Privacy Policy

We are Coursary a product of Blaze Limited (hereinafter, the ”Company”, “we”, “our”, “us”), a fast, simple and effective online search engine which provides access to thousands of courses located on thousands of web pages in a single search and through a single results page, with the purpose of saving you the time it takes to carry out individualised searches on each of said web pages (hereinafter collectively and interchangeably referred to as “Coursary“, the “Portal”, the “Web Site”, the “Platform”).

We consider the privacy of people important both to the visitors to our website Coursary.com and any other domains held by the Company in connection with this website, application and blog (hereinafter collectively, the “Platform“) and to any other people who may provide us with information through said website and domains, whose data are processed by the Company as part of our provision of services (hereinafter and jointly, “you” and/or the “user” or “users“).

In this regard, the Company undertakes to process your data as provided by applicable personal data protection regulations. In particular, the Company will comply with the provisions of REGULATION (EU) 2016/679 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, and repealing Directive 95/46EC (hereinafter, the “General Data Protection Regulation” or “GDPR“) and any other related regulations which may be in force from time to time.

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The users have the following rights:

• The right to request access to their personal data: you may ask the Company if it is processing your data and, if so, gain access to said data
• The right to request that said data be rectified if they are inaccurate or completed if incomplete.
• The right to request the erasure of their data.
• The right to request a limited processing of their data: in this case we will only keep your data with a view to exercising or defending any possible claims.
• The right to object to the processing: the Company will cease to process your personal data except for legitimate reasons and/or in order to exercise or defend any claims.
• The right to the portability of the data: if you wish to have your data processed by a different data controller, the Company will enable the transfer of said data to the new controller.
• The right not to be subject to a decision based solely on the automated processing of their personal data.

lf you have granted your consent to the processing of your data for a specific purpose, you may withdraw said consent at any time without this affecting the lawfulness of the processing performed prior to said withdrawal.

In any event, all personal data linked to the user’s account, as well as any information and/or content included in his/her profile, will be cancelled as of the time when the user exercises his/her right of erasure. Furthermore, should the user exercise his/her right of erasure in connection with data which are necessary for the Company to provide the services on the Platform, the Company will be forced to terminate its relationship with the user and shall therefore unsubscribe him/her and the user will not be entitled to file any claim whatsoever in this respect.

Users may exercise their rights by written notice sent to the Company’s corporate address or by email sent to the address indicated in section 1 of this Privacy Policy, including in both cases a photocopy of their ID card or equivalent identification document.

You may use the forms and models provided by the European Data Protection Agency in connection with the rights referred to above.

Claim filed before the Supervisory Authority: lf you consider that the Company is processing your data inappropriately, you may address your claim to the Company or to the relevant Supervisory Authority. In Europe, please refer to the European Data Protection Authority.

In this Privacy Policy, the term “personal data” is used in connection with any information which identifies you or may be used to identify you, such as your name, address, telephone number or email address.

lf you decide to provide us with your personal data, the Company will gain access to the following:

Personal data provided voluntarily by the user:

• Email address
• Geolocation, provided that the user activates this option on his/her device
• Any personal data which the user may send directly to the Company

Without prejudice to the provisions in section 5 herein, said personal data will be processed if you interact with the Company and our representatives; if you participate or apply to participate in activities related to the Company, such as the provision of services or online surveys about our services and/or activities; if you interact with the Platform upon being requested to provide personal data as described in this Privacy Policy and in the Cookies Policy; if you subscribe to our Platform or use certain functionalities without subscribing, such as participating in our interactive services.

Personal data which our website collects from your computer or electronic device

• Cookies, applicable to Coursary.com and any other domains held by the Company connected with this website
• IP

For more information on the use of cookies by the Company, please read our Cookies Policy.

The Company hereby communicates to any users applicable that any personal data which they may provide and we may capture will be identified in the Register of Processing Activities held by Coursary, and may be used for the following purposes:

• To register the user and generate a new Coursary user account.
• To provide our services under the Terms of Service and Cookie Policy of Coursary or those that may be established in the future with each of the users
• To enable access to any options requiring registration (e.g., accessing options within the account profile, activating custom alerts)
• To respond to consultations or information requests made by the users
• Provided that you have ticked the relevant box, to keep you informed of our services, activities, projects, updates and new website or application features by means of notices/newsletters sent by email and/or other electronic means.
• Provided that you have ticked the relevant box, to keep you informed, by means of notices/newsletters sent by email and/or other electronic means, of the services and products of our partners in connection with the following sectors: boating, motor, clothing and footwear, publishing, banking and finances, vehicle rental, catering and accommodation, tourism and leisure trips (purchase of trip and tourist packages), cosmetics and personal hygiene, food, consumer goods, technology, companies- creation of smartphone applications addressed to consumers) and non-governmental organisations. The content of said notices will be selected at all times by Coursary and sent to you directly by us.
• If you have ticked the relevant boxes, we may also send you push notifications in connection with our products and services.
• In the case that you have expressly accepted it in the forms authorized for this purpose, to send them to our clients, so they can send you offers related to their products or services.

Your IP address will be collected and used to check the origin of your messages with a view to detecting any possible irregularities (for instance, if opposing parties of a single case write to Coursary from the same IP address).

The Company may process your personal data on any of the following legal grounds:

• A legitimate commercial purposes;
• B If it is necessary in connection with the performance of an agreement you are party to;
• C If it is necessary so that the Company may comply with its legal and regulatory obligations; and
• D if you have given your consent to said processing.

