Privaatsuspoliitika
PRIVACY NOTICE FOR PROCESSING PERSONAL DATA BY KOOD/JÕHVI
This Privacy Notice describes the purpose and extent of processing your personal data by Mittetulundusühing Tuleviku Tehnoloogiaharidus, registry code 80583085 (kood/Jõhvi).
- GENERAL PROVISIONS
- kood/Jõhvi ensures that the processing of personal data is in accordance with the legislation regarding the protection and security of personal data (including the General Data Protection Regulation of the European Union, GDPR), other personal data protection legislation, and good business practices.
- kood/Jõhvi considers the privacy of individuals and the protection of their data important and makes the best efforts to ensure the security and protection of the information system and other data carriers.
- DEFINITIONS
- Platform means the online learning platform for Students provided by kood/Jõhvi and/or the data processors.
- Processing of personal data means viewing, collecting, saving, storing, altering, transmitting, or receiving personal data and other activities related to personal data.
- Student means a person who is enrolled in the curriculum of kood/Jõhvi and uses the Platform.
- PURPOSE OF THE PROCESSING OF PERSONAL DATA AND ITS LEGAL BASIS
- kood/Jõhvi processes personal data necessary for enrolling students in courses, tracking their progress, assigning grades, providing tasks and resources, facilitating communication between students and kood/Jõhvi and educators, and maintaining records as required by educational standards and regulations. Data pertaining to the gender of the Students is collected for statistical purposes, the aim of which is to foster diversity and involvement in the tech sector by providing educational services.
- In general, the legal basis for such a purpose is carried out in accordance with Article 6(1)(b) of the GDPR. Such processing is necessary for the performance of the learning contract to which the Student is a party or in order to take such steps at the specific request of the Student prior to entering into a contract. Sometimes the processing of data is necessary for legitimate interests under Article 6(1)(f) of the GDPR provided those interests are not outweighed by the Students’ rights and interests.
- kood/Jõhvi is processing the following personal data:
| Processing activity | Data categories | Purpose | Legal basis |
| Account Management | Full nameEmail address Date of birthEnrollment statusGender | To register students on the platform and create individual user accounts that allow access to courses and content | Contractual obligation (Article 6(1)(b) of the GDPR) |
| Identity Verification | Full namePersonal ID codeResidence permit informationDocument photoNationality | To identify the students’ identity prior to or in the course of enrolment | Contractual obligation (Article 6(1)(b) of the GDPR) |
| Personalized Learning Paths | Academic recordsCourse preferencesInteraction data (e.g., pages visited, content viewed) | To tailor the educational experience to each student’s needs and preferences, optimizing their learning outcomes | Contractual obligation (Article 6(1)(b) of the GDPR) |
| Course Management | Attendance recordsAssignment submissionsGrades and evaluations | To administer courses, track attendance, collect and grade assignments, and record academic achievements | Contractual obligation (Article 6(1)(b) of the GDPR) |
| Communications | Postal addressPhone numberCommunication preferences | To send updates, course notifications, and other relevant communications to students | Contractual obligation (Article 6(1)(b) of the GDPR) |
| Online Assessments | Test responsesGradesFeedback comments | To administer assignments, tests, and exams, provide grades, and offer feedback on student performance | Contractual obligation (Article 6(1)(b) of the GDPR) |
| Platform Analytics | Usage data (e.g., login frequency)Browser and device informationFeedback and survey responses | To analyze how the platform is used and to identify areas for technical improvement and content enhancement | Legitimate interest, to improve and optimize the platform’s functionality and content (Article 6(1)(f) of the GDPR) |
| Compliance with Legal Requirements | Identification dataAcademic records | To comply with legal obligations related to education law, health and safety regulations, and record-keeping standards | Legal obligation, to comply with applicable laws and regulations (Article 6(1)(c) of the GDPR) |
| Technical Support | User account dataTechnical logsInteraction data (for troubleshooting) | To provide assistance with technical issues or account-related problems | Legitimate interest, to ensure the reliable operation of the platform and user satisfaction (Article 6(1)(f) of the GDPR) |
| Security Measures | Login dataAccess logsNetwork information | To safeguard the platform from unauthorized access, cyber threats, and to ensure the integrity of student data | Legal obligation, to ensure the security of personal data under data protection laws (Article 6(1)(c) of the GDPR) |
4. HOW KOOD/JÕHVI COLLECTS PERSONAL DATA
- kood/Jõhvi collects personal information on the Platform directly when the Student:
- registers an account on the Platform, providing information such as name, email address, date of birth, and enrolment details;
- participates in educational activities, including forum discussions, assignments submission, and assessments, wherein they input personal academic data;
- customizes their user profile and learning experience by entering preferences, learning styles, and feedback;
- engages with communication tools on the platform, for instance, when sending messages or emails, contributing to discussions, or requesting support;
- kood/Jõhvi collects personal information indirectly on the Platform when:
- the administrative system of kood/Jõhvi integrates with the platform, transferring necessary student information such as accounts, enrolment status, and academic history;
- kood/Jõhvi inputs grades, evaluations, and feedback into the system related to student performance and participation;
- kood/Jõhvi collects data via cookies and similar technologies to facilitate platform functionality, including but not limited to login data, IP addresses, browser types, and access times;
- the Platform automatically generates records of student interactions, such as time spent on learning materials, progress tracking, and resource access patterns;
kood/Jõhvi provides aggregated data for the purpose of educational research or analytics that may contain information derived from student performance and usage metrics.
