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PRIVACY POLICY

Welcome to the website of mdsonlineacademy.com within which you can learn about our company and our services as well as

a) sign-up on the Site to purchase training content and/or marketing services (hereinafter, the “Services”) in the e-learning platform mdsonlineacademy.com

b) request to receive communications with exclusive and personalized offers, discount coupons and news about training courses and streaming events.

c) send us your application for one of the open job positions 

d) use the chatbot service to obtain information regarding your registration to the Site and/or Services (hereinafter, the “Chatbot”);

e) send us your request, idea or suggestion (hereinafter the “Request”).

This Privacy Policy (hereinafter, the “Privacy Policy”) applies if you are interested in using the above Services and/or subscribing to the Newsletter and/or sending us your Application or Request and/or using the Chatbot and providing us with your personal data, or if we are required to process your data for the management of your requests and for the purposes set out below.

The Privacy Policy is governed by (EU) 2016/679 Regulation of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, the “GDPR”) and by Legislative Decree 196/2003, as amended by Legislative Decree 101/2018.

Please note that the use of the Services, the subscription to the Newsletter, the transmission of the Application or a Request and the use of the Chatbot are reserved to users over 18 years of age. We do not collect or process personal information about minors.

1. WHO IS THE DATA CONTROLLER OF THE PROCESSING

2. WHAT DATA WE PROCESS AND WHY

3. NATURE OF THE PROVISION AND METHODS OF DATA PROCESSING

4. HOW LONG WE KEEP YOUR PERSONAL DATA

5. TRANSFER OF DATA TO THIRD COUNTRIES

6. WITH WHOM WE SHARE YOUR PERSONAL DATA

7. YOUR RIGHTS

8. CONTACTS

9. CHANGES TO THIS PRIVACY POLICY 6

1. WHO IS THE DATA CONTROLLER OF THE PROCESSING

The Data Controller is mdsonlineacademy.com   with registered office in 9 abdelmohsen soliman st, dokki, giza (egypt) 

For any communication relating to the processing of personal data subject to this Privacy Policy and to exercise the rights described in paragraph 7 you can write to us by sending an e-mail to the following address privacy@mdsonlineacademy.com, or a registered mail to our offices at the above address or by contacting us at phone number + 201018626262

2. WHAT DATA WE PROCESS AND WHY

  1. Use of the Services, as well as subscription to the Newsletter, transmission of your Application, a Request or use of the Chatbot are optional. You are, therefore, free to browse the Site without having to provide any personal data.

  2. When you use the Services, subscribe to the Newsletter, submit your Subscription or Request, use Chatbot , mds collects and uses your information. In particular, for each purpose we will process the following data:

    1. use of the Services: personal data, residence and contact details, bank details to proceed with any billing;

    2. Newsletter subscription: e-mail;

    3. request for support or information, including through the Chatbot: name, surname, e-mail, phone number;

    4. transmission of your Application: personal data, residence and contact details, data relating to your study path and previous professional experience and your personal photograph where included in the CV and the other data included in the letter/e-mail of presentation where attached;

    5. transmission of a Request: contact data.

  1. If you need assistance with using the Services, subscribing to the Newsletter, transmitting an Application or Request, or using Chatbot, we will process your personal information in a way that we can respond to your request.

  2. In case of litigation or need to protect our rights or interests we will process the data necessary to protect our legitimate interest in not suffering damage or injury to our rights.

  3. If you are interested, by signing up on the site to use the Services, we can also use your e-mail to send you the Newsletter (to the eventual reception of which you can oppose, at any time, using the link that you will find in each e-mail) and/or contact you by phone to offer you exclusive offers, advice and personalized professional suggestions. You can oppose the eventual receipt of the above mentioned e-mails at any time, using the link that you will find in each e-mail to request the cancellation from our mailing list.

