Last update: 09.09.24
PRIVACY PRACTICES OVERVIEW
This document presents the privacy policies of the aiwiselearning.com website, herein referred to as the "Website." It delineates our methodologies in accumulating and utilizing the personal data you furnish while engaging with the VARYN LIMITED Website for accessing VARYN LIMITED Service. Additionally, it details your options regarding our handling of your personal information, including ways to influence and oversee this process. Visitors are not mandated to submit personal information merely by browsing the Website. Nonetheless, accessing VARYN LIMITED Service via our Website necessitates the collection and processing of personal data, for which we generally seek the consent of the data subject. According to Article 37/1 of the GDPR, VARYN LIMITED is not required to designate a Data Protection Officer (DPO), yet we have named a delegate responsible for overseeing GDPR adherence. This individual can be contacted for any data protection inquiries or issues at [email protected] email. VARYN LIMITED commits to abiding by the General Data Protection Regulation (GDPR) and applicable local data protection legislation, particularly in handling sensitive information such as names, addresses, emails, phone numbers, or payment details of any individual ("data subject"). Our Privacy Policy is designed to transparently communicate how we collect, use, and manage such personal data, including its purpose and extent. It further informs data subjects (users) about their rights concerned with their personal data. Serving as the data controller, VARYN LIMITED has instituted robust technical and organizational safeguards to ensure the highest protection of personal data entrusted to us on this Website. In this Privacy Policy, the terms "We," "Us," "Our," and "VARYN LIMITED" represent VARYN LIMITED. It is pertinent to note that our services are not intended for minors, and our Website does not cater to individuals under the age of 18.
INFORMATION WE COLLECT
In our efforts to bolster VARYN LIMITED's adherence to GDPR requirements, we place considerable emphasis on the principle of data minimization to protect personal data. We carefully delineate specific categories of personal data that are pivotal for us to render our services effectively. The types of personal details we collect are as follows:
- User's Complete Name: We collect both the first and last names of the user, fundamental for account registration and personalized user experience.
- Email Address: This is essential for account setup, enabling users to access VARYN LIMITED's Service and receive important notifications.
- Billing Information: To facilitate transactions, we require comprehensive billing details such as the user's address, zip code, city, country, and phone number.
- Payment Method: It's vital to note we only retain partial information related to the selected payment method and do not store complete credit card details.
- IP Address and Location Data: Procured from the user's Internet Service Provider (ISP), the IP address is key for user identification. Additionally, location data aids in understanding user engagement across different regions.
Upon signing up for the VARYN LIMITED Service, it is imperative that this crucial personal information is provided, classified under User Information. This includes recognizable details such as your full name and email address, which VARYN LIMITED meticulously proceeds to collect, process, and store for account creation and management purposes. Additionally, Billing Information comprises personal details that are partially retained by VARYN LIMITED and partially managed by external payment processors.
The utilization of your Personal Data serves a myriad of purposes, aimed at enhancing your experience. These encompass tailoring the website to better suit user needs, sending pertinent emails regarding registration status, password modifications, and payment confirmations, facilitating communication about your interactions with the Service, and sharing aggregated statistical data with our partners to improve service delivery. This comprehensive approach reaffirms our unwavering commitment to ensuring personal data security and adherence to stringent data processing agreements (DPAs).
HOW WE USE YOUR INFORMATION
At VARYN LIMITED, safeguarding user privacy and ensuring the autonomy over their personal information are pivotal aspects of our operations. Our data management practices revolve around securing the explicit consent from those we serve, commonly referred to as data subjects or users. Such consent is to be explicitly conveyed through affirmative action, indicating a well-informed, distinct agreement to the processing of personal information. A "data subject" or "user" is defined as any identifiable individual whose personal data is processed by VARYN LIMITED. This processing can encompass an extensive range of activities including collection, storage, organization, modification, access, review, use, dissemination, combination, and deletion of data, executed manually or with automated systems. Personal data encompasses any piece of information that can directly or indirectly unveil the identity of a data subject or user. This spans from their name and identification numbers to location data, online identifiers, and characteristics of physical, psychological, genetic, mental, economic, cultural, or social attributes. Our dedication to rigorous data management underscores our commitment to preserving user privacy and rights, ensuring that data subjects are fully informed and consent willingly to our data processing activities. Through these measures, VARYN LIMITED remains compliant with GDPR and other data protection laws, maintaining the highest imperatives of data privacy and security.
