This statement (“Privacy Policy”) explains what we do with students’ personal data that we receive through the educational services (“Services”), provided by Maven Academies (part of Maven Academies Company), and how students enrolled in a course provided by Maven Academies can exercise their rights therein.

We are Maven Academies, a limited liability company wholly owned by Maven Academies Company. In this text, “we” refers to Maven Academies. We provide an online learning platform for students looking to advance their education via a platform known as “Maven Academies”. We are the controller of your data. This means that we are responsible for determining how your personal information is collected, stored and used. From time to time, we may engage third parties to process your information, and we may process your information ourselves (as further described below).

If you have any questions or concerns about the information contained in this Privacy Policy, or about our handling of personal data in general, or if you would like more detailed information, you should email us at [email protected] to bring it to the attention of our Privacy Officer.

By registering an account with Maven Academies and in turn using our Services, we will collect the following information from you (“Personal Data”) :

• Your name
• Your email address
• Social media accounts and information (if you log in/register using social media, specifically Facebook or Google)
• Your personal photo (optional)
• Records of your visits to Maven Academies and engagement with educational content, such as pages, videos, ratings, posts, comments and any other interactions.
• Details of the grades you have received in assessments you take in Maven Academies.
• Online snapshots of interactions you have had in online lecture videos, called “Pause and Find Events”
• Records of teachers and experts creating virtual classrooms on Maven Academies or any of the assistant applications.
• Information you add to the child accounts you create for your children on Maven Academies.

If you are a parent or guardian creating an account for your child, the following (“Personal Data”) will be collected for the child :

• Child’s name
• Child’s email address
• Child’s gender (optional)
• Child’s personal photo (optional)
• Child’s academic grade
• Country of curriculum you want the child’s programs to follow

Maven Academies will never share a child’s Personal Data externally, or any link between the child’s data and the parent’s data.

When using your personal data, we process it on the following bases :

• To perform a contract to which you as the data subject are a party (including in relation to keeping records detailing your learning progress and performance for the purpose of maintaining course progress and certificates)
• In the legitimate interest of Maven Academies, the following activities are carried out :
• Internal research purposes, for example to improve the design and operation of courses.
• The following research and marketing purposes (unless you decide not to participate when registering or later) :
• Internal research into how the Maven Academies platform is used.
• To send you updates regarding the online courses offered by Maven Academies.
• Improve the user experience of the Maven Academies platform.
• Publish scientific research in journals or conferences. No data that identifies you is shared in a scientific publication. We only publish aggregated or anonymized data.

We will never collect any unnecessary personal data from you or process your information in any way other than as set out in this Policy.

We do our best to keep the personal data we store accurate and complete, and to ensure that all your personal data is kept up to date. However, you can help us by contacting us immediately if there are any changes to your personal data.

We will not be liable for any losses you incur as a result of any inaccurate, incorrect, incomplete or incorrect personal data you provide to us.

For EU users and users in other countries with data protection legislation that requires the deletion of user personal data after some time, your account data will be automatically deleted after 7 years of inactivity. Inactivity is defined as no interaction with the course content. After 7 years of inactivity, we will contact you with one month’s notice to inform you that your personal data will be deleted from the computers on which it is stored and give you the option to request that your personal data be retained for a further 7 years. For users in all other countries, Maven Academies will retain your account data until you submit a request to us to delete your data through the Site, after which your data will be deleted in accordance with the timeline provided by the Site when you request deletion.

Maven Academies may shorten the retention period for your personal data depending on the amount, nature and sensitivity of your personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.

We may from time to time share your personal data with the following parties for the purpose of improving course content and marketing operations :

• Our internal education management team.
• Our internal marketing team.
• Our internal leadership team.
• Third parties with whom we partner for the purposes of creating, running or evaluating a course (including experts, teachers, teaching assistants and staff of organizations that partner with Maven Academies for the purpose of a course you are enrolled in), and marketing agencies with whom we partner for Maven Academies’ own marketing needs.

All third parties receiving personal data from Maven Academies sign a data processing agreement with Maven Academies stating that your personal data will only be used for the purposes for which Maven Academies has contracted in accordance with the General Data Protection Regulation (GDPR), or any other applicable data regulations, and that the third party will delete your personal data within 10 days of termination or completion of the contract.

We may also from time to time share your personal data (in anonymized form) with external educational researchers for the purpose of conducting educational research.

We only transfer your personal data outside the EEA where we have a legal basis to do so, and where we require that your personal information is protected to the same standard as it would be in the EEA. We do this by entering into data sharing agreements with recipients of your personal data outside the EEA, which comply with the European Commission’s standard clauses for the transfer of personal information.

If you would like further details about our transfer of your personal information outside the EEA or details of the safeguards in place in relation to your personal information, please contact the Privacy Officer at Maven Academies.

We only transfer your personal data outside the EEA where we have a legal basis to do so, and where we require that your personal information is protected to the same standard as it would be in the EEA. We do this by entering into data sharing agreements with recipients of your personal data outside the EEA, which comply with the European Commission’s standard clauses for the transfer of personal information.

Except to the extent required by applicable law, we reserve the right to update this policy to reflect changes to our information practices by prominently posting a notice of the update on our Services, and obtaining your consent, as appropriate. Any updates will become effective immediately upon posting updates to this Policy and will apply to all information collected about you, or where applicable, upon your consent. You agree to review this Policy periodically. If we make any changes to this Policy, we will change the “Last Updated” date above.

European and UK privacy laws give you certain rights in relation to the data we hold about you.

• With some exceptions, you have the right to receive a copy of the personal data we hold about you. We may charge a reasonable fee for additional copies of that data after the first copy, based on our administrative costs. Where the data is data that you have provided to us, you have the right to receive a copy of it in a common electronic format, and to provide copies of it to other people if you wish.
• You have the right to have the personal data we hold about you corrected if it is factually inaccurate.
• In some circumstances, you have the right to have the personal data we hold about you erased (the “right to be forgotten”). This right is generally not available where we still have a valid legal reason to retain the data (for example, if we are obliged to do so by law).
• You have the right to ask us to stop using your personal data for marketing purposes.
• You also have the right in some circumstances to request temporary restrictions on how we process your personal data, for example, if we are processing it on the basis of our legitimate interest, and you contest our assessment that our interest is not overridden by your fundamental rights and freedoms.
• If we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop processing unless we have another legal basis to proceed on. In some cases, the only way for Mevin Academies to stop such processing will be to terminate your accounts. Mevin Academies will ask for your confirmation before terminating your account via the email address from which you request to withdraw your consent. If you do not provide written confirmation within 21 days for Mevin Academies to terminate your account, your request to withdraw your consent will be deemed to have been revoked.

These rights are summarized below :

For your protection and the protection of others, we may ask you to verify your identity before you exercise these rights. If you are not satisfied with how we handle your personal data, you have the right to contact us to request a solution.