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Privacy
Policy
This
Privacy Policy was last updated on March 30, 2024.
Thank you for joining Hematech Academy. We at Hematech Academy (“Hematech
Academy”, “we”, “us”) respect your privacy and want
you to understand how we collect, use, and share data about you. This Privacy
Policy covers our data collection practices and describes your rights regarding
your personal data.
Unless we link to a different policy or state otherwise, this
Privacy Policy applies when you visit or use Hematech Academy websites, mobile
applications, APIs, or related services (the “Services”). It also
applies to prospective customers of our business and enterprise products.
By using the Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.
Table of Contents
·
2. How We Get Data About
You
·
3. What We Use Your Data
For
·
4. Who We Share Your Data With
·
7. Jurisdiction-Specific Rules
1. What Data We Get
We
collect certain data from you directly, like information you enter yourself,
data about your consumption of content, and data from third-party platforms you
connect with Hematech Academy. We also collect some data automatically, like
information about your device and what parts of our Services you interact with
or spend time using. All data listed in this section is subject to the
following processing activities: collecting, recording, structuring, storing,
altering, retrieving, encrypting, pseudonymizing, erasing, combining, and
transmitting.
1.1 Data You Provide to
Us
We may
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:
Category of Personal Data |
Description |
Legal
Basis for Processing |
Account Data |
In
order to use certain features (like accessing content), you need to create a
user account, which requires us to collect and store your email address,
password, and account settings. To create an instructor account, we collect
and store your name, email address, password, and account settings. As you
use certain features on the site, you may be prompted to submit additional
information including occupation, government ID information, verification
photo, date of birth, race/ethnicity, skill interests, and phone number. Upon
account creation, we assign you a unique identifying number. |
·
Performance
of contract ·
Legitimate
interests (service provisioning, identity verification, fraud prevention and
security, communication) |
Profile Data |
You
can also choose to provide profile information like a photo, headline,
biography, language, website link, social media profiles, country, or other
data. Your Profile Data will be publicly viewable by others. |
·
Performance
of contract ·
Legitimate
interests (enhanced platform functionality, convey content source
information) |
Shared Content |
Parts
of the Services let you interact with other users or share content publicly,
including by uploading courses and other educational content, posting reviews
about content, asking or answering questions, sending messages to students or
instructors, or posting photos or other work you upload. Such shared content
may be publicly viewable by others depending on where it is posted. |
·
Performance
of contract ·
Legitimate
interests (service provisioning, enhanced platform functionality) |
Learning Data |
When
you access content, we collect certain data including which courses,
assignments, labs, workspaces, and quizzes you’ve started and completed;
content and subscription purchases and credits; subscriptions; completion
certificates; your exchanges with instructors, teaching assistants, and other
students; and essays, answers to questions, and other items submitted to
satisfy course and related content requirements. |
·
Performance
of contract ·
Legitimate
interests (service provisioning, enhanced platform functionality) |
Student Payment Data |
If
you make purchases, we collect certain data about your purchase (such as your
name, billing address, and ZIP code) as necessary to process your order and
which may optionally be saved to process future orders. You must provide
certain payment and billing data directly to our payment service providers,
including your name, credit card information, billing address, and ZIP code.
We may also receive limited information, like the fact that you have a new
card and the last four digits of that card, from payment service providers to
facilitate payments. For security, Hematech Academy does not collect or store
sensitive cardholder data, such as full credit card numbers or card
authentication data. |
·
Performance
of contract ·
Legal
obligation ·
Legitimate
interests (payment facilitation, fraud prevention and security, compliance) |
Instructor Payment Data |
If
you are an instructor, you can link your PayPal, Payoneer, or other payment
account to the Services to receive payments. When you link a payment account,
we collect and use certain information, including your payment account email
address, account ID, physical address, or other data necessary for us to send
payments to your account. In some instances, we may collect ACH or wire
information to send payments to your account. In order to comply with
applicable laws, we also work with trusted third parties who collect tax
information as legally required. This tax information may include residency
information, tax identification numbers, biographical information, and other
personal information necessary for taxation purposes. For security, Hematech
Academy does not collect or store sensitive bank account information. The
collection, use, and disclosure of your payment, billing, and taxation data
is subject to the privacy policy and other terms of your payment account
provider. |
·
Performance
of contract ·
Legal
obligation ·
Legitimate
interests (service provisioning, payment facilitation, fraud prevention and
security, compliance) |
Data About Your Accounts on Other Services |
We
may obtain certain information through your social media or other online
accounts if they are connected to your Hematech Academy account. If you log
in to Hematech Academy via Facebook or another third-party platform or
service, we ask for your permission to access certain information about that
