Data Protection Policy

Last updated:

1. Introduction

Glowcleanelimina ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Data Protection Policy explains how we collect, use, store, and protect your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws in Finland and the European Union.

We recognize that your privacy is important, and we take our responsibility to protect your personal information seriously. This policy applies to all personal data we process through our website, courses, and services. By using our services, you acknowledge that you have read and understood this policy.

2. Data Controller Information

The data controller responsible for your personal information is:

Glowcleanelimina
Ilmalantori 1
00240 Helsinki, Finland
Phone: +358 9 8866 6000
Email: community@glowcleanelimina.world

If you have any questions about how we handle your personal data or wish to exercise your rights, please contact us using the information provided above.

3. Personal Data We Collect

We collect and process various types of personal data depending on how you interact with our services:

3.1 Information You Provide Directly

When you register for courses, contact us, or use our services, you may provide:

  • Name and contact information (email address, phone number, postal address)
  • Account credentials (username, password)
  • Payment information (credit card details, billing address)
  • Educational background and professional experience
  • Course preferences and learning objectives
  • Communication preferences
  • Any information you include in messages or correspondence with us

3.2 Information Collected Automatically

When you visit our website or use our services, we automatically collect:

  • Device information (IP address, browser type, operating system)
  • Usage data (pages visited, time spent, navigation patterns)
  • Cookies and similar tracking technologies
  • Location data (based on IP address)
  • Referral sources and search terms

3.3 Information from Third Parties

We may receive information about you from third-party sources, including:

  • Payment processors for transaction verification
  • Analytics providers for website usage insights
  • Marketing partners for campaign effectiveness
  • Public databases and social media platforms (only with your consent)

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

4.1 Contractual Necessity

Processing is necessary to fulfill our contractual obligations when you enroll in courses or use our services. This includes providing course access, processing payments, and delivering customer support.

4.2 Legitimate Interests

We process data based on our legitimate business interests, such as improving our services, preventing fraud, ensuring network security, and conducting analytics. We always balance these interests against your rights and freedoms.

4.3 Legal Obligations

We process data to comply with legal requirements, including tax laws, accounting regulations, and responses to lawful requests from authorities.

4.4 Consent

For certain processing activities, such as marketing communications and non-essential cookies, we rely on your explicit consent. You can withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

5. How We Use Your Personal Data

We use your personal information for the following purposes:

5.1 Service Delivery

  • Providing access to courses and learning materials
  • Processing enrollments and managing your account
  • Facilitating communication between students and instructors
  • Issuing certificates and tracking progress
  • Providing technical support and customer service

5.2 Payment Processing

  • Processing transactions and managing billing
  • Preventing fraud and unauthorized transactions
  • Maintaining financial records for accounting purposes
  • Handling refunds and payment disputes

5.3 Communication

  • Sending course updates and important notifications
  • Responding to inquiries and support requests
  • Providing information about new courses and features
  • Sending marketing communications (with your consent)

5.4 Improvement and Analytics

  • Analyzing usage patterns to improve our services
  • Conducting research and developing new features
  • Personalizing your learning experience
  • Testing and optimizing website performance

5.5 Legal and Security

  • Complying with legal obligations and regulations
  • Protecting against fraud, abuse, and security threats
  • Enforcing our terms of service and policies
  • Resolving disputes and legal claims

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with the following categories of recipients:

6.1 Service Providers

We work with trusted third-party service providers who process data on our behalf, including:

  • Cloud hosting and storage providers
  • Payment processors and financial institutions
  • Email and communication platforms
  • Analytics and marketing tools
  • Customer support software

All service providers are contractually obligated to protect your data and use it only for specified purposes.

6.2 Legal Requirements

We may disclose your information when required by law, such as:

  • Responding to court orders, subpoenas, or legal processes
  • Complying with regulatory requirements
  • Cooperating with law enforcement investigations
  • Protecting our rights, property, or safety

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you of any such change and ensure continued protection of your data.

7. International Data Transfers

Your personal data is primarily stored and processed within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as:

  • Standard Contractual Clauses approved by the European Commission
  • Adequacy decisions recognizing equivalent data protection
  • Binding Corporate Rules for intra-group transfers
  • Your explicit consent for specific transfers

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy:

  • Account information: Retained while your account is active and for 3 years after closure
  • Course data: Retained for the duration of your enrollment and 7 years thereafter for certification purposes
  • Payment records: Retained for 7 years to comply with tax and accounting regulations
  • Marketing data: Retained until you withdraw consent or for 2 years of inactivity
  • Website analytics: Aggregated data retained indefinitely; individual data for 26 months

After the retention period expires, we securely delete or anonymize your personal data.

9. Your Rights

Under GDPR and applicable data protection laws, you have the following rights:

9.1 Right of Access

You can request a copy of the personal data we hold about you, including information about how we process it.

9.2 Right to Rectification

You can request correction of inaccurate or incomplete personal data.

9.3 Right to Erasure

You can request deletion of your personal data in certain circumstances, such as when it's no longer necessary or you withdraw consent.

9.4 Right to Restriction

You can request that we limit how we use your personal data in specific situations.

9.5 Right to Data Portability

You can request a copy of your personal data in a structured, machine-readable format and have it transferred to another service provider.

9.6 Right to Object

You can object to processing based on legitimate interests or for direct marketing purposes.

9.7 Right to Withdraw Consent

Where processing is based on consent, you can withdraw it at any time without affecting prior processing.

9.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the Finnish Data Protection Ombudsman or your local supervisory authority if you believe we have violated your data protection rights.

To exercise any of these rights, please contact us using the information provided in Section 2.

10. Security Measures

We implement appropriate technical and organizational measures to protect your personal data:

  • Encryption of data in transit and at rest using industry-standard protocols
  • Regular security assessments and vulnerability testing
  • Access controls and authentication mechanisms
  • Employee training on data protection and security
  • Incident response procedures and breach notification protocols
  • Regular backups and disaster recovery plans

While we strive to protect your personal data, no method of transmission or storage is completely secure. We cannot guarantee absolute security but continuously work to improve our safeguards.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience. For detailed information about our use of cookies, please refer to our Cookies Policy. You can manage cookie preferences through your browser settings or our cookie consent tool.

12. Children's Privacy

Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected information from a child, please contact us immediately, and we will take steps to delete it.

13. Changes to This Policy

We may update this Data Protection Policy periodically to reflect changes in our practices or legal requirements. We will notify you of significant changes by posting a notice on our website or sending an email. The "Last updated" date at the top indicates when the policy was last revised. Your continued use of our services after changes constitutes acceptance of the updated policy.

14. Contact Information

If you have questions, concerns, or requests regarding this Data Protection Policy or our data practices, please contact us:

Glowcleanelimina
Data Protection Officer
Ilmalantori 1
00240 Helsinki, Finland
Phone: +358 9 8866 6000
Email: community@glowcleanelimina.world

We will respond to your inquiry within 30 days of receipt.