Privacy Policy of Elite Class
The Elite Class App is operated and managed by jointly " Elite Class", " we" or " us"). Elite Class collects data when you (" User" or " you") use the App, register as a user, and contact us. Amongst these data, we also collect personal data, namely any information relating to an identified or identifiable natural person (" Personal Data"), an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Elite Class understands the importance of privacy and strives to protect it. All your Personal Data collected by Elite Class shall therefore be processed in accordance with the " General Data Protection Regulation" or " GDPR", together with codes of practice, regulatory guidance and standard clauses and other related legislation resulting from the GDPR, as amended from time to time.This privacy policy (the " Privacy Policy") describes the Personal Data that we collect from you and process, the purposes of such processing, the legal basis for processing your Personal Data, the retention period of these Personal Data, and whether third parties may access your Personal Data and your rights regarding your Personal Data we process. This Privacy Policy applies to the relationship between you and Elite Class, together with the Terms of Use of the App you can consult on Please read this Privacy Policy carefully.
DATA CONTROLLER
THE PURPOSES OF THE PROCESSING
We collect your Personal Data for the following purposes: to allow you to access and use the App; to set up your user account and your access to your account; to display content from external apps, platforms, or websites; to communicate with you and provide you with the appropriate support; to improve, effectively present and personalize our services by using the analytical services to evaluate your use of the website, create reports on the activity, collect demographic data, analyze performance data, and collect other data on our website. Third parties use cookies and other technology to help analyze the data and to provide the data to us; for advertising purposes. This includes direct marketing purposes, such as sending you a newsletter when you have registered, therefore, the delivery of our advertisements, the measurement of the effectiveness of our ad campaigns, and the displaying of advertisements that match your likely interests.
We are committed to safeguarding and protecting your personal data and using it lawfully, fairly and in a transparent way, in compliance with the GDPR, and we will only collect and process your personal data for the specified and explicit purposes listed above.
TYPES OF DATA COLLECTED
3.1.1 When you use the App, we collect the following categories of data:
identification data such as your user account data (if any); technical data such as your IP address, your operating system, and the devices on which you use the App; behavioral data such as the manner in which you use the App or the type of content you access and/or upload This collection can take place through the cookies that we or third parties have installed on your device, to the extent that you have accepted the placing of these cookies. For more information, please read our cookie policy.
Student Payment Data
If you make purchases, we collect certain data about your purchase (such as your name and zip code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code. For security, Elite Class does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
3.1.2 When you register for a User account, we collect the following categories of data:
identification data such as your email address, your name, and surname, your address, your telephone number, and your preferred language;
technical data such as your IP address, your operating system, and the devices you use the App on.
3.1.3 When you interact with us, we collect the following categories of data:
identification data such as your user account (if any), your email address or phone number; the timings of your correspondence with us; the content of your correspondence with us.
3.1.4 When you register for our newsletter, we collect the following categories of data:
identification data such as your user account (if any), your email address or phone number.
LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA
We are allowed to process your personal data in strict accordance with the applicable privacy legislation and on the basis of the following legal grounds:
Performance of the agreement: we are allowed to process most of your Personal Data to deliver our services, comply with our obligations, and communicate with you prior to entering into a contract with you. For example, we need your contact details to be able to create a user account. Legitimate interest: we may process your Personal Data when it is in our legitimate interest to do so. For instance, we collect your behaviour data to improve our services and the App or to measure the effectiveness of our advertising campaigns.
Consent:
we may also process your data if we have your express consent, e.g. when you transfer specific information to an expert, when you answer the questionnaire, when you register for a newsletter or when you agree to the use of specific cookies.
RETENTION AND DELETION
Elite Class may retain your personal data as necessary for internal analytical purposes, or to provide you with services that you have requested, comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: how long the personal data is needed to provide the services and operate the business; the type of personal data collected; and
whether Elite Class is subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).
YOUR RIGHTS AS DATA SUBJECT
Under the GDPR, you are entitled to exercise the rights mentioned below. To exercise rights, please contact us by using the contact details provided in Article 1 of this Privacy Policy.