other account. For example, depending on the platform or service we may
collect your name, profile picture, account ID number, login email address,
location, physical location of your access devices, gender, birthday, and
list of friends or contacts. Those platforms and services make information available to
us through their APIs. The information we receive depends on what information
you (via your privacy settings) or the platform or service decide to give us. If you access or use our Services through a third-party
platform or service, or click on any third-party links, the collection, use,
and sharing of your data will also be subject to the privacy policies and
other agreements of that third party. |
·
Legitimate
interests (identity verification, user experience improvement) |
Sweepstakes, Promotions, and Surveys |
We
may invite you to complete a survey or participate in a promotion (like a
contest, sweepstakes, or challenge), either through the Services or a
third-party platform. If you participate, we will collect and store the data
you provide as part of participating, such as your name, email address,
postal address, date of birth, or phone number. That data is subject to this
Privacy Policy unless otherwise stated in the official rules of the promotion
or in another privacy policy. The data collected will be used to administer
the promotion or survey, including for notifying winners and distributing
rewards. To receive a reward, you may be required to allow us to post some of
your information publicly (like on a winner’s page). Where we use a
third-party platform to administer a survey or promotion, the third party’s
privacy policy will apply. |
·
Performance
of contract ·
Legitimate
interests (promotions administration, prize delivery, compliance) |
Communications and Support |
If
you contact us for support or to report a problem or concern (regardless of
whether you have created an account), we collect and store your contact
information, messages, and other data about you like your name, email
address, messages, location, Hematech Academy user ID, refund transaction
IDs, and any other data you provide or that we collect through automated
means (which we cover below). We use this data to respond to you and research
your question or concern, in accordance with this Privacy Policy. |
·
Legitimate
interests (customer and technical support) |
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:
Category
of Personal Data |
Description |
Legal Basis for Processing |
System
Data |
Technical data about your computer
or device, like your IP address, device type, operating system type and
version, unique device identifiers, browser, browser language, domain and
other systems data, and platform types. |
·
Performance
of contract ·
Legitimate
interests (service provisioning, customer and technical support, fraud
prevention and security, communication, product improvement) |
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. |
·
Legitimate
interests (service provisioning, user experience improvement, product
improvement) |
Approximate
Geographic Data |
An approximate geographic
location, including information like country, city, and geographic
coordinates, calculated based on your IP address. |
·
Legitimate
interests (user experience improvement, fraud prevention and security, compliance) |
The
data listed above is collected through the use of server log files and tracking
technologies, as detailed in the “Cookies and Data Collection Tools” section
below. It is stored by us and associated with your account.
1.3 Data From Third
Parties
If you are a Hematech Academy Business enterprise or corporate prospect, in addition to information you submit to us, we may collect certain business contact information from third-party commercial sources.
2. How We Get Data About
You
We use tools like cookies, web beacons, and similar tracking technologies to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.
2.1 Cookies and Data
Collection Tools
We use
cookies, which are small text files stored by your browser, to collect, store,
and share data about your activities across websites, including on Hematech
Academy. They allow us to remember things about your visits to Hematech Academy,
like your preferred language, and to make the site easier to use. To learn more
about cookies, visit https://cookiepedia.co.uk/all-about-cookies.
We may also use clear pixels in emails to track deliverability and open rates.
Hematech Academy and service providers acting on our behalf (like Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools“) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.
2.2 Why We Use Data
Collection Tools
Hematech
Academy uses the following types of Data Collection Tools for the purposes
described:
You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional. To learn more about managing Data Collection Tools, refer to Section 6.1 (Your Choices About the Use of Your Data) below.
3. What We Use Your Data
For
We use
your data to do things like provide our Services, communicate with you,
troubleshoot issues, secure against fraud and abuse, improve and update our
Services, analyze how people use our Services, serve personalized advertising,
and as required by law or necessary for safety and integrity. We retain your
data for as long as it is needed to serve the purposes for which it was
collected.
We use
the data we collect through your use of the Services to:
4. Who We Share Your Data
With
We
share certain data about you with instructors, other students, companies
performing services for us, Hematech Academy affiliates, our business partners,
analytics and data enrichment providers, your social media providers, companies
helping us run promotions and surveys, and advertising companies who help us
promote our Services. We may also share your data as needed for security, legal
compliance, or as part of a corporate restructuring. Lastly, we can share data
in other ways if it is aggregated or de-identified or if we get your consent.
We may
share your data with third parties under the following circumstances or as
otherwise described in this Privacy Policy:
5. Security
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.
