These are the principles of personal data protection, represented by MindLane s.r.o., with its registered office at Plzeňská 3352/156, Smíchov, 150 00 Praha 5, Czech Republic, ID No. (IČO) 23589779, registered in the Commercial Register kept by the Municipal Court in Prague, acting as the data controller for the services provided under the brand Algonova (‘MindLane s.r.o.’, ‘we’, ‘us’, or ‘our’).

This Privacy Policy ("Privacy Policy") reflects our commitment to protecting personal data and the choices we offer you regarding how your data is used. We welcome you to read more about how we keep your information safe, as well as how you can exercise your rights.

By using the website or services, you confirm that you have read and understood this Privacy Policy which governs the use of algonova.school website and our Platform on alg.academy domain.

You may decide not to give us "discretionary" Personal Data. However, please remember that without it, we may not be able to provide you with the full scope of our administrations or with the best customer experience when utilizing our services.

The personal information that we collect depends on the context of your interactions with us and the services, the choices you make, and the products and features you use.

Henceforth, our primary acquisition and processing of Customer personal data encompass two principal categories: (1) instances where Customers furnish us with their personal information, including that of their children, and (2) scenarios wherein Algonova receives supplementary data directly from Customers and or course participants under specific, circumscribed circumstances and subsequently incorporates it into the Platform.

When you create an account and use the services, including through a third-party platform, we collect any data you provide directly, including:

To use certain features (like paid or unpaid services), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, password, and name, and assign you a unique identifying number ("Account Data").

Personal Data is information that can be used to identify you specifically, including your names, phone numbers, email addresses, usernames, passwords, billing addresses, and mailing addresses. You consent to give us this information by providing it to us voluntarily on our website. Your decision to disclose this data is entirely voluntary. You are under no obligation to provide this information, but your refusal may prevent you from accessing certain benefits from our website.

In accordance with applicable law in the Czech Republic (Act No. 110/2019 Coll. on Personal Data Processing) and Slovakia (Act No. 18/2018 Coll. on Personal Data Protection), children under 15 years in the Czech Republic and under 16 years in Slovakia cannot give valid consent themselves. Any collection or use of a child’s personal data is therefore based exclusively on the consent and contractual agreement of the parent or legal guardian.

This includes information explicitly provided by Customers, such as the child's name, gender, age, contact phone number, contact email address, and any other relevant details shared with us. Additionally, data is obtained during and after the use of our services, encompassing specifics related to the participant’s individual progress, pages viewed, features utilized, error reports, links clicked, and other applications employed on the participant's device. Algonova may also initiate direct contact with the Customers in limited instances, receiving feedback regarding the Platform, services, and compliance with Algonova's standards and policies.

In accordance with our commitment to privacy and data protection, Algonova ensures the responsible handling and processing of participants' personal data, maintaining compliance with applicable laws and regulations. Customers are encouraged to review our privacy policy for comprehensive information on the collection, use, and protection of participant's data within the Algonova platform.

Financial data is related to your payment methods, such as credit card or bank transfer details. We collect financial data to allow you to purchase services from our website. We store limited financial data. Most financial data are transferred to our payment processor, Stripe, and you should review these processors' Privacy Policies to determine how they use, disclose, and protect your financial data.

• Stripe Privacy Policy can be found here https://stripe.com/gb/privacy

This information is registered automatically with the visit by the configuration or manual of each tool on the website.

• When you visit, connect with, or utilise our service, we may gather, record, or create specific specialised data about you. We do so either autonomously or with the assistance of third-gathering Service Providers, including using "cookies" and other following innovations.
• We automatically collect certain information when you visit, use, or navigate the website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website and other technical information.

The information we collect includes:

• Log and Usage Data. Log and usage data are service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our website, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, settings, and information about your activity on the website (such as the date/time stamps associated with your usage, pages, and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or another device you use to access the website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

To ensure the provision of optimal and personalized services, it is imperative for Algonova to collect and process certain personal data. In the absence of this information, our ability to deliver tailored services may be limited. The following categories of data are essential for the effective provision of our services and are required in all cases:

• Name, age, and contact details of course participants and their legal representatives.
• Information about a course participant obtained during the provision of services, including data related to working on the Platform.
• Photographic and/or video images (processed only with the explicit prior consent of the parent or guardian, and solely for educational, feedback, or promotional purposes as specified in the consent).