6.1.1 Right for information and access
You are always entitled to know what Personal Data we hold on you, how, where, and for how long such Personal Data are processed. You, therefore, have the right to request information regarding the Personal Data that we hold and process in your respect and to access these Personal Data. We will then provide you with information and/or access to the Personal Data that is being processed and the source of such Personal Data.
Please note that we may request you to provide us with satisfactory proof of your identity before complying with your request for information or access.
6.1.2 Right of rectification and right of erasure
You have the right to request us, free of charge, to rectify any inaccuracies, or to complete your Personal Data if such Personal Data would be incomplete or inaccurate.
You have the right to request us, free of charge, to erase all your Personal Data collected, stored, and processed by us, without unreasonable delay.
6.1.3 Right to object to data processing
You may, at any time, withdraw the consent that you have given to Elite Class for the processing of your Personal Data. We may solely use your Personal Data for direct marketing purposes subject to your explicit consent. If you have provided such explicit consent, and you no longer wish to receive marketing materials, you may at any time require us to stop processing your Personal Data for direct marketing purposes.
6.1.4 Right to restriction
You have the right to "restrict" our use of your Personal Data where: (i) you contest the accuracy of the Personal Data, (ii) the processing is unlawful and you request us to "restrict" our use of your Personal Data rather than to erase it; (iii) we no longer need the Personal Data for the original purpose of the processing but they are required by you for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and there is a verification of whether our legitimate grounds can override yours.
6.1.5 Right to Data Portability
Within the limits set forth in the GDPR, you may request the portability of your Personal Data, i.e. obtain that the Personal Data you have provided to Elite Class be returned to you or transferred to someone else of your choice, in a structured, commonly used and machine-readable format.
DISCLOSURE TO THIRD PARTIES AND TRANSFER TO THIRD COUNTRIES
7.1 Disclosure to third parties
Other than as set out in this Privacy Policy, Elite Class will not sell or otherwise disclose your Personal Data to third parties without obtaining your prior explicit consent, unless this is necessary for the purpose set out in this Privacy Policy or unless we are required to do so by law. In the event of a full or partial merger with or acquisition of all or part of Elite Class, Elite Class may transfer your Personal Data to a Third Party. In such event, Elite Class shall impose this Third Party to use any Personal Data strictly consistent with this Privacy Policy.
We may also share Personal Data with third-party cloud providers and service providers who help us to provide, commercialize and improve the App and our services. We do not authorize these third-party service providers to use or disclose your Personal Data except as strictly necessary to perform any services under our supervision or to comply with applicable legislation. We seek to provide any such third-party service provider with only the Personal Data they need to perform their specific function.
Elite Class puts in place contractual (including data protection, confidentiality, and security provisions) and other organizational safeguards with third-party service providers who have access to your personal data to ensure an adequate level of protection of your personal data.
At the date of this privacy policy, Elite Class shares your personal data with the following third-party:
Advertising partners, who help us with the purchasing, delivery, optimization, and/or measurement of our advertisements. Elite Class uses contractual and technical measures designed to prevent advertising partners from accessing information regarding specific title selections you make, URLs you land on, or shows you have watched on our service. We do not share information about Advertising agencies, who are responsible for displaying advertisements to you when you use our App;
CHANGES TO THIS PRIVACY POLICY
Elite Class reserves the right to change this privacy policy at any time and from time to time in order to reflect changes in the services provided on the App or the applicable laws. If Elite Class decides to change this privacy policy in the future, Elite Class will post an appropriate notice at the top of this privacy policy page and/or give you reasonable advance notice through the App. Any non-material change (such as clarifications) to this privacy policy will become effective on the date the change is posted and any material changes will become effective thirty (30) days from their posting on the App. The date this privacy policy was last revised appears at the top of this document. Your continued use of the App after the changes to this privacy policy become effective signifies that you accept any such changes.
Updates & Contact Info
From time to time, we may update this Cookie Policy. If we do, we’ll notify you by posting the policy on our site with a new effective date. If we make any material changes, we’ll take reasonable steps to notify you in advance of the planned change.
If you have any questions about our use of cookies, please email us at [email protected]