HOW WE SHARE YOUR INFORMATION
In the spirit of transparency and accountability, it is important for VARYN LIMITED to communicate how and with whom your personal information may be shared. Foremost, we ensure that sharing is conducted within the legal confines prescribed by data protection regulations such as GDPR, ensuring that your privacy rights are steadfastly protected.
Your information may be shared with third-party service providers who perform services on our behalf. These include, but are not limited to, cloud storage providers, marketing and analytics partners, and software development services. All third-party partners are rigorously vetted to ensure they meet our high standards of data protection, and they are bound by contractual agreements to ensure they process your information based solely on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures.
In addition, we may be required to disclose your information to law enforcement, regulatory bodies, or the courts, where it is necessary to comply with legal obligations or to protect the rights, property, or safety of VARYN LIMITED, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
It is our policy to only share the minimum information necessary for the third party to provide their services or comply with the law. We do not sell or rent your personal data to marketers or third parties.
Lastly, in the event that VARYN LIMITED undergoes a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information may be among the assets transferred. However, we will ensure that the privacy promises set forth in this policy will continue to apply to your information and any acquirer would be obligated to adhere to these commitments.
YOUR DATA PROTECTION RIGHTS
At VARYN LIMITED, we believe it's essential for our users to feel empowered and informed about their data rights. The principles of transparency and control are central to our data protection practices. Below, you will find detailed information about the rights you hold concerning your personal data and how you can exercise these rights:
Right to Access
You have the Right to Access your personal data that VARYN LIMITED holds. This means you can request a copy of all the data we have about you, including how we use it and who we share it with. This right enables you to understand the extent of data processing carried out by VARYN LIMITED, thereby ensuring transparency. To exercise this right, simply contact our data protection officer with your request. We are committed to providing you with a response without undue delay and within one month of receiving a valid request. This service is usually provided free of charge.
Right to Rectification
You possess the Right to Rectification; if you find that any personal data we hold about you is inaccurate or incomplete, you are entitled to request that we correct or complete it. This ensures that your information remains up-to-date and accurate, reflecting your current status accurately. To initiate this process, please reach out to our data protection team, and we will make the necessary adjustments as swiftly as possible. Your right to rectification is fundamental to maintaining the integrity of your personal data.
Right to Restrict Processing
The Right to Restrict Processing grants you the authority to limit the way VARYN LIMITED uses your personal data. This right is particularly relevant when you dispute the accuracy of your data or question the legality of the processing. It enables you to request a halt on data processing until your concerns are addressed. Exercising this right ensures that your data is not used in a manner you find inappropriate or incorrect while disputes are being resolved. To request a restriction on processing, contact our data protection officer with specific details of your request. We prioritize these requests to ensure your data is handled according to your wishes.
Right to Data Portability
The Right to Data Portability allows you to obtain and reuse your personal data for your own purposes across different services. You can request that VARYN LIMITED provides your data in a commonly used and machine-readable format, or you can ask for the data to be transferred directly to another organization, provided it is technically feasible. This ensures your flexibility and control over your personal data.
Right to Object
The Right to Object grants you the ability to oppose the processing of your personal data by VARYN LIMITED under certain conditions. If you believe that your data is being processed for direct marketing, research, or in a way that infringes upon your rights, you have the full authority to file an objection. Upon receiving an objection, VARYN LIMITED will cease processing your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or if the processing is for the establishment, exercise, or defense of legal claims. To exercise this right, please contact our data protection office with your specific concerns.
Rights Related to Automated Decision Making and Profiling
The Rights Related to Automated Decision Making and Profiling provide you with the ability to not be subject to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This right ensures that you have a say in decisions that impact your life and that any decision-making processes involving your personal data are fair and transparent. If you wish to challenge or request human intervention in any such decision, please reach out to our data protection officer directly.
COOKIES AND TRACKING TECHNOLOGIES
Cookies and pixel tags play a crucial role in enhancing the online user experience and are pivotal for understanding user behavior and improving digital marketing strategies. At VARYN LIMITED, we are committed to transparently utilizing these technologies while prioritizing user privacy and data protection.
