PRIVACY STATEMENT

ExpertCollege processes personal data for the provision of our products and services. We hereby act in accordance with the General Data Protection Regulation (GDPR) to guarantee that your data is processed carefully, and your privacy is secured. In the GDPR, the party responsible for your personal data is referred to as the Data Controller. If you use our products or services, or if you work with us or enter a business relationship with us, we become the Data Controller for certain personal data when personal data is exchanged or processed.

In this privacy statement, we would like to inform you about our policy, the way in which ExpertCollege handles your personal data, and how we determine our duties as Data Controller. We would also like to inform you of your rights when ExpertCollege processes your personal data.

If you have any questions after reading this privacy statement, or if you have a comment about the way we handle your personal data, then you will find more information at the bottom of this page on how you can get in touch with us.

1. What personal data do we process?

When creating an account on our website

You have purchased e-learning modules via our website or you have received access to our e-learning modules. To give access to our e-learning and to enable your progress and development in the e-learning modules, we require some information from you. To register your account, we process the following data:

• Your first name and last name;
• Your gender;
• Your email address.

When ordering products on our website

When you order the e-learning modules via our website, we also collect data for the payment of our products, and in some cases, the shipment of products by mail. In these cases, there are some additional information that we request and process from you, namely:

• Your address details;
• Your billing information;
• Your payment method
• Your phone number.

When you activate our e-learning or purchase on behalf of a study that follows a higher education institution, we ask you to register for the following data:

• The educational institution where you are studying;
• The training you follow;
• The year in which you participate;
• The class in which you participate.

If you do not study at an institution, you can select “Other” as an institution; in which case, we will not collect this information from you.

Using our e-learning

When you study with our e-learning modules, we also create study progress data. We register if you have started with a module and if you have completed this. After completing a module, a certificate is made available. Our system also records your answers in the e-learning. This automatic registration is necessary to determine your score, to determine when you have obtained the certificate, to determine which questions and topics need to be brought to your attention, and to be able to show this progress to you. During this process, we therefore make the following information from you:

• Study progress data.

After completing an accredited e-learning module, we offer you the opportunity to register your BIG registration number or membership number of an association so that we can apply for your accreditation with the relevant association. We link this information to your profile so that we can apply for accreditation as easily as possible for you in the future.

Using our e-learning as part of your study

You might be using our e-learning because you study at an educational institution for your degree program. Your institution will, for example, prescribe the use of an e-learning from ExpertCollege to support your study.

In these cases, ExpertCollege offers you the opportunity to share your study progress data with your educational institution, so that your study supervisor can gain insight into the modules for which you have obtained a certificate. ExpertCollege will only share your study progress data if you have explicitly given permission for this. You can grant this permission at any time and withdraw it at any time.

After we have received your consent, we determine which supervisor and educational institution we will share your study progress data with. We use the information about your educational institution, training, grade, and class that you have entered in your order. You can change this information at any time in your account.

Upon acknowledgement of your consent, we share the following information with your study supervisor:

• Your first name and last name;
• Your study progress data;
• Your academic year and class.

Direct marketing

In the course of conducting marketing research, we might find your contact details through publicly available sources, such as official websites of Universities, Higher education institutions and Hospitals.

In such cases we might contact you, if we think that our products/services are relevant to you considering your professional occupation. If we contact you for such purposes, it will be only on your business e-mail, thus we consider this as B2B marketing. In case you do not want to receive communication from us, you have the option to opt-out from our email list.

The information that we might collect during our marketing research is:

• Your names;
• Your business e-mail address;
• Your professional title;
• The institution in which you work.

We collect this information based on our legitimate interest to promote our products/services. However, we always take into consideration your rights and interests first and balance them against our legitimate interest before we contact you.

2. Why do we process this personal data?

You have either received access to our e-learning, or you have purchased our e-learning directly from our website. With this purchase, we guarantee an efficient digital learning environment. In order to achieve this, it is necessary that we process certain personal data from you.

ExpertCollege does not process more data than necessary to guarantee the above. The objectives of the data arising from our products and services include:

• Registering a user account;
• Registering your study progress in our e-learning modules;
• Offering a certificate upon completion of a module;
• Processing payments and orders for our products and services.

In addition, there are a number of purposes for which we only use your data after you have explicitly given us consent to do so. This involves the following goals:

• Analyzing our product usage and improving our products and services;
• Sharing information about our products and services through our newsletter;
• Sharing your study progress data with your educational institution (if applicable).

Without your consent, we will not use your data for these three purposes mentioned above.

3. Are your personal data shared with third parties?

ExpertCollege only shares your details with third parties if this is necessary for the fulfillment of the agreement that arises from your purchase, or when you have given permission for this.

In practice, this means that your data is shared with partners within the EU who support us in offering a working product. A list of these partners can be found here.

As indicated above, your data can also be shared with your study supervisor at your educational institution as registered in your account. However, this only happens when you give permission to do so through your account.

4. How long will your data be stored?

If a legal term exists for the processing of certain personal data, ExpertCollege will keep these personal data for at least as long as the law prescribes and / or no longer than the legally prescribed term.

For most of the personal data processed by ExpertCollege, such a statutory period does not exist. Personal data from your account as well as the study progress data registered therein will be retained for up to 10 years after your last login to your account. After that, your personal data will be irreversibly deleted.

Data for marketing and commercial purposes will be retained for as long as you are registered as a client of ExpertCollege, or until we have established that you are no longer a (potential) customer of our products or services.

5. What are your rights?

When we process your personal data you will be referred to as the Subject concerned under the GDPR. As a data Subject, you enjoy various rights to protect your privacy. You can contact us, the Data Controller, at any time to invoke your rights. You can find out how this can be done at the bottom of this page.

As a Subject you have the following rights:

• Right to access: inspection of the personal data we process;
• Right to rectification: the right to correct inaccurate data or information which we hold about you;
• Right to be forgotten: the right to have personal data we process to be deleted;
• Right of objection: the right to object to the processing of your personal data on the basis of a legitimate interest or for direct marketing.

If you want to use one of the above rights, we ask you to send an email to dpo@expertcollege.com. To establish your identity and to determine that the request really comes from you, we ask you to send a copy of your identity card or passport. To protect your privacy, we ask you to blacken the passport photo, the Social Security number, passport number, and MRZ code (series of numbers, letters and characters at the bottom of your passport). We will inform you when we have processed your request and we will strive to respond to your request within four weeks.

For your convenience you can use our Data Subject Access Request form, which can be downloaded from here.

6. Data Protection Officer

ExpertCollege has appointed a Data Protection Officer (DPO) to supervise the way in which ExpertCollege processes your personal data. The DPO advises the management and the employees of ExpertCollege about everything that has to do with the processing of personal data and privacy.

The DPO is also your first point of contact for questions or comments about the processing of your personal data by ExpertCollege, or when you wish to make use of your rights under the GDPR. If you believe that ExpertCollege deals with your personal data in an incorrect or unlawful manner, you can contact our Data Protection Officer. You can do this by sending an e-mail to dpo@expertcollege.com, for the attention of Mr. J. Tuinman.

You can also contact us by post. Send your correspondence in this case to:

ExpertCollege BV

T.a.v. Data Protection Officer

Gondel 1

1186 MJ AMSTELVEEN

7. Complaints

If you are dissatisfied with our response to or the way we have handled your question or comment, and you believe that we are dealing with your data unlawfully, you can submit a report to your local Supervisory Authority. The Supervisory Authority for Personal Data supervises compliance with privacy laws and regulations on behalf of the government. You can submit your report or complaint on the website of your local Supervisory Authority.