5. TRANSMISSION OF THE PERSONAL DATA
- kood/Jõhvi processes personal data in the European Union (EU) and within the European Economic Area (EEA). kood/Jõhvi receives, transmits, and processes personal data only digitally.
6. DISCLOSURE OF PERSONAL DATA
- kood/Jõhvi engages third-party service providers to provide, run, and maintain the Platform on our behalf. These service providers have access to your personal data only to the extent necessary to perform their services, and they are contractually obligated to maintain the confidentiality and security of your information.
- We may disclose your personal data if required to do so by law or in good faith belief that such action is necessary to comply with legal obligations, such as platform exchange of tax information or anti-money laundering obligations.
- Infrastructure service providers
| Data Processor | Processing activity | Territory |
| FutureCoders OÜ | Providing, running, and maintaining the Platform | Estonia |
| Veriff OÜ | Identity verification | EEA |
7. RETENTION AND DELETION OF PERSONAL DATA
- The storage period of personal data depends on the legal obligations to store data (i.e. accounting regulations), contractual obligations, and legitimate interest or consent to provide the best services:
| Data type | Purpose | Retention time |
| User Account Information | To manage student accounts on the platform and provide access to services | Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement, except for information necessary for accounting purposes, which shall be retained for 7 years after expiry of the student agreement |
| Verification Data | To identify the students’ identity prior to or in the course of enrolment | Retained for as long as the processor conducting identity verification retains the data. For further information, refer to the privacy policy of the processor |
| Academic Records | To document the educational history and achievements of students | Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement |
| Coursework and Assignments | To evaluate student performance and provide a record of work completed | Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement |
| Examination Data | To maintain a record of assessments for accreditation and educational continuity | Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement |
| Communication Logs | To provide a record of communications for accountability and to facilitate educational services | Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement |
| Personalized Learning Data | To support individualized learning experiences and improvements to educational offerings | Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement |
| Technical Logs and Usage Data | To ensure the integrity, security, and improvement of the platform | Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement, then securely deleted or anonymized |
| Feedback and Survey Responses | To enhance the educational services and platform features | Retained for the duration of the student’s enrollment, and for a period of 3 years after the expiry of the student agreement, then anonymized for further analysis if needed |
8. RIGHTS OF THE STUDENT (DATA SUBJECT)
- The Student (data subject) shall have the right at any time to request:
- access to personal data (accessed via the Platform);
- correction of inaccurate personal data;
- require the deletion of personal data;
- restriction of processing of personal data;
- withdrawal of data-processing consent (if applicable).
- In order to exercise these rights, the Student must submit a declaration to privacy@kood.tech. The application shall be responded to within a maximum of 30 calendar days.
- The Student has the right to lodge a complaint against the processing of personal data with the supervisory authority, which is the Estonian Data Protection Inspectorate.
9. CHANGES AND VALIDITY
- kood/Jõhvi has the right to change the conditions for processing personal data. In the event, that there are substantial changes, kood/Jõhvi will provide at least 1 (one) month’s notice in advance through the Platform before the substantial changes take effect.
- The conditions for processing personal data are valid from 01.01.2024.