سياسة الخصوصية

LAST UPDATED: Jul. 18TH 2022

 

This statement (“Privacy Policy”) explains what we do with Learner’s personal data which we receive through the educational services (the “Services”) provided by the Sheikh CEO (part of The International Advisory Group), and how Learners enrolled in a course provided by The Sheikh CEO can exercise their rights over it.

 

The information we collect about you and why we collect it

 

By registering an account on the Sheikh CEO platform and in turn using our Services, we will collect from you the following information (“Personal Data”):

 

  • Your name
  • Your email address
  • Your year of birth
  • Highest education level achieved
  • Gender
  • Country of residence/origin
  • Phone numbers (Teachers)
  • Social media accounts (If you login/register using social media, namely Facebook or Google)
  • Records of your visits to our Platform and engagement with educational content such as pages, videos, assessments, and posts, comments, and any other interactions you perform on course discussion forums
  • Details of grades scored on assessments you take on the platform
  • Online footage of interactions you performed in online lecture videos, called “pause and seek events”
  • Records of creation of virtual classrooms by teachers on the Sheikh CEO platform

 

Our legal basis for using your Personal Data

 

Where we use your Personal Data, we process it on the following bases:

 

  • Performance of a contract to which you as a data subject are a party (including in connection with the retention of records detailing your learning progress and performance for the purpose of saving your course progress and certificates); and
  • For the legitimate interest of the Sheikh CEO carrying out the following activities:
  • Internal research purposes, for example, the improvement of course design and operation;
  • The following research and marketing purposes (unless you decide to opt-out when registering or subsequently):
    1. Internal research in connection with how the platform is used; and
    2. For the purpose of sending you updates in respect of online courses offered by the Sheikh CEO
  • Improving the platform user experience of the Sheikh CEO; and
  • The publication of scientific papers in journals or conferences. No data that identifies you are ever shared in a scientific publication. We only publish aggregated or anonymized data.

We will never collect any unnecessary Personal Data from you and do not process your information in any way, other than as specified in this Policy.

 

We make every effort to maintain the accuracy and completeness of your Personal Data, which we store, and to ensure all of your Personal Data is up to date. However, you can assist us with this by promptly contacting us if there are any changes to your Personal Data. We shall not be responsible for any losses you suffer arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

 

How long we will keep your Personal Data

 

For EU users and users in other countries with data protection legislations that require personal user data to be deleted after some time, your account data will be deleted automatically after 7 years of inactivity. Inactivity is defined as the absence of interaction with course content. Following 7 years of inactivity, we will contact you with a 1-month prior notice, informing you that your Personal Data will be deleted from the computers on which it is stored, and giving you the option to request your Personal Data is retained for another 7 years.

 

For users in all other countries, your account data will be saved by the Platform until you submit a request for us to delete your data through the Website, after which your data will be deleted according to the timeline provided by the Website when you request the deletion.

 

The Platform 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 the applicable legal requirements.

 

Who we share your Personal Data with

 

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

 

  • The internal course management team;
  • The internal marketing team; and
  • The internal leadership team.
  • Third parties we partner with for the purposes of course creation, operation, or evaluation (including instructors, teaching assistants, and personnel from organizations that partner with the Sheikh CEO for the purpose of a course you are enrolled in) and marketing agencies we partner with for the Sheikh CEO specific marketing needs. All third parties who receive personal data from company sign a data processing agreement with the company that mandates they use your Personal Data only for the purposes for which our company contracted them and in accordance with GDPR or any other applicable data regulations, and that the third party deletes your personal data within 10 days of the termination or completion of the contract.

 

We may also from time to time share your Personal Data (in an anonymised form) with external educational researchers for the purpose of conducting educational research.

Use of your Personal Data for automated decision-making

We do not make any automated decisions using this information.

 

Changes to this policy

 

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

 

Your rights and how to exercise them

 

 

  • With some exceptions, you have the right to have a copy of the Personal Data that we hold about you. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs. Where the data is data that you have given to us, you have the right to receive your 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 Personal Data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, if we are obliged to do so by law).
  • You have the right to require us to stop using your Personal Data for marketing purposes.
  • You also have the right in some circumstances to request that temporary restrictions are placed on how we process your Personal Data, For example, if we are processing it on the basis of our legitimate interest, and you contest to 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 that processing unless we have another legal basis on which to continue. In some cases, the only way for our platform to stop that processing would be by terminating your accounts. The Sheikh CEO will request your confirmation before terminating your account, through the email address through which you request to withdraw your consent. If you do not provide written confirmation within 21 days for the Sheikh CEO to terminate your account, your request to withdraw your consent will be considered canceled.
  • In order to protect you and others, we may require you to prove your identity before you exercise these rights.

 

If you are unhappy with how we have handled your Personal Data, you have the right to complain to your local data protection authority.