Cookies, small text files stored by your web browser, enable our website to remember your preferences and settings, making your subsequent visits more convenient and personalized. They are essential for functionalities such as keeping you logged in during your session, remembering your language preferences, and facilitating smooth transactions.
Pixel tags, also known as web beacons or clear GIFs, complement cookies by tracking user interactions on our website and in our emails. They help us understand how users engage with our content and which parts of our communication are most relevant. This data informs our content strategies and helps us deliver more targeted and useful information to our users.
We use both session cookies, which expire once you close your browser, and persistent cookies, which remain on your device for a set period or until you delete them. This mix ensures efficiency in both immediate user experience and long-term preferences management.
Understanding that privacy is a paramount concern for our users, we offer comprehensive options for managing cookies. You can adjust your browser settings to reject new cookies, receive notifications about new cookies, or disable existing ones. However, it's important to note that disabling cookies might restrict access to certain parts of our website, potentially affecting your user experience.
For those interested in a deeper level of control, tools and websites such as www.allaboutcookies.org and www.youronlinechoices.com provide extensive information on cookie management and privacy settings across various browsers and platforms.
Our Cookie and Pixel Tag Policy is designed to respect your privacy choices while ensuring a seamless and personalized online experience. By allowing users the ability to manage their cookie preferences, we aim to foster trust and transparency. Whether you choose to enable or disable cookies, VARYN LIMITED remains dedicated to providing high-quality, tailored services that meet your needs and expectations.
DATA SECURITY
At VARYN LIMITED, we understand that the digital realm is not just a space for connection and innovation but also a field where security challenges thrive. Protecting your service usage privacy and securing your personal information against unauthorized access, disclosure, or theft is a cornerstone of our commitment to you. To achieve this, we employ a comprehensive strategy that addresses data theft, misuse, and other forms of compromise.
One critical aspect of our data security policy involves a meticulous approach to collecting, storing, and processing user data. We ensure that only the necessary information is collected, minimizing the risk associated with data breaches. All data stored on VARYN LIMITED's servers are encrypted, ensuring that, in the unlikely event of a breach, the information remains inaccessible to unauthorized parties.
Our dedication to security extends to our stringent compliance with global privacy laws and regulations, such as the General Data Protection Regulation (GDPR) in the European Union. This compliance framework mandates the responsible handling of personal data, ensuring transparency with our users about how their information is used and safeguarded.
Despite our rigorous security protocols, we recognize that there are scenarios where we may need to disclose personal information. These situations are carefully managed and include:
- Fulfilling legal duties or responding to legitimate legal requests and proceedings that involve us.
- Investigating potential breaches of privacy policy or instances where our service could be exploited for illegal activities.
- Probing activities suspected of being fraudulent.
- Protecting the rights, property, or safety of VARYN LIMITED, our employees, our users, or the public.
In the case of significant organizational changes, such as mergers, acquisitions, or the dissolution of the business, personal information may be transferred to the new owners. We pledge to inform our users about any such transitions, allowing them to exercise their GDPR rights accordingly.
Furthermore, to ensure the protection and lawful processing of personal data, we engage with third-party entities under strict data processing agreements. These include not only strategic marketing partners but also payment processors that adhere to the Data Protection Act (DPA), facilitating secure transactions and maintaining the integrity of our services.
While we do rely on external technology providers to deliver our services, it's important to note that we only permit such providers to process personal data as sub-processors, adhering strictly to our Data Processing Agreement (DPA) in alignment with GDPR guidelines.
However, our efforts to secure data can be undermined by the users' handling of their access credentials. If credentials are compromised due to negligence, we cannot be held responsible for any resulting data breaches. In the event of a data breach, we are committed to promptly notifying the relevant supervisory authority and, when necessary, the affected data subjects.
Through our multifaceted approach to data security, VARYN LIMITED aims to create a safe online environment where privacy is protected, and trust is paramount.
