Privacy Statement

At Mysoly, we are committed to protecting the privacy and security of your personal data. This Privacy Statement explains how we collect, use, store, and protect your personal data as you interact with our platforms, including our learning management systems, test simulations, and other related services. By accessing or using our services, you consent to the collection and use of your data in accordance with this Privacy Statement.

Last Updated: 31/12/2024

Definitions

1.1 Platform: A platform includes but is not limited to providing a multilingual, communicative, and interactive learning environment both for Instructors and Students.

– Tijd4.nl

– 7LMS.com

– Surms.com or similar.

1.2 Clients: Organizations or enterprises that enter into agreements with the Company to access and utilize our Platform.

1.3 Students: Individuals who use the Platform for learning purposes, including accessing lessons, participating in quizzes, and receiving feedback. This includes but is not limited to individuals using our services to enhance their skills, prepare for certifications, or achieve specific educational goals.

1.4 Instructors: Individuals or entities who use the Platform to create, provide, or manage lessons and educational content. This includes professionals, educators, or organizations responsible for delivering learning materials and monitoring progress.

1.5 Content: Any material, including but not limited to text, images, videos, and other data, uploaded or By uploading content to our services, you grant us a non-exclusive, worldwide license to use, display, and distribute such content generated by Clients, Students, or Instructors while using our Platform, solely to provide and improve the services. Those content can be shown to potential clients for demo and marketing purposes by Company. 

1.6 Mysoly API: The API used to perform AI-powered Large Language Model (LLM) calls and provide feedback.

1.7 Text-to-Speech API: The API that converts text into speech in a multilingual manner to support accessibility and engagement.

1.8 Translation API: The API that translates Student or Instructor inputs into multiple languages for enhanced usability.

1.9 Performance Dashboard: A feature within the Platform that provides analytics and insights on learning progress and engagement.

1.10 Other Tools: Customizable tools within the Platform that allow users to use all platform features in a safe and secure mode. 

1.11 Services: Providing AI-based multilingual and interactive learning and learning management platforms or software for different purposes. 

 

1. Information We Collect

We collect the following types of personal information when you use our services:

• Personal Identification Information: Name, email address, phone number, and other contact details.
• Account Information: Username, password, preferences, and user settings.
• Usage Data: Information on how you access and use the platforms, including time spent on the platform, features used, and pages visited.
• Learning Data: Data related to your learning activities, such as courses enrolled in, progress, quiz results, and feedback.
• Payment Information: If applicable, payment details for subscription or course fees.

 

2. How We Use Your Information

We use your personal information for the following purposes:

• To provide, maintain, and improve our platforms and services.
• To personalize your learning experience and deliver relevant content.
• To communicate with you, including sending notifications about your account, updates, and promotional materials (only if you opt-in).
• To process payments for subscriptions or courses (if applicable).
• To monitor and analyze usage and trends to improve platform functionality.
• To ensure compliance with our policies and legal obligations.

3. How We Share Your Information

We may share your personal data with third parties under the following circumstances:

• Service Providers: We may share your data with third-party service providers who assist with platform operations, such as payment processing, email communications, and data analytics. These providers are obligated to protect your data and only use it for the specified purposes.
• Legal Requirements: We may disclose your information to comply with legal obligations, such as responding to subpoenas, court orders, or government requests.
• Business Transfers: In the event of a merger, acquisition, or sale of our assets, your personal data may be transferred as part of that transaction.

 

4. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Statement or as required by law. After this period, your data will be securely deleted or anonymized.

• Account Information: Retained for the duration of your account’s existence.
• Payment Information: Retained for 7 years in compliance with tax regulations.
• Learning Related Data: Retained for the duration of your subscription plus 1 year for performance analysis unless otherwise requested.

 

5. Your Rights

You have the following rights regarding your personal information:

• Access: You can request a copy of the personal data we hold about you.
• Correction: You can request corrections to any inaccurate or incomplete personal data.
• Deletion: You can request the deletion of your personal data, subject to certain exceptions (such as ongoing contractual obligations).
• Objection and Complaints: You can object to the processing of your data for marketing purposes or other legitimate interests. If you believe we have not complied with data protection laws, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or your local supervisory authority.
• Data Portability: You can request a copy of your data in a structured, commonly used, and machine-readable format.
• User Control: If you do not want to use our platforms driven by AI LLM models, you may cancel your contract according to the agreement you have. It is not possible to limit or control AI functionality per-user-based.

To exercise any of these rights, please contact us at [Insert Contact Information].

 

6. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our platforms. These technologies help us analyze usage, customize content, and improve platform performance. You can control cookie settings through your browser, but disabling cookies may affect your experience.

 

7. Data Security

We implement reasonable security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

 

8. Use of AI, LLM, Text-to-Speech, Text-to-Image, and Third-Party APIs

As part of our services, we integrate advanced technologies, including Artificial Intelligence (AI), Large Language Models (LLM), text-to-speech (TTS), text-to-image (T2I), and third-party APIs. These technologies are used to enhance the learning experience, improve content delivery, and provide personalized learning paths. The following outlines how we use these technologies and how your data is handled:

Artificial Intelligence and Large Language Models (LLM)

• We use AI and LLM technologies to generate content, provide instant feedback on exercises, and assist with personalized learning recommendations. These models may process and analyze the text you submit for language learning, such as your written answers or interactions within the platform.
• Anonymized Data: We may use anonymized or aggregated data to enhance our AI models, improve our platform, and conduct research. This data cannot be traced back to individual users
• Data Use: When interacting with these AI systems, the text you provide may be temporarily processed to improve the accuracy of feedback or the system’s recommendations. However, we do not use your personal data for training purposes unless explicitly stated and with your consent.
• Data Retention: Input data from AI interactions may be retained temporarily for performance improvement and quality control. We anonymize and securely store data where possible to ensure user privacy.
• Automated Decision-Making: Some features of our platform may involve automated decision-making, such as personalized learning paths or scoring of assignments. Users can request human intervention, express their viewpoint, or contest decisions by contacting us at support@mysoly.nl.