3. NATURE OF THE PROVISION AND METHODS OF DATA PROCESSING

In relation to the processing of personal data for the purposes set out in point 2.2, the provision of the data marked with an asterisk is mandatory when filling out the various forms; in the absence of the data marked with an asterisk, we will not be able to correctly provide the Services or proceed to the correct subscription to the Newsletter or receive and examine your Application, your Request or what has been submitted through the Chatbot.

The data will be processed by the Data Controller and by his or her employees mainly with electronic and manual systems according to the principles of correctness, loyalty and transparency provided for by the applicable legislation on the protection of personal data and protecting the confidentiality of the subject to whom the data refers through technical and organizational security measures to ensure an adequate level of security (e.g. preventing access to unauthorized parties except in the cases required by law, or the ability to restore access to the data in the event of physical or technical accidents.

4. HOW LONG WE KEEP YOUR PERSONAL DATA

We will retain your data for the time necessary to fulfill the purposes set forth in this Privacy Policy, unless a longer retention period is required or permitted by the law to which MDS is subject. We use the following criteria to define the retention period of data: (i) for the entire duration of the relationship and for 1 year after termination of the relationship; (ii) as required by the legal obligations to which MDS is subject (e.g., tax and accounting obligations), usually equal to 10 years or 6 years for tax purposes; (iii) until your deletion from our marketing databases; (iv) at the latest 24 months after the submission of your Application or the closing of the selection process.

5. TRANSFER OF DATA TO THIRD COUNTRIES

Your data is processed by us and our suppliers within the European Union and middle east. If, in order to provide better and more efficient use of the Services and/or receipt of the Newsletter and/or transmission of your Application or Request, or use of the Chatbot, your personal data should be transferred outside the European Economic Area or middle east, we are committed to ensuring adequate levels of protection and safeguard, including contractual protection, in accordance with applicable law, including the conclusion of standard contractual clauses and we will inform you by updating this Privacy Policy.

6. WITH WHOM WE SHARE YOUR PERSONAL DATA

In order to guarantee the functionality of the Site, the use of the Services, the subscription to the Newsletter, the transmission of the Application or a Request, the use of the Chatbot, we use MDS personnel and external consultants, who can access and process your data only for the purposes indicated above and according to the preferences you provide. In particular, our employees and associates in the IT, administration and customer service areas will have access to your data if they need to process it for the performance of their duties.

In addition, your personal data may be shared with third parties who process the data, such as autonomous data controllers or who operate on our behalf as data processors (for example, parties that provide services for the management of the information system and communication networks, including e-mail, companies specializing in assistance and consulting relationships, the competent authorities to fulfill legal obligations and/or provisions of public bodies, on request, in the case of administrative accounting purposes, commercial information companies for the assessment of solvency and payment habits and/or subjects for purposes of debt collection).

The updated list of data processors can be requested through the contacts mentioned in point 8.

MDS may also receive requests for information from the police or judicial authorities when conducting judicial investigations; in this case the communication is necessary to fulfill a legal obligation to which MDS is subject.

7. YOUR RIGHTS

(i) Right to rectification

MDS will take the necessary measures in accordance with applicable data privacy laws to ensure that your personal data is accurate, complete and up-to-date. If you find that personal data about you is inadequate, incomplete or incorrect, you have the right to request that it is amended.

(ii) Access

You can request confirmation of any processing of your personal data and, if so, access your personal data and additional information, such as the purpose of processing. You also have the right to receive a copy of the personal data being processed. If your request is submitted electronically, the information will be provided in an electronic format in common use, unless you request a different format.

(iii) Objection to a particular processing

You may object to the processing of your personal data processed on the basis of a legitimate interest, for reasons related to your particular situation.

(iv) Deletion

Your personal data may be deleted in certain circumstances, for example, if it is no longer necessary for the purposes for which it was collected.

(v) Restriction of processing

You can ask us to limit the processing of your personal data to the sole storage of personal data in certain circumstances, for example, when the processing is illegal, but without the personal data being deleted.

(vi) Revocation of consent

You have the right to withdraw your consent to the processing of data at any time if the processing is based on your consent.

