FREECOURSEHEROUNLOCKS takes its users’
privacy very seriously and will process and use your personal data in a safe
and secure manner. When you make use of FREECOURSEHEROUNLOCKS, you naturally
want us to handle your personal data with care and ensure that your data does
not end up with other companies. In this document we explain in full which
personal data we collect and how we deal with it with due care. Put briefly, we
use your personal data to be able to offer you Study Material, to inform you
about our service and to be able to make personal offers. If you have any
questions regarding your personal data, please contact us via [email protected].
We advise you to read this Privacy
Statement carefully. If capitalised terms in this Privacy Statement are not
defined in this Privacy Statement, their definitions can be found in FREECOURSEHEROUNLOCKS’s
Terms of Use.
Privacy Statement Navigation:
o 1. Who is FREECOURSEHEROUNLOCKS?
o 2. What data does FREECOURSEHEROUNLOCKS
collect and process?
o 3. What are cookies
and how does FREECOURSEHEROUNLOCKS use them?
o 4. Disclosure to
third parties
o 5. How does FREECOURSEHEROUNLOCKS
protect personal data?
o 6. Retention of data
o 7. Transfer of
enterprise
o 8. Your rights
o 9. Is this Privacy
Statement subject to change?
o 10. Questions?
FREECOURSEHEROUNLOCKS hereinafter
referred to as “FREECOURSEHEROUNLOCKS”, is a website that offers an online
platform on which users are given the opportunity to access Study Material from
coursehero.com for free upon request or through payment. This Platform is
further defined in the Terms of Use. FREECOURSEHEROUNLO CKS has its registered
offices at Gift Land Plaza Ground Floor TRM Drive; Nairobi-Kenya.
FREECOURSEHEROUNLOCKS is responsible for the manner in which
your personal data is collected, used
and stored.
2. What data does FREECOURSEHEROUNLOCKS collect and process?
FREECOURSEHEROUNLOCKS
Profile
If you want to upload or download Study
Material through the Platform, you are required to create a Profile. When you
are creating a Profile, you will be asked to disclose certain data about
yourself. You are not obliged to disclose all data, but the following data is
required:
Upload:
A valid email address, username and
password, your name and paypal address to enable us to pay you for your Study
Material.
Download:
A valid email address, Username and
password
The personal data you disclose when
creating the FREECOURSEHEROUNLOCKS Profile and the personal data you
subsequently add to your Profile or disclose through other features will also
be used to provide you with personal offers.
As well as the purposes discussed in this
Privacy Statement, our main purpose for using the disclosed personal data is to
create your FREECOURSEHEROUNLOCKS Profile and to provide you with the
corresponding features. This use of your personal data is required to perform
an agreement to which you are a party, which agreement pertains to your use of
the services FREECOURSEHEROUNLOCKS offers to you through the Platform.
Furthermore, FREECOURSEHEROUNLOCKS would
like to keep you updated on the development of its Platform. If there is an
upcoming extension or an update or other amendment concerning the Platform, FREECOURSEHEROUNLOCKS
will let you know. The same applies to information regarding payments or
amounts due. It is not possible to opt out of such notifications.
On the Platform, you grant FREECOURSEHEROUNLOCKS
the right to disclose the personal data (such as your username and profile
picture) and Study Material you have submitted, as well as to reproduce such
data and Material, in the context of providing the Platform. Among other
things, this means that FREECOURSEHEROUNLOCKS may use certain personal data you
have disclosed to promote the Platform, for example by indicating who the most
successful user is, which Study Material is being downloaded most often or
which Study Material or Users are new to the Platform. Your personal data will
only be used in this context if you have given your consent for it. If you no
longer want your personal data to be used for this purpose, you can withdraw
your consent by sending a message to [email protected].
Automatically
Generated Information
FREECOURSEHEROUNLOCKS collects
Automatically Generated Information on all Users. This information comprises
your browsing behaviour on the Platform, such as the pages you visit, the
amount of time you spend on a specific page, the items you download and/or
upload and how you use your Profile. Furthermore, FREECOURSEHEROUNLOCKS
collects your IP address, your browser type (computer program used to visit
webpages) and cookies. Among other things, FREECOURSEHEROUNLOCKS uses this
information to adjust the services to fit your needs as much as possible and to
solve technical and security issues. This processing of your personal data is
required for the purposes of FREECOURSEHEROUNLOCKS’s legitimate interests,
namely, FREECOURSEHEROUNLOCKS’s interest in securing its Platform and being
able to offer it in the most user-friendly way possible. If the Automatically
Generated Information is collected using cookies, Section 3 (cookies) will also
apply.
Newsletters
FREECOURSEHEROUNLOCKS may keep you
posted about special offers it organises by means of its newsletter. The
newsletter is sent on a regular basis. If you have subscribed to the
newsletter, FREECOURSEHEROUNLOCKS will use the email address you have submitted
to send the newsletter. FREECOURSEHEROUNLOCKS may also use your name and/or
gender to personalise the newsletter. If you no longer wish to receive the
newsletter, you can opt out by unticking ‘Newsletter’ in your Profile. Also,
each separate newsletter contains the option to opt out. If you do decide to
opt out, FREECOURSEHEROUNLOCKS advises you to keep an eye on the Platform to
see whether there are any new special offers.