Customers are advised that entering into an agreement with Algonova necessitates the collection of the mentioned data to facilitate the delivery of our services. Opting out of Algonova' direct contact is possible; however, it is not recommended, as doing so may compromise the assurance of receiving services that adhere to the high standards set by Algonova. Customers are encouraged to carefully consider the implications before opting out of direct contact.

For the purposes described in this Privacy Policy, MindLane s.r.o., operating under the brand Algonova, acts as the data controller responsible for determining how and why your personal data, and that of your child, is processed.

In certain cases where Algonova provides services to another organization (for example, a school or educational partner), we may act as a data processor on their instructions. In such cases, the processing will be governed by a separate Data Processing Agreement (DPA) signed with that organization.

Once your personal information is collected, as detailed above, we may share it with carefully selected third-party service providers (acting solely as data processors under our instructions) for purposes such as email delivery, data hosting, analytics, payment processing, and content streaming. These providers are contractually bound to process personal data only for the purposes specified by us and in compliance with applicable data protection laws.

These services may collect browsing data that includes IP addresses, referring pages, and Customers' movements as they navigate the website. Other third parties help us with our marketing efforts, including sending and analyzing our marketing efforts by measuring whether recipients have opened an email and clicked on any content within it.

Information about our Customers is vital to our business, and we do not sell our Customers' personal information to third parties. Algonova only shares personal information with its subsidiaries and affiliates that are either subject to this Privacy Policy or follow practices that are at least as protective as those described in this Privacy Policy.

Independent service providers: we employ other businesses and individuals to carry out our responsibilities. Examples include data analysis, marketing assistance, payment processing, content transmission, and management. These third-party service providers have access to only the personal information required to perform their functions and are prohibited from using it for any other purpose. In addition, they must process the personal information in accordance with our contractual agreements and the applicable data protection laws.

We keep personal data only for as long as necessary for the purposes set out in this Privacy Policy, unless a longer period is required by law. In particular:

Learning records
Retained until the end of the course plus 3 years, strictly limited to handling potential inquiries, complaints, or disputes. After this period, records will be securely deleted or anonymized.

Children’s personal data
Retained only as long as necessary to provide services and for a maximum of 3 years after course completion, after which it will be securely deleted or anonymized, unless a longer period is legally required.

Billing and financial records
Retained for 10 years in compliance with Czech and Slovak accounting and tax regulations (e.g. Act No. 563/1991 Coll. on Accounting in the Czech Republic and Act No. 431/2002 Coll. on Accounting in Slovakia).

Marketing consents
Retained until consent is withdrawn.

Technical logs and security records
Retained for up to 1 year.

You have a variety of rights granted to you pursuant to GDPR. Below, we outline the main of them in brief, albeit there are others that we did not list. Should you need more detailed guidance, please contact us or an independent GDPR specialist on your rights.

You have the right to withdraw from us your consent to process your and your child's personal data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. If we are not required to collect such data in order to fulfil our legal obligations, or if it is not in our legitimate interest, we will delete or otherwise process your data. For more details on this, please read Article 7 of the GDPR.

You have the right to obtain confirmation from us as to whether your and your child's personal data are being processed, and, where that is the case, access to that personal data, the information concerning how we process it, and some other information. For more details on this right, please read Article 15 of the GDPR.

You have the right to obtain from us the rectification of your and your child's personal data. You also have the right to have incomplete personal data completed. For more details on this right, please read Article 16 of the GDPR.

If you have given us consent to send you newsletters or other marketing communications, you may withdraw this consent at any time. See “Your Rights” for details on how to withdraw.

You have the right to obtain from us the erasure of your and your child's personal data, and we will erase that personal data without undue delay unless we are required to collect such data to fulfil our legal obligations or unless it is in our legitimate interest. For more details on this, please read Article 17 of the GDPR.

You have the right to ask us to restrict the processing of your and your child's personal data. For more details on this right, please read Article 18 of the GDPR.

You have the right to object that we process your personal data on the basis of our legitimate interest on grounds relating to your particular situation to processing of your and your child's personal data, and we will no longer process that personal data unless we are able to demonstrate compelling legitimate grounds for such processing. Send us an objection to our contact email, and we will evaluate it immediately, within 30 days at the latest. For more details on this, please read Article 21 of the GDPR.

You have the right to receive from us your and your child's personal data, which you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transmit those data to another controller. For more details on this, please read Article 20 of the GDPR.

You have the right to lodge a complaint with a supervisory authority, in particular, in the member EU state of your habitual residence, place of work or an alleged infringement of the GDPR, about our collection and processing of your and your child's personal data. For more details on this right, please read recital 141-143, articles 12, 13, 15, 77 and others of the GDPR.