(vii) Data portability

You may request to receive a machine-readable copy of the personal data processed on the basis of your consent or the need for the processing to enter into an agreement with you and the personal data you have provided to MDS (data portability) and request the transfer of the information to another data controller (if possible).

(viii) Complaints to the supervisory authority

You are aware that you always have the right to submit complaints regarding the processing of your personal data to the competent EGYPTIAN data protection authority, if required by applicable data protection laws. The data protection authority to which you can turn to is that of your country of residence or work or the place where the alleged violation occurred. 

8. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy at any time as a result of changes in processing or regulatory changes.

Previous versions of our Privacy Policy on the processing of personal data are available [here].

SUBJECT: PROVIDED PURSUANT TO ARTICLES 13 AND 14 OF EU 2016/679 REGULATION

Dear Customer,

Pursuant to Articles 13 and 14 of EU 2016/679 Regulation (hereinafter, the “GDPR”), we inform you of the following with regard to the processing of personal data that our company will come into possession of in relation to the contract that may be concluded between the parties (hereinafter, the “Privacy Policy”).

.

For any communication relating to the processing of personal data covered by this Privacy Policy and to exercise the rights described in point 7 you can write an e-mail to the following address privacy@mdsonlineacademy.com or send a registered mail to our offices at the above address or by contacting us at phone number + 201018626262

TYPE OF PERSONAL DATA

The data transmitted by you during the establishment of the contractual relationship and in the consistency of the same (also, possibly, as an employee responsible for the execution and management of contracts) including name, surname, contact data, professional qualifications where relevant, billing and payment data, data of economic and financial nature if related to individual economic activities, registration in any registers or records – whether directly provided by you or obtained from public sources (e.g. Chambers of Commerce) – will be processed by MDS, in accordance with the GDPR and national legislation including any measures issued by the Control Authority (Guarantor Authority for the protection of personal data), where applicable.

PURPOSE OF THE TREATMENT AND LEGAL BASIS

The data processing is carried out by MDS in the execution of its economic and commercial activities for purposes related to the management of the contractual relationship. In particular, the data will be processed for the fulfillment of legal and regulatory obligations (e.g. fiscal and accounting obligations, obligations arising from contractual obligations); for the opening of the customer registry; for the administrative management of contracts, including the management of invoices. For the processing of data for the purposes indicated above, it is not necessary to obtain specific consent as MDS may avail itself of the exemptions referred to in articles 6.1 b), c) and f) of GDPR such as the fulfillment of contractual obligations or pre-contractual measures and legal obligations.

MDS may also process the data in order to enforce or defend a right in court and for the management of litigation, for example in case of disputes. The legal basis for such processing is MDS legitimate interest in having its rights or those of third parties protected.

Finally, in case of explicit consent, the data may be processed for the sending of informative messages and commercial and promotional communications relating to the activity, products and services of the Owner, through automatic means, by e-mail as well as traditional means, such as telephone contact with operator, in full compliance with the principles of lawfulness and correctness and the provisions of law.

NATURE OF THE PROVISION AND MODALITIES OF THE TREATMENT

The provision of the data is necessary and, failing this, it will not be possible to establish any contractual relationship or to properly perform the obligations and commitments arising therefrom.

The data will be processed by the Data Controller and its appointees mainly with electronic and manual systems according to the principles of correctness, loyalty and transparency provided for by the applicable legislation on the protection of personal data and protecting the confidentiality of the subject to whom the data refers through technical and organizational security measures to ensure an adequate level of security (e.g. preventing access to unauthorized persons except in cases required by law, or the ability to restore access to the data in case of physical or technical accidents).

The provision is in any case optional with regard to the processing of data for sending information messages and commercial and promotional communications relating to the activity, products and services of the Owner, as well as for calls with the operator for the same purposes.

