The Data Controller is ExoClick, S.L., with a registered office at C/ Marina, 16-18, 08005, Barcelona, Spain, VAT number B-64355506, contact e-mail: [email protected], Commercial Registry Data: Barcelona, Volume 39063, Page 160, Sheet B-336819, 1st Inscription, and Data Protection Officer (DPO) contact: [email protected] (hereinafter, “ExoClick” or “ExoClick Academy”).

1. Welcome to the ExoClick Academy Privacy Policy

This page is meant to inform you of our policies regarding the collection, use, and disclosure of personal data when you use the Thinkific platform (herein, the “Platform”). The Platform is owned by Thinkific Labs Inc., a Canadian company that acts as a Data Processor and with whom ExoClick has a data processing agreement to guarantee the protection of your personal data. 

ExoClick has contracted this Platform to offer courses to learn how to use ExoClick's ad-serving platform and expand their knowledge of affiliate advertising. 

By using the Platform, you (herein, the “Data Subject” or “User”) agree to the collection and use of information following this Policy, and according to the European Data Protection Regulation 679/2016, of 27 April (hereinafter, “GDPR”), and by the Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (“LOPD-GDD”).

2. Personal data collection and use

2.1 While signing up for the Platform, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you during the use of the Platform. 

Categories of personal data we may collect:

• Identification data: Name and surname, email address, username, professional title (not mandatory), and profile image (not mandatory).

 3. Legal basis of the processing 

In compliance with the requirements of the GDPR and the LOPD-GDD, and following our internal policies, when you sign up to the Platform you are freely and unequivocally declaring to us that you agree that we will process your data according to the purpose mentioned in the section 2.1. and thus to fulfillment of a contract we have entered with you. Also, when you sign up for our newsletter, you are expressing your desire and consent to process your personal data for this purpose.

4. Retention period

The personal data provided will be kept for the time necessary to fulfill the purpose for which they are collected and to determine the possible responsibilities that may arise from the purpose. However, to comply with the legally established deadlines, once the service has been completed and for the legal prescription period, they will be kept blocked, adopting for this purpose the appropriate technical and organizational measures to prevent their processing, including their visualization, and being only available to judges, courts, public prosecutors or public administrations, all this to address the legal responsibilities, if any. Once the required legal period has elapsed, these data will be definitively destroyed.

5. Rights of the Data Subject

You, at any moment, can exercise the following rights:

• A right of access to a copy of the information comprised in its personal data.
• A right to have inaccurate personal data rectified or suppressed.
• A right to request a limitation of the processing of its personal data.
• A right to object to processing.

To exercise your data protection rights, you may contact ExoClick Academy at [email protected] or their registered office.

Likewise, you may, at any time, submit a complaint to the Spanish Data Protection Authority if your rights are not being properly assisted.

6. Personal data sharing and disclosure

ExoClick will not provide users’ data to third parties, understood as third parties that are not directly related to the user or that do not carry out a function on behalf of or commissioned by the service provider or data controller, that is, ExoClick.

Your data will be communicated to those entities that provide a service to ExoClick when acting as Data Processors (such as Thinkific). In those cases, ExoClick has subscribed to confidentiality and data processing agreements with them according to the requirements under GDPR and privacy applicable law.

We inform you that our servers are usually located in the European Union, and we generally hire service providers located within the European Economic Area or in countries that have been declared to have an adequate level of protection.

In case we need to use external service providers that require the communication of personal data outside the European Union or in countries that have not been declared with an adequate level of protection, we will ensure that we guarantee the security and legitimacy of the processing of your data employing adequacy decisions, standard clauses, binding corporate rules, exceptions or any other instrument approved by the supervisory authority that provides adequate guarantees for the performance of the international transfer of data.

 7. Cookies

Our partner (Thinkfic) may use different types of cookies (small text files placed on your device) and similar technologies to enable the use of the Platform and help collect data.

To obtain more information about the Platform cookies, we invite you to visit our partners Cookies Policy. 

 8. Confidentiality and Security

Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user enters, submit, or access their information to maintain the safety of your personal data.

All users are encouraged to select strong passwords and to never share them with third parties or unauthorized users.

 9. Changes to the Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Last Updated August 27, 2024