The “Services” include:
- the SaaS application related to the authoring account
- the website and (my account pages)
- the (optional) hosting of the learning content for your learners
- the (optional) tracking and tracing database for the results of your learners
- customer onboarding services, branding, built-in support and online help
Data collection, processing, sharing and retention
- What data we get
- How we get data about you
- What we use your data for
- Who we share your data with
- Your rights
- Retention of personal data
- Updates & contact info
1. What data we get
Easygenerator collects and processes personal data of customer representatives directly dealing with Easygenerator for contractual engagements.
While availing Easygenerator application services, customers let Easygenerator process personal data of their end users although neither Easygenerator nor any sub-processor has direct access to any of their courses or personal data except in the case as mandated for help and support purposes for which the user gives explicit consent.
Easygenerator collects certain personal data from you directly, like information you enter yourself, data about your consumption of content, and data from third-party platforms you connect with Easygenerator. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.
1.1 Data you provide to us
We collect different data from or about you depending on how you use the services. Below are some examples to help you better understand the data we collect.
When you create an account and use the services, including through a third-party platform, we collect any data you provide directly, including:
|Account data||In order to use certain features, you need to create a user account as an admin, author or learner. When you create or update your account, we process and store the data you provide like your email address, password, phone number, role, company name and account settings and assign you a unique identifying number|
|Profile data||You can also choose to provide profile information like a photo, name, email, phone number.|
|Shared content||Course content created by authors will be shared among learners. Parts of the services let you interact with other users or share content including questions/answers in courses, course scores, learners’ satisfaction score.|
|Additional services||If you participate in other services like customer satisfaction surveys, Easygenerator and our sub-processor will be able to process your personal data like name, job title, company details, email and phone number. If using EasyAI, please refer to the EasyAI addendum for details.|
The data listed above is stored by us and associated with your account.
1.2 Data we collect through automated means
When you access the Services (including browsing content), we collect certain data by automated means, including:
|System data||Technical data about your computer or device like your mobile device used, operating system, internet provider, date and time of login and logoff, cookie IDs, IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types.|
|Usage data||Usage statistics about your interactions with the Services, including content accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services.|
|Approximate geographic data||An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.|
2. How we get data about you
Data is mostly fed by the authors/learners into the application and stored on our cloud servers.
System data like user ID, mobile device used, operating system, internet provider, date and time of login and logoff, cookie IDs will be automatically collected from the end users and processed by the application.
Personal data is also processed by our suppliers via their respective applications/functionalities powering Easygenerator SaaS application. We have a legal base either as a contractual requirement, legitimate interest or exclusive consent for the processing of personal data.
3. What we use your data for
We use your data to provide our services, communicate with you, troubleshoot issues, improve and update our services, analyze how people use our services, and as required by law or necessary for safety and integrity.
We consider that the legal bases for the processing of your personal data as set out in this privacy notice are as follows:
Our use of your personal data is necessary for complying with our legal obligations; or
Our use of your personal data is necessary for our legitimate interests or the legitimate interests of our sub-processors. Our legitimate interests are to:
- run, grow and develop our business;
- operate our website and provide our services;
- provide onboarding and support to customers;
- build relationships with suppliers and partners;
- for internal administrative and auditing purposes; or
Consent, to send you certain communications or where you submit certain information to us, or where required to rely upon consent by privacy law.
4. Who we share your data with
With a legal basis for processing personal data like legitimate purpose, we share certain data about you with suppliers (sub-processors) performing services for us, Easygenerator affiliates.
We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data for other business purposes only if we have your exclusive consent. The list of sub-processors is provided in the separate DPA annex.
We use appropriate security based on the type and sensitivity of data being stored. As with any internet enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account. Easygenerator urges its authors and learners to enforce strong password policies. Easygenerator strongly urges its customer organizations to integrate SSO with the application for a better access management system.
Easygenerator takes appropriate organizational and technical security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. Easygenerator deploys industry-standard security solutions and measures for data privacy and security. Easygenerator complies with privacy laws like GDPR and aligns its business processes with ISO 27001 standard. Personal data is mostly processed in EU and in case data gets processed by our sub-processor in a non-EU country, DPA with EU standard contractual clauses are in place.
These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Easygenerator, the services, or any information provided to us in connection with the data we collect through the services will be free from unauthorized access by third parties. Your credentials are an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact the support team immediately with any concerns.
6. Your rights
You have certain rights around the use of your data, including the ability to opt out of promotional emails, and collection of your data by certain third parties (like in customer satisfaction surveys). You can update or terminate your account from within our services and can also contact us for individual rights requests about your personal data.
You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.
You can access and update your personal data that Easygenerator collects and maintains as follows:
To update data you provide directly, log into your account and update your account at any time.
You can also delete your profile and personal data instantly.
To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the services, including administrative confirmations, order confirmations, important updates about the services, and notices about our policies.
Easygenerator processes data on behalf of its clients (controllers) and the requests from clients regarding rights of their end users will be addressed in line with GDPR guidelines.
Easygenerator will only access your account upon your request for assistance. You will be asked to provide explicit consent for that. No employee of Easygenerator will access your account without prior permission; unless required to do so by law and in such cases, where legally permissible, Easygenerator shall inform you.
Easygenerator has the option to track and trace the results from your learners. This option can be switched on or off for customer. These results will only be visible to the author (owner) and the admin from customer, not to anyone else. There is also the possibility to show the high-level aggregated results only.
Easygenerator does have the right to analyze this data for general trends and figures, but not on a personal or customer level unless that customer has approved or requested that.
7. Retention of personal data
We keep your personal data for no longer than necessary for the purposes for which the personal data is collected and processed. We only retain the contractual agreement data and not the personal data of customer end users. The length of time we retain personal data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.
End users can delete their profiles and their personal data; and before this they can export the courses to an external LMS system via HTML, XML or SCORM.
8. Cookie management
Session cookies are temporary bits of information which are deleted when you exit the application or the website. Session cookies are typically used to improve navigation and to collect statistics. Easygenerator portal and the application use session cookies.
Persistent cookies are more permanent bits of information that are stored and remain on your computer/phone until they are deleted by you. Persistent cookies delete themselves after a certain period of time but are renewed each time you visit the website.
9. Updates & contact info
When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email with any questions, concerns, or disputes.