Privacy Policy

Privacy

Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose personal information. The following is our privacy policy at Code Learner.

• Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.

• We will collect and use personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.

• We will only retain personal information as long as necessary for the fulfillment of those purposes.

• We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.

• Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-todate.

• We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

• We will make readily available to customers information about our policies and practices relating to the management of personal information.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

How Long Do We Store Your Personal Data?

We will keep your personal information only as long as we consider it necessary to fulfill our purposes as described above under “Why do we process your personal information”. Then we will delete or, in some cases, anonymize your personal information. We regularly check whether we have saved personal information to be deleted. Since we process your personal information for different purposes, the actual period of personal information will vary.

Typically, the following deletion deadlines apply:

Data type What is it? Deletion deadline
User data User data is information about, how you use the service and which orders you make. Until the account is deleted (is processed in 5 years)
Customer service data Customer service data is information that you provide when you are in contact with Code Learner's customer service and voice recordings made for educational purposes. 3 years (call logs and text dialogs)

1 month (voice recordings)
Account information Account information is information about your account, such as username, password and purchase information made in the
Code Learner service.
Until deletion of account
Transaction data Transaction data is information about transactions made on your account in connection with purchases made in the
Code Learner service
10 years

Data Controller

Gyrissmo Limited, a legal entity incorporated under the laws of Cyprus under registration number HE410696, having its registered office at Navarinou 17A, Agios Andreas, Nicosia 1100, Cyprus, will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Service.