​Introduction

We respect your right to privacy and we understand that, when you use our products and services (hereinafter “Services”) or otherwise interact with us (for example, by viewing our courses or sharing your details), you prefer to control the way you share your personal information (“Personal Data”) and preferences.

 

The terms “we”, “us” and “our” refers to Early Birds Music Academy Owner and iSpring Market Account Owner (the platform). The terms “user”, “you”, and “your” refer to customers over the age of 18. The terms "the student", "your child" refer to the dependents of the user that are below the age of 18.

 

We provide this Privacy Policy to inform you of our practices with respect to the collection and use of your Personal Data.

 

We comply with the Regulation 2016/679/EU of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”). We act as both a data controller and a data processor under GDPR.

 

Online courses with Ispring Solutions:

We collect information globally and primarily store that information on the servers based in the United States and Germany. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. The Personal Data of individuals from EEA and Switzerland are stored on servers based in Germany and processed in the United States. Regardless of where your information is stored or processed, we apply the same protection described in this Policy. We offers European builds of desktop products to individuals from EEA and Switzerland to store the information we collect from your use of the Services on the servers in Germany. We also use the model contract clauses approved by European Commission as a means of ensuring adequate protection when transferring data outside of the EEA and Switzerland. By incorporating model contract clauses into a contract established between the parties transferring data, personal data can be protected when transferred outside the EEA to countries which have not been deemed by the European Commission to adequately protect personal data.

 

Agreement to this Policy

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Policy. This Policy may change from time to time. Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

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Notice to End Users

We are the administrator of the web based services and are responsible for the accounts in web based services over which we have control. Please direct your data privacy questions to us, as your use of the web based services is subject to our policies.

The administrator of the account in web based services will assert administrative control over your account and use of the web based services.

You will be able to change the email address associated with your account only upon the administrator’s approval.

Please contact us for more information.

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How we may collect information about you in our role as data controller

We collect information about you and determine the purposes and means of processing your Personal Data in our role as data controller when you input it into the Services or otherwise provide it directly to us. 

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Site account and Profile Information:  We collect information about you, when you sign-up for or make purchases through the Services. Signing up with the name of the Student ensures the best Services are given. With regards to online content,  certification is based on the data supplied at sign up.

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Subscription to our newsletters and webinars. We collect information about you, when you subscribe to our newsletters and webinars. You can set your communication preferences from your site account or opt-out at any time.

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Information we collect automatically when you use the Services

We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services. 

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Your use of the Services: We keep track of certain information about you when you interact with any of our Services. This information includes the features you use; frequently used search terms; and how you interact with others on the Services. 

 

Why we process your personal information in our role as data controller

We process your Personal Data for the following purposes:

- Processing of orders and provision of Services such as educational reporting;

- Conducting market research, conducting retention and customer satisfaction surveys, conducting marketing activities (including through email newsletters, social media and onsite/offsite and online/offline advertisement), conducting sales activities (including analysing your Personal Data and your use of our Services for making (personalised) offers and quotes with the aim of entering into a customer relationship, and/or maintaining, renewing or expanding a customer relationship);

- Communicating with customers (a) to provide information about our Services, (b) to provide information about offers, orders, provision of Services, order status and payment, (c) to provide support and maintenance services, (d) to handle complaints, and (e) to answer questions from (potential) customers;

- Investigating and processing suspected violations of acceptable use of our Services;

- Complying with statutory obligations, including (a) provision of data to authorised authorities in the context of criminal investigations, (b) complying with (applicable) data retention obligations, and (c) the provision to third parties of Personal Data concerning customers in connection with an infringement of these third parties’ rights.

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How we share your personal information in our role as data controller

We may share Personal Data about you with:

- Partners or agents involved in delivering the Services;

- Law enforcement agencies, regulatory organisations, courts or other public authorities to the extent required by law;

- A customer, if you notify us that this customer uses our Services violates the acceptable use of our Services or applicable law;

- A third party that has claimed that your use of our Services violates the acceptable use of our Services or applicable law (to the extent such sharing is required by law);

- In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

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Legal bases for processing

If you are an individual in the European Economic Area (EEA) or Switzerland, we collect and process information about you only where we have legal bases for doing so under applicable EU laws.  The legal bases depend on the Services you use and how you use them. To process your information as described above, we rely on the following legal bases:

- Performance of a contract: the use of your information is necessary to provide you the Services, customer support and personalised features. If you order and use our Services, we will use your information to carry out our obligation to complete and administer that Services under the contract that

we have with you;

- Legitimate interests: the processing is necessary for the purposes of the legitimate interests pursued by us, namely for information security. We also want to provide you with the best suitable content of the website, to improve and promote our products and services and the content on our website, and for administrative, fraud detection and legal purposes;

- Consent: we may rely on your consent to use your Personal Data for specific purposes, for example, for sending newsletters and for certain direct marketing purposes.

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How we store and secure information we collect

Information storage. We use data hosting service providers in the United States and Germany to host the information we collect, and we use technical measures to secure your data.  

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Technical and organisational security procedures and data transfers.

We observe reasonable procedures to prevent unauthorised access to, and the misuse of Personal Data. We use appropriate business systems and procedures to protect and safeguard the Personal Data. We also use security procedures and technical and physical restrictions for accessing and using the Personal Data on our servers. Only authorised personnel are permitted to access Personal Data in the course of their work.

 

Managed accounts: If the Services are made available to you through an organisation (e.g., your employer), we retain your information as long as required by the administrator of your account. 

 

Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your site account. 

   

How you can access and control your information

Subject to some limits, you have certain rights regarding your Personal Data and the processing thereof. PLEASE NOTE THAT OUR CUSTOMERS CONTROL AND MAINTAIN ACCESS TO THEIR DATA THAT IS STORED BY US, AND WE MAY NOT HAVE ACCESS TO THE DATA MAINTAINED BY OUR CUSTOMERS OR EVEN TO KNOW WHAT DATA IS BEING MAINTAINED.

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information.

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Your rights:

- You can access and update your information in your site account at any time;

- You can deactivate your site account, if you no longer wish to use our Services;

- You can request for what information we have collected about you;

- You can request that we make changes to the Personal Data you have seen, but cannot change in your site account;

- You also have the right to obtain from us the erasure of your Personal Data (right to be forgotten);

- In addition, you may, under certain circumstances, have the right to restriction of the processing of your Personal Data;

- You have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data;

- You have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller when the processing is based on your consent or is necessary for the performance of a contract (the right to data portability);

- You can opt out of promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your site account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. 

Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your site account settings.

Consent and withdrawal of consent. You are entitled to withdraw your consent at any time by giving us notice. Upon receipt of a notice where your consent is withdrawn, we will without undue delay stop processing your Personal Data to the extent it is required under law. Please use the contact information at the bottom of the page should you wish to withdraw your consent given under this privacy statement.

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Our policy towards children

The Services are not directed to individuals under 16 without parental control and consent. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us using the contact link at the bottom of this page.​

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Changes to this Policy

We may change this Policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We will also keep prior versions of this Policy in an archive for your review.  We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

 

Contact Us if you have questions or concerns about how your information is handled.

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Updated: 3/8/24