FREECOURSEHEROUNLOCKS processes your
email address for direct-marketing purposes based on its legitimate interest in
order to be able to send you the newsletter.
Personal offers
Based on the personal data FREECOURSEHEROUNLOCKS
collects, FREECOURSEHEROUNLOCKS may make personalised offers to you by means of
emails or by drawing your attention to the personal offer in the Portal.
To do this, we use:
o the products you buy and the amounts you spend;
o your browsing behaviour on the website; and
o data we collect using cookies.
Your personal data will only be used in
this way if you have given your consent for it. If you no longer want your personal data to be
used for this purpose, you can withdraw your consent by sending a message
to [email protected] or by changing your email
settings in your Profile.
Statistical surveys
FREECOURSEHEROUNLOCKS strives to provide
you with a Platform of the highest quality. This requires FREECOURSEHEROUNLOCKS
to carry out statistical surveys so that it can adjust the Platform where
necessary.
For such statistical surveys, FREECOURSEHEROUNLOCKS
may use your personal data, among other things by using cookies. FREECOURSEHEROUNLOCKS
does this based on its legitimate interest in the statistical surveys, namely,
to improve the quality of its services. The results of the surveys are always
aggregated. This means that the data contained in the results cannot be traced
back to you personally.
In providing the Platform, FREECOURSEHEROUNLOCKS
uses cookies which your browser saves on your computer or device (“Device”).
Cookies are small pieces of data that FREECOURSEHEROUNLOCKS’s server transmits
to your browser; the idea is that this data is then transmitted back to FREECOURSEHEROUNLOCKS’s
server on your next visit. By using cookies, our Platform is able to recognize
you when you revisit it, and the Platform can be personalized to your needs.
Cookies therefore help you save time. Cookies cannot spread viruses.
Functional cookies
FREECOURSEHEROUNLOCKS uses functional
cookies. These cookies are necessary to provide you with the services and
features you have requested. For example, functional cookies enable you to log
in to the Platform just once and ensure that you are not asked to log in again
on every page you visit. It is not possible to disable functional cookies.
Analytic cookies
To collect web statistics on the use of
and visits to the Platform, FREECOURSEHEROUNLOCKS uses Google Analytics. Google
Analytics installs a persistent cookie on your Device. This cookie records your
use of the Platform. That data is then analysed by Google and it subsequently
sends the results to FREECOURSEHEROUNLOCKS. In this way, FREECOURSEHEROUNLOCKS
develops an understanding of the manner in which the Platform is used and can
then adjust the Platform and/or its services based on that data. Google may
disclose this data to third parties if it is statutorily required to do so
and/or if third parties process the data on Google’s behalf. Google may not use
the data for other services offered by Google.
Social plug-ins
The Platform provides access to various
social media, including but not limited to Facebook, Twitter and Instagram.
Using these “social plug-ins”, you can share information with or recommend
information on the Platform to other people. When you visit a web page that has
the social plug-ins of these social media, third parties will install cookies
on your Device. These cookies will collect, among other things, data about your
browser and the websites you have visited with your IP address.
The use of the cookies that are
installed on the Platform via the social plug-ins is subject to further
third-party terms and conditions. FREECOURSEHEROUNLOCKS does not assume any
responsibility or liability for those third-party terms and conditions. FREECOURSEHEROUNLOCKS
refers you to the terms and conditions of those parties.
Facebook Website
Custom Audiences
Aided by Facebook’s Website Custom
Audiences, FREECOURSEHEROUNLOCKS may use data from its Platform to show you
relevant advertisements on Facebook. Through a pixel that is integrated in FREECOURSEHEROUNLOCKS’s
website, general data regarding your browser session, including any Facebook
cookies and the website you are visiting, is transmitted to Facebook. Based on
this data, Facebook users may be placed in specific Custom Audiences and may be
shown personalised ads. The data that is collected in this manner is not linked
to the data in your FREECOURSEHEROUNLOCKS account.
Deleting cookies
You are at all times entitled to
withdraw the consent you have given to FREECOURSEHEROUNLOCKS to install and
read cookies. To do so, you will need to change your browser settings so that
it no longer accepts cookies and/or you will need to disable all the cookies that
have already been installed on your browser. In such event, however, you may no
longer be able to use or fully use all the features of the Platform or you may
be denied access to the Platform or sections of it. For more information on
enabling or disabling cookies, go to your browser´s Help menu.
If you have enabled cookies and you are
on a publicly accessible computer, FREECOURSEHEROUNLOCKS advises you to log out
when you leave the computer unattended, in order to maintain the
confidentiality of your password and username.
Without your explicit consent, FREECOURSEHEROUNLOCKS
will not disclose your personal data to third parties for direct-marketing
purposes (e.g. to send promotional material).
