Privacy Policy

UNLOK – PRIVACY NOTICE

Kenes Education B.V. including our subsidiaries and affiliates worldwide (“Kenes“, “we“, “our” or “us“), puts great efforts in making sure that the personal data we process is safe and used properly, and that our data practices are properly communicated.

We respects your privacy and are committed to protecting your personal data. This Privacy Policy describes how we collect, store, use and disclose personal data, and informs you as to how we look after your personal data when you visit our website including any data you may provide through this website when you sign up to any of our activities and services or when you interact with any of the online forums, registration forms, sign-up forms, and other digital activities carried out through this website (“Activities” or “Services“). This Privacy Policy also describes your choices regarding the use, access and correction of your personal information and informs you about your privacy rights and how the law protects you.

It is important that you read this Privacy Policy so that you are fully aware of how and why we are using your personal data.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can always edit your registration and and update your profile within the system.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Partners, or Service Providers (per Section 7 below), please avoid any interaction with us or any use of our Services. However, if you fail to provide certain data when requested, we may not be able to provide our services. In this case, we will notify you if this is the case at the time.

Personal data, or personal information, means any information about an individual from which that person can be identified. To the extent that any of the information solely relates to a non-human entity, we will not regard it as personal data, and this Privacy Policy will not apply to it. It also does not include data where the identity has been removed (anonymous data).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, title, date of birth and gender, and any other information you may provide us with.

Contact Data includes postal address of either you or your institution, email address, telephone numbers and VAT number (if applicable), picture, and any additional information submitted by the you.

Financial transaction Data includes details about payments to and from you and other details of services you have purchased from us, that may consist of credit card or bank account number, IBAN, SWIFT code and payment preferences.

Profile Data includes your username (email) and password (which is stored in an encrypted form), company name, specialty, professional role, educational/employment/professional background such as title, license, your interests, preferred language, other information used for authentication and access control, if applicable, profession, professional interests, preferences, feedback and survey responses, any comments on blogs, chat rooms or other similar forums, correspondence with us (e.g., for user experience, support and training purposes and any other data you upload), and event schedule.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website and Services, including connectivity, technical and aggregated usage data such as, IP addresses, geolocation, device data (such as type, OS, device id, browser version, locale and language settings used), performance and activity logs, session recordings, activity on our Services, and the cookies and pixels installed or utilized on your device.

Marketing and Communications Data includes your preferences in receiving marketing from us or third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data (as the term is defined in the GDPR) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Kenes processes the personal data described in section 2 as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services. These include understanding how our Services are used, and how our Services, campaigns and other activities are performing; gaining insights which help us dedicate our resources and efforts more efficiently; marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Services, ourselves and the organizations and individuals we engage with.

Important note: Please note that if you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing personal data in the manners described in this Policy (in general, or specifically with respect to the types of personal data you expect or elect to be or have processed by or via the Services), your acceptance of our Terms of Use and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed herein. If you wish to revoke such consent, please contact us at dpo-kenes@popovarnaudov.bg.

At certain cases our Partners shall further process the personal information for the management of their operation including to further the goals of the Partner, statistical analysis, promotion of future educational initiatives and developing the Partner membership. Please see section 13 for further explanations regarding the role of our Partners as Joint-Controllers concerning some of the personal information we collect and process under this Privacy Policy.

We use different methods to collect data from and about you including through:

Direct interactions. Direct interactions. You may provide us with personal information by registering to our website, filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you: (a) create an account with us; (b) access the Services; (c) subscribe (or are subscribed) to the Services; (d) request marketing to be sent to you; (e) enter a promotion, survey, blog, chat room or any other similar forum; or (f) give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

Third parties: We work closely with third parties (including, for example, business partners and sub-contractors in technical, and payment services, advertising networks, analytics providers, academic institutions and search information providers) from whom we may receive information about you.

We use Personal Information for the purposes detailed in section 3 above, relying on the legal bases specified there. Specifically, we use your data for the following purposes:

• to facilitate, operate, activate, and provide our Services, including determining your initial and continued eligibility to use our Services;
• to authenticate your identity and allow you to access and use our Services;
• to process your activities such as event and course registration, attendance and accreditations;
• to provide you with customer care, assistance and technical support services;
• to further develop, customize and improve the Services, and to improve your user experience, based on common or personal preferences, experiences and difficulties;
• to facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively;
• to contact you with general or personalized service-related messages, or with promotional messages, in accordance with Section 10 below, and to facilitate, sponsor and offer certain events and promotions;
• to support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
• to create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we or our Partners may use to provide and improve our respective services, or for any other purpose (such as estimating and reporting total audience size and traffic);
• to comply with our legal, regulatory, compliance and contractual obligations;
• as otherwise described to you at the point of collection.

We do not sell or share your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA) or the California Privacy Rights Act (CPRA).

We and our Partners retain your personal data for as long as it is reasonably necessary to provide the Services; to maintain and expand our relationship and provide you with our Services and offerings; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations, and where applicable, also with our Partner’s reasonable instructions and as further stipulated in our Data Processing Addendum (DPA) and other commercial agreements with such Partner.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at dpo-kenes@popovarnaudov.bg.

We will share your personal data with the following recipients to achieve the purposes set out in section 3 above.

Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services.

Service Providers: we may engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platform, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, on-site contractors, billing and payment processing services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems, and our business, legal, financial and compliance advisors (collectively, “Service Providers “). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating, supporting and enhancing our Services, and may only use it for such purposes.

