GDPR Privacy Policy
Last updated: January 21, 2025
This Privacy Policy describes how Unukalhai Stynthyhos ("we", "us", or "our"), operating at jogirii.info, collects, uses, stores, and protects personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable data protection legislation. By accessing or using our platform, you acknowledge that you have read and understood this policy.
1. Data Controller
Unukalhai Stynthyhos acts as the data controller for personal data collected through this platform. If you have questions regarding the processing of your personal data, you may contact us at:
Address: 4 St Joseph's Ave, Botanic, Dublin, Ireland
Email: help@jogirii.info
Phone: +35312735199
2. Personal Data We Collect
We collect personal data only to the extent necessary to provide our educational services. The categories of personal data we may collect include:
2.1 Data You Provide Directly
When you register an account, enrol in a course, or contact us, we may collect:
| Category | Examples |
|---|---|
| Identity data | Full name, username, profile photo |
| Contact data | Email address, phone number, postal address |
| Account credentials | Password (stored in hashed form), security questions |
| Payment data | Billing address, transaction reference (card details processed by third-party payment providers) |
| Communication data | Messages sent to instructors, support tickets, feedback forms |
2.2 Data Collected Automatically
When you use our platform, we automatically collect certain technical and usage data, including:
| Category | Examples |
|---|---|
| Technical data | IP address, browser type and version, device type, operating system |
| Usage data | Pages visited, session duration, course progress, feature interactions |
| Cookie data | Session identifiers, preference cookies, analytics identifiers |
2.3 Data from Third Parties
If you choose to register or log in using a third-party authentication provider (such as Google or similar services), we may receive basic profile data from that provider, subject to your permissions granted to them.
3. Legal Basis for Processing
We process your personal data only where a valid legal basis exists under Article 6 of the GDPR:
| Purpose of Processing | Legal Basis |
|---|---|
| Providing access to courses and platform features | Performance of a contract (Art. 6(1)(b)) |
| Processing payments and issuing receipts | Performance of a contract (Art. 6(1)(b)) |
| Responding to support enquiries | Performance of a contract (Art. 6(1)(b)) |
| Compliance with legal obligations | Legal obligation (Art. 6(1)(c)) |
| Sending service-related notifications | Legitimate interests (Art. 6(1)(f)) |
| Platform analytics and performance monitoring | Legitimate interests (Art. 6(1)(f)) |
| Sending marketing communications | Consent (Art. 6(1)(a)) |
| Personalising learning experience | Consent or legitimate interests (Art. 6(1)(a)/(f)) |
4. How We Use Your Personal Data
We use collected personal data for the following purposes:
Service delivery: To create and manage your account, provide access to courses, sessions, and learning materials, and facilitate communication between learners and instructors.
Payment processing: To process enrolment fees, issue invoices, and manage refunds where applicable.
Communication: To send transactional emails such as account confirmations, session reminders, and important platform updates.
Personalisation: To adapt learning paths, recommend content, and tailor the platform experience based on your activity and preferences.
Security and fraud prevention: To detect, investigate, and prevent fraudulent transactions or unauthorised access to accounts.
Legal compliance: To meet our obligations under applicable law, including record-keeping and responding to lawful requests from public authorities.
Marketing: Where you have provided consent, to send promotional communications about new courses, features, or offers. You may withdraw consent at any time.
5. Cookies and Tracking Technologies
5.1 What We Use
We use cookies and similar tracking technologies to operate and improve our platform. Cookies are small text files stored on your device when you visit our website.
5.2 Types of Cookies
| Type | Purpose | Retention |
|---|---|---|
| Strictly necessary | Session management, authentication, security | Session or up to 1 year |
| Functional | Remembering preferences, language settings | Up to 1 year |
| Analytics | Understanding platform usage and performance | Up to 2 years |
| Marketing | Delivering relevant communications (with consent) | Up to 1 year |
You may manage or withdraw cookie consent at any time through your browser settings or our cookie preference centre. Disabling certain cookies may affect platform functionality.
6. Data Sharing and Disclosure
We do not sell your personal data to third parties. We may share your data only in the following circumstances:
6.1 Service Providers
We engage trusted third-party processors to support our operations, including cloud hosting providers, payment processors, email delivery services, and analytics platforms. All processors are bound by data processing agreements and are required to handle your data securely and only as instructed by us.