To provide the Platform, FREECOURSEHEROUNLOCKS
occasionally uses third parties, for example, for hosting its central database
(Amazon). FREECOURSEHEROUNLOCKS has entered into agreements with those third
parties, which agreements contain arrangements regarding the technical and
organisational measures those third parties must implement to protect your
personal data.
FREECOURSEHEROUNLOCKS may disclose your
personal data to third parties if you have given your consent for it to do so. FREECOURSEHEROUNLOCKS
may also disclose your personal data to third parties, in so far as the data
cannot be traced back to you personally (such as Automatically Generated
Information, excluding the IP address) and therefore does not constitute
personal data.
Finally, FREECOURSEHEROUNLOCKS may
disclose your personal data to third parties if it is statutorily required to
do so, if it is required to do so as a result of legal proceedings, and/or if
it believes this is necessary to protect its own rights.
The Terms of Use provide how FREECOURSEHEROUNLOCKS
will respond if a person reports that certain Study Material infringes
third-party rights (including intellectual property rights) (“notice and
takedown”). In such events, FREECOURSEHEROUNLOCKS may transfer certain personal
data (name, email address) of the person who has given notice, to the user who
has uploaded the allegedly infringing Study Material. FREECOURSEHEROUNLOCKS
also reserves the right to transfer certain personal data (e.g. username and
email address) of the user who has uploaded the allegedly infringing Study
Material to the person who has given notice and/or to third parties, if FREECOURSEHEROUNLOCKS
is required to do so based on laws and regulations.
The Platform may contain hyperlinks that
lead you away from the Platform and take you to third-party websites. FREECOURSEHEROUNLOCKS
has no control over the third-party websites to which its website is linked.
This means that the use of these third-party websites may be governed by
different privacy policies. This Privacy Statement relates solely to personal
data obtained through the Platform. FREECOURSEHEROUNLOCKS does not assume any
responsibility or liability for the operation and/or contents of third-party
websites.
FREECOURSEHEROUNLOCKS has implemented
appropriate technical and organizational measures to protect your personal data
against loss or any form of unlawful processing.
For example, the Platform is protected
in such a way that it cannot be accessed without login codes. Your personal
data is protected against unwanted use by means of a username and a password.
Furthermore, communications with the
Platform itself are protected as well. This security is evidenced by the
inclusion of ‘https’ in the browser’s URL (the web address bar) and the image
of a locked padlock at the top of the screen. If you double-click on the
padlock, you can check whether the connection with the Platform is secure.
FREECOURSEHEROUNLOCKS will not retain
your personal data for longer than is necessary to fulfil the purposes for
which the personal data has been collected.
If FREECOURSEHEROUNLOCKS further grows
and develops, it may be the case that one or more divisions or assets of the
business are transferred to a third party or FREECOURSEHEROUNLOCKS may merge
with a third party. In such event, your personal data may be transferred as
well. Naturally, we will inform you if that is going to be the case, and you
are at all times entitled to opt out of the service.
Under privacy laws, you have various
rights as a data subject. This section f the Privacy Statement describes the
rights you have and how you can invoke them.
Response Time
We endeavour to respond to your requests
as soon as possible and in any event within one month. However, it may be that
we need more time. If that is the case, we will inform you about this before
the end of the month referred to in the previous sentence. The extra time will
not exceed two months.
You may submit your requests
to [email protected].
To ensure that the personal data you are
requesting is really yours, we ask that you attach a copy of a valid ID. Please
render the citizen service number (ID number) on your ID illegible.
There is a chance that we reject your
request, for example if your request is unfounded or excessive or if the law
does not enable or require us to meet your request. We will also inform you of
any rejections. Furthermore, we may ask you to identify yourself before we
consider your request.
Right of access
You have the right to submit a request
to find out if we are processing personal data concerning you. If that is the
case, we will provide you with a copy of the personal data we have collected
about you, as per the law.
Right to rectification
You have the right to submit a request
for rectification of inaccurate personal data concerning you. If possible, you
also have the right to disclose additional personal data in order to complete
the personal data we have collected.
Right to be forgotten
You have the right to request erasure of
certain personal data concerning you (the right to be forgotten). If your
request is granted, we will delete the personal data concerned.
Right to restriction
of processing
You have the right to request for
restriction of processing of your personal data. This means that if the
restriction request is granted, we will not continue to process your personal
data for as long as the restriction is in effect, unless we are statutorily
allowed to do so.
Right to object
Under certain circumstances, you have
the right to object to the processing of your personal data, for example if we
process your personal data based on legitimate interests. If you lodge an
objection, we will balance your privacy interests against our company
interests. If your interests override our interests, we will cease processing
your personal data.
If your personal data is used for direct-marketing purposes, you are at all times entitled to object to the processing. In such event, we will cease processing your personal data for those purposes.
Right to data
portability
You have the right to request data
portability. We will provide the data that falls under this right in a
structured, commonly used and machine-readable format to you so that you can
transmit it to a third party.
This Privacy Statement is subject to
change. Any changes will be communicated through the Platform. The Privacy
Statement was last updated on September 22nd, 2020.