Third-Party Websites and Services: our Services may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third-party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and third-party services. To the extent that our Service Providers contact you in order to offer or promote our Service, they may additionally interest you in their own services. Should you decide to engage in such activities with Kenes’s Service Providers, please note that such engagement is beyond the scope of Kenes’s Terms and Use and Privacy Policy and will therefore be covered by our Service Provider’s terms and privacy policy.

Sharing Data with our Partners and their representatives:  data is shared with the administrator or other representatives of the relevant Partner, meaning, such representatives may access it on behalf of the Partner, and will be able to monitor, process and analyze the personal data contained therein. Please see section 13 for further explanations regarding the role of our Partners as Joint-Controllers concerning some of the personal information we collect and process under this Privacy Policy.

Sharing Data with other Participants: registration and participation in some of our services is only allowed for identified Participants (i.e., no anonymous participation is allowed). By participating in any of these services you are required to identify yourself to us and to the other Participants, by name, country of origin or company, professional interest, or any additional information. We also may make public use of personal photo image of participants in certain events. These details may be visible to other registered attendees in online and recorded events.

Sharing Public Information: we may share information that you voluntarily make public, including information that you post on any blogs, message boards, chat rooms, educational portals or other similar forums whether or not such forums are operated or owned by Kenes. Since such public information can be accessed by others and used by any member of the public, such use by third parties is beyond our control. With your consent, we may also display personal testimonials of satisfied Partners on the Event website along with your name

Protecting Rights and Safety: we may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Kenes, any of our Partners, their representatives, other users, or any members of the general public.

Kenes Subsidiaries and Affiliated Companies; Change of Control: we may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Kenes Education B.V. or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant and/or a potential investment, personal data may be shared with the parties involved in such an event. If we believe that such an event might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

Additional Sharing: Kenes may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

We and our authorized Service Providers (per section 7 above) may transfer your personal data outside your country of residence in order to provide the Services. When we transfer personal data out of the EEA or the UK, we ensure an appropriate degree of protection is afforded to it by implementing at least one of the following safeguards:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or UK Information Commissioner’s Office (as applicable); and/or

Where we use providers based in countries outside of the EEA or the UK, that have not been deemed to provide adequate level of protection by the said entities, we only transfer data to them under the scope of a Data Processing Agreement which incorporates the appropriate Standard Contractual Clauses, or another legally applicable data transfer mechanism, which require them to provide protection to EEA/UK data to the standard expected within the EEA/the UK.

Kenes and our Service Providers use cookies and other technologies for performance, tracking, analytics, and personalization purposes in order to provide you with a better experience. We may share non-identifiable/aggregated extracts of such information with our partners for our legitimate business purposes.

Cookies: cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session – these are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.

Google Analytics: we use Google Analytics to collect information about the use of our Services. Google Analytics collects information such as how often you visit the Services, which pages you visited when they do so, and which other sites they used prior to coming to our Services. We do not merge the information collected through the use of Google Analytics with personally identifiable data. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt-out of these analytics services is available here.

To learn more about our cookies practices, please visit our Cookie Policy.

We engage in service and promotional communications, through e-mail, phone, SMS and notifications.

Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, payment issues, login attempts or password reset instructions, etc. Our Partners may also use our Services to send messages and other updates regarding your use of the Services.

Notifications and Promotional Communications: we may also notify you about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., SMS, phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive promotional communications, you may notify Kenes by sending an e-mail to: dpo-kenes@popovarnaudov.bg.

We and our hosting services implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. When personal information is transferred to us over the Internet, we encrypt it using Transfer Layer Security (TLS) encryption technology or similar technology. These measures provide sound industry-standard security, however, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third-parties.

Individuals have rights concerning their personal data any applicable law, including the EU General Data Protection Regulation (GDPR), or the California Consumer Privacy Act (CCPA)/ the California Privacy Rights Act (CPRA), when entering into effect. Such rights include the right to request access, rectification or erasure of your personal data held with Kenes, or to restrict or object to such personal data’s processing, or to port such personal data, the right to equal services and prices, or the right to not being discriminated due to the exercise of the said rights (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority. If you wish to exercise any of these rights please contact us by e-mail at: dpo-kenes@popovarnaudov.bg.

Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Please also note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 3 above. We may redact from the data which we will make available to you, any personal data related to others.

Certain data protection laws and regulations, such as the GDPR and the CCPA/CPRA typically distinguish between two main roles for parties processing personal data: the “Data Controller” or “Business”, who determines the purposes and means of processing; and the “Data Processor” or “Service Provider”, who processes the data on behalf of the Data Controller.

Kenes is the controller and responsible for your personal data.

In addition, Kenes collaborates with Partners, mostly healthcare associations or other organizations in healthcare such as publishers, hospitals or universities, to provide within the Services e-learning communities and related services (the “Joint Services“). Concerning the Joint Services, Kenes and the applicable Partner may act as a Joint Controller, and both parties shall be able to process the Personal Information relevant to the use of the Joint Service. In this case, Kenes shall have an arrangement with the Partner according to which Kenes is responsible for the exercise of rights of data subjects, including the provision of information, as required by applicable law, concerning the collection and use of personal data by the parties. Each Party is responsible for taking adequate technical, physical and organizational security measures to protect personal data against unauthorized or unlawful access, alteration, deletion, damage, loss, or inaccessibility with respect to Personal Information processed by it.

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: while our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third-parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

Our Services are not designed to attract children under the age of 16: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at dpo-kenes@popovarnaudov.bg.

EU Representative: Kenes Bulgaria has been designated as Kenes’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Kenes Bulgaria may be contacted only on matters related to the processing of personal data. To make such an inquiry, please send an email to bulgaria@kenes.com.

Questions, concerns or complaints: if you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Kenes, you can contact us at: dpo-kenes@popovarnaudov.bg

Effective Date: 1.12.22