Hematech
Academy takes appropriate security measures to protect against unauthorized
access, alteration, disclosure, or destruction of your personal data that we
collect and store. 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 Hematech Academy, 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 password is 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 our Support Team 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, cookies, and collection of your data by certain
third parties. You can update or terminate your account from within our
Services, and can also contact us for individual rights requests about your
personal data. Parents who believe we’ve unintentionally collected personal
data about their underage child should contact us for help deleting that
information.
6.1 Your Choices About
the Use of Your Data
You can
choose not to provide certain data to us, but you may not be able to use
certain features of the Services.
If you have any questions about your data, our use of it, or
your rights, contact us at info@iihmt.org.
6.2 Accessing, Updating,
and Deleting Your Personal Data
You can
access and update your personal data that Hematech Academy collects and
maintains as follows:
6.3 Our Policy Concerning
Children
We
recognize the privacy interests of children and encourage parents and guardians
to take an active role in their children’s online activities and interests.
Individuals younger than 18 years of age, but of the required age for consent
to use online services where they live (for example, 13 in the US or 16 in
Ireland), may not set up an account, but may have a parent or guardian open an
account and help them access appropriate content. Individuals younger than the
required age for consent to use online services may not use the Services. If we
learn that we’ve collected personal data from a child under those ages, we will
take reasonable steps to delete it.
Parents who believe that Hematech Academy may have collected
personal data from a child under those ages can submit a request that it be
removed to info@iihmt.org.
7. Jurisdiction-Specific
Rules
If you
live in California, you have certain rights related to accessing and deleting
your data, as well as learning who we share your data with. If you live in Australia,
you have the right to make a formal complaint with the appropriate government
agency. Users outside of the United States should note that we transfer data to
the US and other areas outside of the European Economic Area.
7.1 Users in California
Users
who are California residents have certain rights under the California Consumer
Privacy Act, (“CCPA”). If you are an eligible California user, included in
these rights are:
CCPA has a specific definition of a “sale” and “sharing” and
while Hematech Academy does not, in the traditional sense, sell your personal
information or the personal information of any of our users, we do use cookies
that make non-personally identifiable information available to select
third-parties, including for cross-context advertising. To opt out of such a
“sale” and “sharing,” click on the “Do Not Sell or Share My Personal
Information” link at the bottom of this page.
To exercise any of these rights under CCPA, please email info@iihmt.org or
write to us at Hematech Academy, Attn: Privacy/Legal Team, 600 Harrison Street,
3rd floor, San Francisco CA 94107. CCPA allows you to designate an authorized
agent to make these requests on your behalf. For your protection, we may
require that the request be sent through the email address associated with your
account, and we may need to verify you and/or your agent’s identity before
fulfilling your request.
Additionally, for more information about the personal
information we collect and how we collect it, please see the sections above
entitled “What Data We Get” and “How We Get Data About You.”
To learn about the business and commercial purposes for which
your personal information is collected and the categories of service providers
who have access to your personal information, please see the sections above
entitled “What We Use Your Data For” and “Who We Share Your Data With.”
As a California resident, you also have the right to request
certain details about what personal information we share with third parties for
those third parties’ direct marketing purposes. To submit your request, send an
email to info@iihmt.org with
the phrase “California Shine the Light” and include your mailing address, state
of residence, and email address.
Since there is no widely accepted standard for the
browser-initiated Do Not Track signal, we do not currently recognize or respond
to Do Not Track signals.
7.2 Users in Nevada
Hematech
Academy does not sell its users’ personal information or personal data. Nonetheless, Nevada
residents have the right to submit a request that we do not sell your covered
personal information, which you can do by emailing info@iihmt.org or
writing to us at Hematech Academy, Attn: Privacy/Legal Team, 600 Harrison
Street, 3rd floor, San Francisco CA 94107.
7.3 Users in the European
Economic Area (“EEA”) and United Kingdom (“UK”)
If you
are located in the EEA or UK, you have the right to request access to your data
in a portable format and to request the rectification, erasure, restriction of
processing, or objection to processing of your personal data. You may use the
information in Section 6.2 to submit your request. Additionally, if you are
located in the EEA, UK, or Switzerland, you also have the right to lodge a
complaint with your supervisory authority.
Personal data is also processed outside of the UK, Switzerland, and the EEA by our Hematech Academy group companies, or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 4. We use the Controller-to-Processor Standard Contractual Clauses adopted by the European Commission to facilitate transfers of personal data from the EEA to third countries and have entered into data processing agreements with our service providers and Hematech Academy group companies to restrict and regulate their processing of your data. By submitting your data or using our Services, you consent to this transfer, storage, and processing by Hematech Academy and its processors.
