in the service contract that you have stipulated with them will still be applied by the telephone operators.
Our Legal Basis for Collecting and Processing Personal Data
Our legal basis for collecting and processing your PD when you buy our products, services, or sign up for our trial membership is based on the necessity for the performance of a contract or to take steps to enter into a contract.
What Happens If You Don’t Give Us Your PD
If you do not provide us with enough PD, we may not be able to provide you with all our products and services. However, you can access and use some parts of our website without giving us your PD.
We Collect Your PD in the Following Ways:
We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our website, if any, as well as the name of the website you’ll visit when you leave our website. This information also includes the IP address of your computer/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our website. We use all this information to analyze trends among our users to help improve our website.
When Entering and Using Our Website
When you enter and use our website and agree to accept cookies, some of these cookies may contain your PD.
At Member Registration or When Buying Our Products or Services
When you register as a member to buy our products, services, or sign up for our trial membership, we may collect some or all of the following information: your first and last name, email address, physical address, credit card or other payment information, phone number, user name, password, and other information listed.
Website Chat Software
Our website contains chat software that enable visitors to communicate with us live online or offline by email. In some cases, visitors can communicate with us without becoming a member or buying our products and services. When you use this chat software, we may collect some or all the following information: your email address, first name, last name, location, and any other information you willingly choose to provide to us. You should limit the information you provide to us that is only necessary to answer your questions.
Strictly Necessary Cookies
These cookies collect information about the use of the website, such as pages visited, traffic sources, users’ interests, content management, and other website measurements.
These cookies enable the website to remember a user’s choices – such as their language, user name, and other personal choices – while using the website. They can also be used to deliver services, such as letting a user make a blog post, listen to audio, or watch videos on the website.
These cookies can be used to improve a website’s performance and provide special features and content. They can be placed by third parties who provide services to us or by our company.
Advertising or Targeting Cookies
These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.
These cookies allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they browse a website. Session cookies also permit users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; thus, they are not stored long term.
These cookies are stored on a user’s device in between browser sessions, which allows the user’s preferences or actions across a site (or, in some cases, across different sites) to be remembered. Persistent cookies may be used for a variety of purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.
• Identifying the areas of our website that you have visited
• Personalizing content that you see on our website
• Our website analytics
• Remarketing our products or services to you
• Remembering your preferences, settings, and login details
• Targeted advertising and serving ads relevant to your interests
• Affiliate marketing
• Allowing you to post comments
• Allowing you to share content with social networks
We may also use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers, members, and visitors.
Google Analytics and Google Tag Manager Privacy Notice
Our website uses Google Analytics and Google Tag Manager to collect information about the use of our website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our website, what pages they visit, and what other websites they have used before coming to our website. We use the information we get from Google Analytics to analyze traffic, remarket our products and services to users, improve our marketing, advertising, and to improve our website. We have enabled Google Analytics advertising features such as remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. Google Analytics collects only the IP address assigned to you on the date you visit our website, not your name or other identifying information. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our website, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our website. For more information on how Google collects and processes your data, visit https://www.google.com/policies/privacy/partners/
You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout
Communications and Emails
When we communicate with you about our website, we will use the email address you provided when you registered as a member or user. We may also send you emails with promotional information about our website or offers from us or our affiliates unless you have opted out of receiving such information. You can change your contact preferences at any time through your account or by sending us an email with your request to: -insert email-
Sharing Information with Affiliates and Other Third Parties
We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your NPD, which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. We may provide your PD to third-party service providers we hire to provide services to us. These third-party service providers may include but are not limited to: payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.
Sharing Information with Facebook and Google for Marketing Purposes
We may share your PD with third parties for similar audience marketing purposes. Similar audience marketing is also called lookalike audience marketing. The third parties we share your PD with for this type of marketing include Facebook and/or Google. Using your PD, for similar audience marketing or lookalike audience marketing helps us find new audiences (users and customers) based on similar interests to yours, this helps us improve our marketing services. Your PD is only shared with Facebook and Google for this type of marketing. By using our website and agreeing to our privacy notice, you are giving your consent for your PD to be used for the marketing purposes described within this section.
Legally Required Releases of Information
We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users or members; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.
Disclosures to Successors
If our business is sold or merges in whole or in part with another business that would become responsible for providing the website to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business.
We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.
Community Discussion Boards
Our website may offer the ability for users to communicate with each other through online community discussion boards or other mechanisms. We do not filter or monitor what is posted on such discussion boards. If you choose to post on these discussion boards, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you choose to disclose your PD through such postings. Also, PD you post on our website for publication may be available worldwide by means of the Internet. We cannot prevent the use or misuse of such information by others.
Retaining and Destroying Your PD
We only retain the personal information collected from a User for as long as the User’s email address is active on our mailing list, or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law.
In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the 2-year criteria, after your relationship with us ends.
We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Updating Your PD
You can update your PD using services found on our website. If no such services exist, you can contact us using the contact information found at the top of this notice and we will help you. However, we may keep your PD as needed to enforce our agreements and to comply with any legal obligations.