DATA RETENTION

The data will be stored in compliance with the applicable legislation for the protection of personal data for as long as necessary to fulfill the above mentioned purposes. In particular, the data will be kept for the entire duration of the contractual relationship in compliance with civil and fiscal obligations (e.g. civil obligation to keep invoices and company documentation for at least 10 years). In case of consent to the sending of informative messages and commercial and promotional communications relating to the activity, products and services of the Owner and the receipt of calls for the same purposes, the data will be kept until the cancellation from our marketing database if an opposition to such processing has occurred.

DATA COMMUNICATION, SHARING AND TRANSFER

Without prejudice to the communications made in compliance with legal and contractual obligations, the data may be communicated to tax or legal advisors, MDS collaborators, credit institutions, as well as to persons entitled by law to receive such information, Italian and foreign judicial authorities and other public authorities, for purposes related to the fulfillment of legal obligations, or for the performance of obligations assumed and arising from the contractual relationship, including for legal defense. The contact data may be communicated for purely occasional and individual needs to MDS customers and/or suppliers, for example if they have to cooperate with such parties for the purpose of providing services.

The data will also be processed by the staff in charge of the administration of MDS.

MDS also makes use of third parties for the provision of certain services involving the processing of personal data including, for example, tax consultants, lawyers, banks or credit institutions, postal couriers and shipping companies, communication agencies, employees etc. and for all services such as technical service providers and IT consultants and other suppliers. These parties operate on the basis of specific and appropriate instructions in terms of processing methods and security measures indicated in specific contractual documentation. The complete and updated list of the parties who process personal data as data processors is available on request by e-mail at privacy@mdsonlineacademy.com 

Except as indicated above, data is generally not transferred outside the European Union; however, should it be necessary to transfer the data to countries outside the European Economic Area, even in countries that do not offer adequate protection, MDS undertakes to ensure adequate levels of protection and safeguard also of a contractual nature according to the applicable rules, including the stipulation of standard contractual clauses (you may request a copy of the commitments made by third parties in the context of such clauses and know the list of countries outside the EEA where the data is transferred by request to be sent to MDS at privacy@mdsonlineacademy.com 

RIGHTS OF THE INTERESTED PARTIES

Interested parties, according to articles 15-21 of GDPR have the right to:

(i) Amendment

MDS will take the necessary measures in accordance with applicable data privacy laws to ensure that your personal data is accurate, complete and up-to-date. If you find that your personal data is inadequate, incomplete or incorrect, you have the right to request that it is amended.

(ii) Access

They may request confirmation of the possible processing of personal data and, in case, access to them and additional information, such as the purposes of the processing. They also have the right to receive a copy of the personal data being processed. If the request is made electronically, the information will be provided in a commonly used electronic format, unless a different format is required.

(iii) Objection to a particular treatment

Interested parties may object to the processing of their personal data processed on the basis of a legitimate interest, for reasons related to their particular situation.

(iv) Deletion

Personal data may be deleted in certain circumstances, for example, if it is no longer necessary for the purposes for which it was collected.

(v) Treatment limitation

They may ask us to limit the processing of their personal data to the sole storage of personal data in certain circumstances, for example, when processing is illegal, but without the personal data being deleted.

(vi) Revocation of consent

They have the right to revoke their consent to the processing of data at any time if the processing is based on consent.

(vii) Data portability

They may request to receive a machine-readable copy of the personal data processed on the basis of their consent or the need for the processing to enter into an agreement and the personal data they have provided to MDS (data portability) and request the transfer of the information to another data controller (if possible).

(viii) Complaints to the supervisory authority

They are made aware that they always have the right to submit complaints regarding the processing of their personal data to the competent data protection authority, if required by applicable data protection laws. The data protection authority to which they can turn to is that of the country of residence or work or the place where the alleged violation occurred. Contact details of the data protection authorities can be found at the following link: https://edpb.europa.eu/about-edpb/board/members_it or you can contact the Data Protection Supervisor.

The Customer undertakes to inform, about the relevant data processing, those whose personal data may be processed by MDS for the purposes set out in this Privacy Policy (e.g. directors, employees and persons who in any capacity work at the Customer) and whose data MDS comes into possession for the purposes of contract execution and provision of services.

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