MANAGEMENT AND PERFORMANCE OF AN AGREEMENT
In order to deal with your subscription on our Platform as provided by the Legal Notice or deal with any other documents subscribed by the user.

LEGAL AND REGULATORY COMPLIANCE
Comply with any obligations applicable from time to time.

CONSENT

• Given by the user himself/herself in connection with the collection and processing of his/her personal data.
• Transparency in the absence of local regulations.

Depending on the purpose of collection of your personal data, said information may be accessed by the following persons without distinction:

• Staff authorised by the Company or its representatives acting on behalf of Coursary, subject to applicable personal data protection law.
• Regulatory authorities or other third parties as provided far by applicable law
• Third-party service providers which may process information as personal data processors under the instructions of the Company, upon applying any measures necessary to ensure that we may share said information under enforceable data protection law.

We shall refrain from selling or disclosing to third parties any information or personal data provided by you on our Platform which may identify you directly or indirectly, unless you have expressly authorized it through the forms authorized for this purpose.

The Company is based in Hong Kong. The Company stores data in various locations worldwide so as to provide the fastest possible service. Regardless of the place where your personal data may be collected or processed, the Company will ensure that service providers keep all administrative, technical and physical security measures as may be appropriate to protect your information.

For more information on the use of model agreements by the Company, please contact us on privacy@Coursary.com.

The Company has security measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, or inappropriately altered or disclosed. In addition, we limit access to your personal information to those who need to process that information for business reasons. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected information security breach and will notify you and any applicable regulator of a suspected breach as appropriate and in accordance with our legal obligations.

However, despite the diligent implementation of such measures, the user must know that Internet security measures are not impregnable.

The Company will process your personal data far as long as may be necessary to fulfil the purposes set forth in this Privacy Policy and will keep your data as provided far by applicable laws and regulations.

The criteria we follow in this regard are determined by:

• The purpose of the personal data collected and compliance with said purpose.
• Compulsory storage times under contractual and regulatory provisions.

Please note that in some cases the Company has the obligation to retain certain personal data of the users.

Professionals working with the Company who may intervene in any way in the services provided to the user undertake not to disclose or use the information they may gain access to. In any event, any information provided by the user will be considered confidential and may not be used for purposes other than the management of the user account and/or the services engaged with the Company, if any. In this regard, we undertake not to disclose information regarding the purposes of the user, the information requested or the duration of our relationship with the user.

Coursary is present in some of the main social networks on the Internet, where the Company acts as data controller in connection with personal data published by Coursary.

The Company will process personal data on each social network in accordance with the rules established by the relevant social network to such end. Therefore, except as otherwise stated, Coursary may inform its followers on each social network of its activities, events and related matters, including follower services, through the channels provided by the social network for such purpose.

The Company will not collect personal data from social networks except otherwise expressly agreed to by the user.

The Platform is not designed for or addressed to children under sixteen (16) years of age, who may not use it without an authorisation of their parents or legal guardians. In this regard, we do not collect information from persons under said age deliberately. In any event, if any parents or legal guardians believe that their children have provided us with personal data without their consent, they should let us know by writing to privacy@Coursary.com.

We undertake not to use your personal data for direct marketing purposes without your express prior consent, as provided under article 5 of this Privacy Policy.

lf, at any time, you wish to stop receiving commercial or promotional information from Coursary or third parties, you may unsubscribe from direct marketing campaigns processing of your personal data far said purposes, free of charge, by contacting us on privacy@Coursary.com or by pressing the opt-out button on the subject field of the email. You may also use the opt-out procedure provided in any promotional message received from Coursary.

Please note that, even if you decide not to subscribe or if you decide to unsubscribe from receiving promotional emails or newsletters, we may need to continue contacting you in connection with important information of a non-commercial nature, such as problem solving, inactivity or lack of use, detection and prevention of errors or, in general, compliance with the Terms of Service and operational procedures of the Platform.

The Company integrates the content of the various classified ads websites in our Platform and directs quality traffic to their advertisements. Furthermore, we are capable of generating additional traffic by sending the right advert to the right user at the right time, through our native advertising products.

We use automated decision-making procedures to respond to your choices on the Platform search engine, in order to render the services under the Cookie Policy and offer you a quality and satisfactory service which is in accordance with your search.

The Platform includes links to other types of websites, applications or platforms which we consider may be potentially informational and useful to you. However, keep in mind that we neither support nor recommend the content and/or services provided therein and that we are not liable for their privacy policies or terms of use. In this respect, we recommend that you read the privacy policies of any websites you may visit. Remember that the provisions herein are only applicable to personal data collected and/or processed by the Company.

We will only use your personal data as set forth in the Privacy Policy which is applicable at the time of collection of your personal data. the Company reserves the right to amend this Privacy Policy at any time by publishing said amendments on our Platform. Therefore, we recommend that you check the Privacy Policy every time you enter the Platform. lf we decide at any time to use personal data other than as stated at the time of collection, we will communicate said decision to you by email, provided that we have your email address. You will then be given the chance to authorise other uses or disclosures of the personal data provided by you before the amendment of our Privacy Policy.

Should any of the clauses in this Privacy Policy be eliminated or considered null and void, this will not affect the rest of the terms and conditions, which shall remain fully valid and effective under regulations in force from time to time.