DATA RETENTION
The duration for which we retain personal data is meticulously aligned with the pertinent legal requirements for data retention. Once the designated period concludes, and the data ceases to serve its initial purpose, we engage in a systematic process to either securely delete or anonymize the information, provided it is no longer necessary for the reason it was collected. Our commitment to data storage and disposal principles plays a crucial role in safeguarding personal data privacy and security. We undertake proactive measures to ensure that data is not retained beyond its useful life or the duration mandated by law. Our data retention policies are in strict compliance with applicable data privacy regulations, such as the GDPR for entities situated within the European Union. These policies emphasize the importance of data minimization and constrain data storage strictly to what is essential for our processing activities. Upon the expiry of the legally permitted retention period or when data no longer meets its initial collection purpose, we initiate a careful process of data deletion or de-identification. The deletion process is carried out with a high degree of security and confidentiality to assure the complete removal of personal information from our systems. In situations where immediate removal is unfeasible or archival retention satisfies a legitimate legal interest, data may be anonymized to eliminate personal identifiers, hence minimizing the potential risks associated with data breaches or unauthorized access.
LEGAL FRAMEWORK
Our Privacy Policy is meticulously crafted to comply with the highest standards of legal regulations, primarily focusing on the General Data Protection Regulation (GDPR) (Regulation 2016/679), which safeguards individuals' rights regarding personal data handling and guarantees the unrestricted flow of such data. This regulation, which supersedes Directive 95/46/EC, became effective on May 25, 2018. For visitors accessing our services from territories outside of the European Union, it is their obligation to ensure adherence to any relevant local regulations, as far as applicable. Within the GDPR framework, two critical roles are delineated concerning the management of personal data: 'data controllers,' who are responsible for determining the purposes and means of processing personal data; and 'data processors,' who process personal data on behalf of the controller. In this arrangement, all clients of VARYN LIMITED, encompassing organizations and individuals alike, are categorized as data controllers. Consequently, this positions VARYN LIMITED as a data processor, tasked with the responsibility of handling your personal data in alignment with GDPR prerequisites, while also requiring our data processing partners to commit to the same standards of compliance.
CHANGES TO THIS PRIVACY POLICY
VARYN LIMITED reserves the right to adjust or entirely remake this privacy policy at any time and for any reason we see fit. Any alterations or updates will take immediate effect once the revised policy is made available on our website. To ensure you remain informed about how we are protecting your personal data, we encourage our users to regularly review our privacy policy. The date of the most recent update will always be prominently displayed at the beginning of the document, making it easy for users to determine the last time the policy was modified. In the case of significant alterations to our privacy practices, we will communicate these changes through our website or directly to our users, as deemed appropriate. However, it's important for users to check this policy periodically to stay updated on any changes that may affect their personal information. Your continued use of our services following the posting of changes to this privacy policy constitutes your acceptance of those changes. At VARYN LIMITED, your privacy is a top priority. We are committed to transparency in all of our data practices and to safeguarding your personal information. Should you have any questions or concerns regarding our privacy practices or how we protect your data, please feel free to contact us via our support channel.
CONTACT INFORMATION
For inquiries related to this Privacy Policy, if you wish to amend your personal information, or opt out of our database, kindly direct your emails to [email protected], ensuring to include "Re: Privacy Policy" in the subject for clear reference. In line with Articles 6-III and 19 of the Law No. 2004-575 passed on June 21, 2004, aimed at fostering confidence in the digital economy, often abbreviated as LCEN, we are committed to providing our users and visitors with concise and transparent information regarding the handling of their data on the aiwiselearning.com platform. Our aim is to ensure that your digital experience is safe, respectful of your privacy, and transparent. VARYN LIMITED is dedicated to upholding these principles and continuously updates its practices to adhere to the highest standards of data protection and user rights under applicable legal frameworks. Your trust and security are paramount to us in the digital age.
OWNER STATUS: Company
PREFIX: LTD
COMPANY NAME: VARYN LIMITED
ADDRESS: AGIOU GEORGIOU 5, 2720 NICOSIA, CYPRUS
COMPANY NUMBER: HE 465143
COMPANY DIRECTOR: ANDREAS SIONIS
VAT: default
EMAIL ADDRESS: [email protected]
SITE BUILDER: VARYN LIMITED
PUBLISHING MANAGER: VARYN LIMITED
RESPONSIBLE PERSON FOR THE PUBLICATION: [email protected]
RESPONSIBLE PERSON FOR THE PUBLICATION AS A LEGAL PERSON:
WEBMASTER: VARYN LIMITED
CONTACT THE WEBMASTER: [email protected]