We respond to all requests we receive from individuals in the EEA who are using the services directed to the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.

The personal information we process may be transmitted or transferred to countries other than where you reside. Those countries may have data protection laws that are different from the laws of your country. This may include transfers of data to the United States when we use providers such as Stripe, Google, or Meta. In such cases, we rely on the EU–U.S. Data Privacy Framework or Standard Contractual Clauses approved by the European Commission to ensure adequate protection.

The servers for our Platform are in EU, and Algonova and third-party service providers operate in many countries around the world. When we collect your personal information, we may process it in any of those countries.

We have taken appropriate steps and put safeguards in place to help ensure that your personal information remains protected by this Privacy Statement. For example, any data transfers between our group companies are governed by our intragroup agreements, which incorporate strict data transfer terms (including the European Commission's Standard Contractual Clauses for transfers from the EEA) and require all group companies to protect the personal information they process in accordance with applicable data protection law.

We also require that third-party service providers to whom a data transfer is made have appropriate safeguards in place to protect your personal information in compliance with applicable data protection laws. The measures used will depend on the service provider, and our agreements with them may include European Commission-approved Standard Contractual Clauses (SCCs), reliance on the service provider’s Binding Corporate Rules, or their participation in the EU–U.S. Data Privacy Framework (for transfers to the United States). These safeguards ensure that your personal data remains protected in line with EU and Czech/Slovak data protection law.

We have implemented industry-accepted administrative, physical, and technology-based security measures to protect against the loss, misuse, unauthorized access, and alteration of personal information in our systems. We ensure that any employee, contractor, corporation, organization, or vendor who has access to personal information in our systems is subject to legal and professional obligations to safeguard that personal information.

Your personal information is only accessible by a limited number of individuals who have special access privileges to such systems and are required to treat the information with strict confidentiality. In addition, the extremely sensitive/credit information of your resource is encrypted using Secure Socket Layer (SSL) technology.
We implement several security measures whenever a user gets into, submits, or accesses their information to protect your individual information.

While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or form of electronic storage is 100 per cent secure. Therefore, we cannot guarantee its absolute security.
Algonova prohibits unauthorized access or use of personal information stored on our servers. Such access is a violation of law, and we will fully investigate and press charges against any party that has illegally accessed the information within our systems.

To the fullest extent permitted by applicable law, Mind Lane s.r.o. shall not be liable for any indirect, incidental, or consequential damages arising out of or in connection with the use of our website or services. Some jurisdictions do not allow such exclusions or limitations, so this limitation may not apply to you.

Our services are primarily intended for use within the European Union and European Economic Area. If you access our website or services from outside these regions, you are responsible for compliance with your local laws.

This Privacy Policy is governed by the laws of the Czech Republic and Slovakia in relation to services provided in those countries, as well as by directly applicable European Union regulations, in particular the General Data Protection Regulation (GDPR).

You have the right to lodge a complaint with a supervisory authority:

• In the Czech Republic: Úřad pro ochranu osobních údajů, Pplk. Sochora 27, 170 00 Praha 7, Czech Republic (www.uoou.cz) with email address posta@uoou.cz.
• In Slovakia: Úrad na ochranu osobných údajov Slovenskej republiky, Hraničná 12, 820 07 Bratislava 27, Slovak Republic (www.dataprotection.gov.sk) with email address statny.dozor@pdp.gov.sk

You can exercise any of the rights described above in the "What are your choices and how can you exercise them?" section directly by sending an email to data.privacy@algonova.school or by mailing a non-registered letter with a document proving your identity to the below address:

MindLane s.r.o.
Email: data.privacy@algonova.school
Address: MindLane s.r.o., Plzeňská 3352/156, Smíchov, 150 00 Praha 5, Czech Republic.
Address for correspondence: see above address.

If you are submitting a request on behalf of another person, you must provide proof that you have been authorized by the individual to act on his or her behalf. In certain circumstances, we may ask the individual to verify his or her own identity directly with us. Please note that we may deny a request from an authorized agent who does not submit proof that they have been authorized by you to act on your behalf.

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, or other factors.

• Minor updates (such as clarifications, wording improvements, or formatting changes) will be published on this page with the “last updated” date adjusted.
• Material changes (such as new purposes for processing, new categories of personal data, or changes in how we share information) will be published on this page and communicated directly by email to all parents or legal guardians associated with active student accounts before the changes take effect.

We encourage you to review this Privacy Policy periodically to stay informed about how we handle personal data.