6.2 Instructors
Where you enrol in a course or session, relevant information such as your name and course progress may be visible to the assigned instructor to facilitate effective teaching and personalised support.
6.3 Legal Requirements
We may disclose personal data where required to do so by law, court order, or regulatory authority, or where necessary to protect the rights, property, or safety of our users or the public.
6.4 Business Transfers
In the event of a merger, acquisition, or sale of all or part of our business, personal data may be transferred to the relevant third party as part of that transaction. We will notify affected users in advance where required by law.
7. International Data Transfers
Our platform serves an international audience, and some of our service providers may process data outside the European Economic Area (EEA). Where personal data is transferred to countries not deemed adequate by the European Commission, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent transfer mechanisms.
You may request information about the specific safeguards applied to your data transfers by contacting us at help@jogirii.info.
8. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:
| Data Type | Retention Period |
|---|---|
| Account and profile data | Duration of account plus 2 years after closure |
| Course enrolment and progress records | 5 years from last activity |
| Payment and transaction records | 7 years (legal and accounting obligations) |
| Support communications | 3 years from resolution |
| Marketing consent records | Until consent is withdrawn, plus 1 year |
| Technical and usage logs | Up to 12 months |
When data is no longer required, it is securely deleted or anonymised in accordance with our internal data lifecycle procedures.
9. Your Rights Under GDPR
As a data subject, you have the following rights with respect to your personal data:
9.1 Right of Access
You have the right to request a copy of the personal data we hold about you and information about how it is processed.
9.2 Right to Rectification
You have the right to request correction of inaccurate or incomplete personal data we hold about you.
9.3 Right to Erasure
You have the right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you withdraw consent (and no other legal basis applies), or where you object to processing and there are no overriding legitimate grounds.
9.4 Right to Restriction of Processing
You have the right to request that we restrict the processing of your personal data in certain circumstances, such as while we verify the accuracy of data you have contested.
9.5 Right to Data Portability
Where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transmit it to another controller where technically feasible.
9.6 Right to Object
You have the right to object at any time to the processing of your personal data where we rely on legitimate interests as the legal basis. You also have an unconditional right to object to processing for direct marketing purposes.
9.7 Rights Related to Automated Decision-Making
You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects. We do not currently make such decisions without human involvement.
9.8 Right to Withdraw Consent
Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
9.9 How to Exercise Your Rights
To exercise any of the rights listed above, please submit a written request to help@jogirii.info. We will respond within 30 calendar days of receiving your request. In complex or multiple cases, we may extend this period by a further two months and will notify you accordingly. We may need to verify your identity before processing your request.
9.10 Right to Lodge a Complaint
If you believe we have not handled your personal data in accordance with applicable data protection law, you have the right to lodge a complaint with the competent supervisory authority in your country of residence or place of work.
10. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:
Technical measures: Encryption of data in transit using TLS, encrypted storage of sensitive data, access controls and authentication requirements, regular security assessments and vulnerability monitoring.
Organisational measures: Data protection training for staff with access to personal data, internal data handling policies and procedures, access limited to personnel who require it to perform their duties, incident response procedures for data breaches.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach and, where required, will notify affected individuals without undue delay.
11. Children's Privacy
Our platform is not directed at children under the age of 16. We do not knowingly collect personal data from individuals under 16 without verifiable parental or guardian consent. If you believe we have inadvertently collected data from a minor, please contact us immediately at help@jogirii.info and we will take prompt steps to delete that data.
12. Third-Party Links and Services
Our platform may contain links to third-party websites, tools, or services. This Privacy Policy applies solely to data collected by Unukalhai Stynthyhos. We are not responsible for the privacy practices of third-party sites and encourage you to review their respective privacy policies before providing any personal data.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify registered users by email or through a platform notification.
We encourage you to review this policy periodically. Continued use of the platform after changes are published constitutes your acknowledgement of the updated policy.
14. Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or our data processing practices, please contact us:
Unukalhai Stynthyhos
4 St Joseph's Ave, Botanic, Dublin, Ireland
Email: help@jogirii.info
Phone: +35312735199
Website: jogirii.info