Text-to-Speech (TTS) Technology

• We use text-to-speech technology to convert written content into audio format, helping learners with pronunciation and listening practice.
• Data Use: The text you input or the content displayed on the platform may be processed by TTS engines to create spoken output. We ensure that this data is processed solely for the purpose of delivering the TTS feature and is not used for any other purpose.
• Data Retention: Audio data generated by TTS may be temporarily stored for the duration of the session to facilitate interaction with the content. This data will not be retained beyond the necessary session duration unless otherwise indicated.

Text-to-Image (T2I) Technology

• Text-to-image technology is used in some features of the platform to generate visual content based on textual descriptions, such as creating images for educational purposes or generating visual feedback for assignments.
• Data Use: The text you provide may be processed to generate images or visual content. This data will be used only for the specific request or task and will not be retained for other purposes.
• Data Retention: Generated images may be temporarily stored within the platform to support user interactions but will not be stored permanently unless required by the service features (e.g., saving assignments or images).

Third-Party APIs

• We integrate third-party APIs to enhance the functionality of our platforms. These APIs may include features like language translation, analytics, payment processing, and others essential for platform performance.
• Data Use: When you interact with these third-party services, your data may be shared with the respective service providers. We ensure that all third-party APIs comply with relevant data protection regulations and that any data shared is limited to what is necessary to fulfill the purpose of the API.
• Third-Party Providers: These third-party service providers are required to process your data in accordance with strict privacy and security protocols. They are prohibited from using your personal information for any purpose other than to deliver the requested service.
• Data Retention: The data shared with third-party APIs will be governed by their respective privacy policies. We encourage you to review these third-party privacy policies to understand how your data may be handled.
• All third-party service providers are bound by strict contractual obligations, including GDPR-compliant Data Processing Agreements (DPAs), ensuring your data is used solely for agreed purposes.

Data Security & Privacy

• We prioritize your privacy and the security of your data. While we strive to ensure that all AI, TTS, T2I, and third-party API integrations comply with high standards of data protection, please note that these technologies may involve the processing of data by external providers. We take all reasonable steps to safeguard your personal information, but we cannot guarantee absolute security due to the inherent risks of using cloud-based technologies and APIs.
• Anonymization: Where feasible, data used for AI and third-party API processing is anonymized to reduce the risk of identification and to protect your privacy.

9. Data Breach Notification

You will be notified in 72 hours in case of data breach.

 

10. Data Protection Officer

11. International Data Transfers

Your personal data may be transferred to and stored in servers located outside of your country of residence (AWS Cloud). By using our services, you consent to the transfer of your data to these locations, which may have different data protection laws. 

Where personal data is transferred outside the European Economic Area (EEA), we rely on Standard Contractual Clauses (SCCs) or other legally recognized safeguards to ensure data protection levels equivalent to those within the EEA.

 

12. Children’s Privacy

Our platforms are not intended for children under the age of 16. We do not knowingly collect or solicit personal information from children under 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information.

In some circumstances for users under 16, we require parental or guardian consent to collect or process personal information. Parents or guardians can contact us to review, update, or delete their child’s data.

 

13. Changes to This Privacy Statement

We may update this Privacy Statement from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Any updates will be posted on this page with a revised “Effective Date.” We encourage you to review this Privacy Statement periodically.

14. Consent

By using our platforms and services, you acknowledge that you have read and understood this Privacy Statement, and you consent to the collection, use, and sharing of your personal data as described herein. If you do not agree with the terms of this Privacy Statement, please do not use our services.

 

15. Contact Information

If you have any questions or concerns about this Privacy Statement or our data practices, please contact us at:

Mysoly E-Learn BV

support@mysoly.nl

+31687213354

Ambachtweg 17A, 5731AE Mierlo
KVK: 90169301

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Legal Basis for Data Processing under EU GDPR

We process personal data in compliance with the European Union’s General Data Protection Regulation (EU GDPR). The following legal bases apply to our data processing activities:

1. Performance of a Contract (Article 6(1)(b))
   We process your data to fulfill our contractual obligations, including providing our platforms and services, enabling your access, and delivering content or courses.

2. Consent (Article 6(1)(a))
   Where required, we obtain your explicit consent to process your data, such as for marketing communications, using optional AI-driven features, or collecting certain types of sensitive information.

3. Compliance with a Legal Obligation (Article 6(1)(c))
   We process data as required to comply with applicable laws, such as tax regulations, record-keeping, or responding to lawful requests by public authorities.

4. Legitimate Interests (Article 6(1)(f))
   We process data to pursue our legitimate interests, provided that these do not override your fundamental rights and freedoms. Examples include:

   • Improving platform functionality and user experience.
   • Analyzing trends to enhance our services.
   • Ensuring the security of our platforms and detecting fraud or abuse.

5. Vital Interests (Article 6(1)(d))
   In rare cases, we may process your data to protect your vital interests or those of another person, such as in emergencies involving health or safety.

6. Public Interest or Official Authority (Article 6(1)(e))
   If applicable, we may process data to perform a task carried out in the public interest or in the exercise of official authority, although this is not typically relevant to our operations.

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