When using our website and submitting personal data to us, you may have certain rights under the General Data Protection Regulation (GDPR) and other laws. Depending on the legal basis for processing your personal data, you may have some or all of the following rights:
The right to be informed
You have the right to be informed about the personal data we collect from you, and how we process it.
The right of access
You have the right to get confirmation that your personal data is being processed and have the ability to access your personal data.
The right to rectification
You have the right to have your personal data corrected if it is inaccurate or incomplete.
The right to erasure (right to be forgotten)
You have the right to request the removal or deletion of your personal data if there is no compelling reason for us to continue processing it.
The right to restrict processing
You have a right to ‘block’ or restrict the processing of your personal data. When your personal data is restricted, we are permitted to store your data, but not to process it further.
The right to data portability
You have the right to request and get your personal data that you provided to us and use it for your own purposes. We will provide your data to you within 30 days of your request. To request your personal data, please contact us using the information at the top of this privacy notice.
The right to object
You have the right to object to us processing your personal data for the following reasons:
• Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
• Direct marketing (including profiling); and
• Processing for purposes of scientific/historical research and statistics.
• Rights in relation to automated decision-making and profiling.
Revoking Your Consent for Using Your PD
You have the right to revoke your consent for us to use your PD at any time. Such an optout will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to affiliates and business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as credit card processing, computer system services, shipping, data management services, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or third-party offers you may choose to accept. If you want to revoke your consent for us to use your PD, send us an email with your request to:
Protecting the Privacy Rights of Third Parties
If any postings you make on our website contain information about third parties, you must make sure you have permission to include that information in your posting. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified, if such postings violate the privacy rights of others.
Do Not Track Settings
Some web browsers have settings that enable you to request that our website not track your movement within our website. Our website does not obey such settings when transmitted to and detected by our website. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.
Links to Other Websites
Our website may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. These websites will likely have their own privacy notices. We have no responsibility for these websites and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy notices of these websites to see how they treat your PD.
Protecting Children’s Privacy
Even though our website is not designed for use by anyone under the age of 16, we realize that a child under the age of 16 may attempt to access our website. We do not knowingly collect PD from children under the age of 16. If you are a parent or guardian and believe that your child is using our website, please contact us. Before we remove any information, we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child is accessing our website, we will delete his/her information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor do we have any liability to do so.
Our Email Policy
You can always opt out of receiving further email correspondence from us or our affiliates. We will not sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business, or if our company files for bankruptcy.
Our Security Policy
We have built our website using industry-standard security measures and authentication tools to protect the security of your PD. We and the third parties who provide services for us, also maintain technical and physical safeguards to protect your PD. When we collect your credit card information through our website, we will encrypt it before it travels over the Internet using industry-standard technology for conducting secure online transactions. Unfortunately, we cannot guarantee against the loss or misuse of your PD or secure data transmission over the Internet because of its nature.
We strongly urge you to protect any password you may have for our website and to not share it with anyone. You should always log out of our website when you finish using it, especially if you are sharing or using a computer in a public place.
Use of Your Credit Card
You may have to provide a credit card to buy products and services from our website. We use third-party billing services and have no control over these services. We use our commercially reasonable efforts to make sure your credit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorized use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number.
California Privacy Rights
In addition to the rights provided for above, if you are a California resident, you have the right to request information from us regarding whether we share certain categories of your personal information with third parties for the third parties' direct marketing purposes. To the extent we share your personal information in this way, you may receive the following information:
(a) the categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and
(b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.
Effective January 1, 2020, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights in relation to their personal information, subject to limited exceptions. Any terms defined in the CCPA have the same meaning when used in this California Privacy Rights section.
• For personal information collected by us during the preceding 12 months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information. ClassTrack will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you services, charge you different prices for services or provide you a different level or quality of services.
• To the extent we sell your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You have the right to direct us not to sell your personal information. ClassTrack does not sell your personal information in its ordinary course of business and will never sell your personal information to third parties without your explicit consent.
Should ClassTrack engage in any of the activities listed in this section, your ability to exercise these rights will be made available to you in your account settings. You can exercise your rights by going contacting us via email so that we may consider your request.
If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. We will respond to your authorized agent's request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.
Transferring PD From the European Union
(PD) that we collect from you may be stored, processed, and transferred between any of the countries in which we operate, specifically India. The European Union has not found the United States and some other countries to have an adequate level of protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. For European Union customers and users, with your consent, your PD may be transferred outside the European Union to the United States and or other countries. We will use your PD to provide the goods, services, and/or information you request from us to perform a contract with you or to satisfy a legitimate interest of our company in a manner that does not outweigh your freedoms and rights. Wherever we transfer, process or store your PD, we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our privacy notice. By using our website, services, or products, you agree to the transfers of your PD described within this section.
We reserve the right to change this privacy notice at any time. If our company decides to change this privacy notice, we will post those changes on our website so that our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email (sent to the email address on file in your account). Otherwise we will use and disclose our users’ and customers’ PD in agreement with the privacy notice in effect when the information was collected. In all cases, your continued use of our website, services, and products after any change to this privacy notice will constitute your acceptance of such change.
Questions About Our Privacy notice
If you have any questions about our privacy notice, please contact us using the information at the top of this privacy notice.