7.4 Data Privacy
Framework (for EU/EEA, UK, and Swiss data subjects)
Hematech
Academy, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF),
the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Hematech
Academy, Inc. has certified to the U.S. Department of Commerce that it adheres
to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with
regard to the processing of personal data received from the European Union in
reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in
reliance on the UK Extension to the EU-U.S. DPF. Hematech Academy, Inc. has
certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S.
Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to
the processing of personal data received from Switzerland in reliance on the
Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy
Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the
Principles shall govern. To learn more about the Data Privacy Framework (DPF)
program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
The Federal Trade Commission has jurisdiction over Hematech
Academy Inc.’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF)
and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy
Framework (Swiss-U.S. DPF).
We are committed to subject to the DPF Principles all personal
data received from the European Union, UK and Gibraltar, and Switzerland. The
types of personal data collected are described in Section 1 of this Privacy
Policy. The purposes for which we collect and use personal data are described
in Section 3 of this Privacy Policy. The type of third parties to whom we
disclose personal data are described in Section 4 of this Privacy Policy. We
remain responsible for any of your personal data that is shared under the
Onward Transfer Principle with third parties for external processing on our
behalf. Additionally, we may be required to disclose personal data in response
to lawful requests by public authorities, including to meet national security
or law enforcement requirements. Hematech Academy, Inc. shall remain liable
under the DPF Principles if its agent processes personal information in a
manner inconsistent with the DPF Principles, unless Hematech Academy, Inc.
proves that it is not responsible for the event giving rise to the damage.
Individuals have the right to access their personal data, and
instructions on doing so are provided in Section 6.2 of this Privacy Policy.
Individuals may also limit the use and disclosure of their personal data as
described in Section 6.1.
In compliance with the EU-U.S. DPF, the UK Extension to the
EU-U.S. DPF, and the Swiss-U.S. DPF, Hematech Academy, Inc. commits to resolve
DPF Principles-related complaints about our collection and use of your personal
information. EU, UK and Swiss individuals with inquiries or complaints
regarding our handling of personal data received in reliance on EU-U.S. DPF,
the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, should first
contact Hematech Academy at info@iihmt.org.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Hematech Academy, Inc. commits to refer unresolved complaints concerning our handling of personal data received in reliance on EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, to the International Centre for Dispute Resolution/American Arbitration Association (ICDR-AAA), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpfeufiling.html for more information or to file a complaint. The services of ICDR-AAA are provided at no cost to you. Under certain conditions, you may invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms as more particularly detailed here: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2
7.6 Users Outside of the
U.S.
In order to provide the Services to you, we must transfer your data to the United States and process it there. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries.
8. 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 or postal mail with any questions,
concerns, or disputes.
8.1 Modifications to This
Privacy Policy
From
time to time, we may update this Privacy Policy. If we make any material change
to it, we will notify you via email, through a notification posted on the
Services, or as required by applicable law. We will also include a summary of
the key changes. Unless stated otherwise, modifications will become effective
on the day they are posted.
As permitted by applicable law, if you continue to use the
Services after the effective date of any change, then your access and/or use
will be deemed an acceptance of (and agreement to follow and be bound by) the
revised Privacy Policy. The revised Privacy Policy supersedes all previous
Privacy Policies.
8.2 Interpretation
Any capitalized terms not defined in this policy are defined as specified in Hematech Academy's Terms of Use
8.3 Questions
If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team (including our Data Protection Officer) at info@iihmt.org. You can also send postal mail to us at Hematech Academy, Attn: Plot A 4A, Coker House, G.B Coker Estate, Alausa, Ikeja, Lagos, Nigeria.
https://iihmt.org to enable instructors and students to use social login with Google for seamless authentication and access to the learning platform. Read access is essential to retrieve basic user information required for authentication purposes, such as name, email address, and profile picture. This allows users to log in easily and securely, enhancing the user experience.
10.2. Read Access for Virtual Classroom using Google Meet
https://iihmt.org to facilitate virtual classrooms for instructors and students by integrating Google Meet for live classes, discussions, and interactive sessions. Read access is necessary to fetch scheduling information, participant lists, and meeting details from Google Meet. This enables the app to create and manage virtual classrooms efficiently, ensuring smooth and effective live classes.
A narrower scope would not be sufficient because by granting read access for social login with Google and virtual classroom integration using Google Meet, Hematech Academy's app can provide a user-friendly and interactive learning environment, enhancing engagement and collaboration among instructors and students during live classes and educational activities.