PRIVACY POLICY

Last Updated: June 9, 2025

1. OUR COMMITMENT TO YOUR PRIVACY

Welcome to Code & Learn ("we," "us," "our"). Your trust is our top priority. This Privacy Policy explains in detail how we collect, use, store, share, and protect your personal data when you visit our website https://clearn.top (the "Website") and use our educational services (the "Services").

This policy applies to data provided by you, a parent or legal guardian ("Client," "you"), and data relating to your child ("Student"). By using our Website and Services, you acknowledge and consent to the data practices described in this policy.

2. DATA CONTROLLER

For the purpose of the UK General Data Protection Regulation (UK GDPR) and other applicable data protection laws, the data controller is German Vitiaz.

Contact Email: [email protected]

3. INFORMATION WE COLLECT

We adhere to the principle of data minimization and only collect information that is necessary to provide and improve our Services.

3.1. Information You Provide Directly:

• Client Account Information: When you register or contact us, we collect your full name, email address, and phone number.
• Student Information: To personalize the learning experience, we collect the Student’s first name and age. We do not require the Student's full name or any direct contact information.
• Communication Data: Records of your correspondence with us, including emails, chat messages, and feedback.

3.2. Information Collected Automatically:

• Technical and Usage Data: We automatically log information about your device and how you interact with our Website. This includes your IP address, browser type and version, operating system, pages viewed, time spent on pages, and dates/times of your visit. This data is used for security and analytics.

3.3. Information from Third Parties:

• Payment Data: When you make a payment, you provide your payment details directly to our third-party payment processors (e.g., Robokassa, CryptoCloud). We do not collect or store your full financial details (like credit card numbers). We only receive a transaction confirmation, which may include your name and transaction ID.

4. HOW AND WHY WE USE YOUR INFORMATION (LEGAL BASIS)

We process your data based on the following legal grounds:

• To Fulfill Our Contract: To create your account, schedule and conduct lessons, and provide customer support.
• For Our Legitimate Interests: To improve our Website and Services by analyzing usage patterns, to ensure the security of our platform and prevent fraud, and to maintain records for our business operations.
• With Your Consent: For sending you marketing communications, from which you can opt-out at any time.
• To Comply with Legal Obligations: To meet legal and regulatory requirements (e.g., tax and accounting).

5. LESSON RECORDINGS

To ensure the quality of our teaching, for the safety and security of both Students and Instructors, and to provide a review resource for the Student, lessons may be recorded.

• Purpose: Quality control, instructor training, dispute resolution, and to allow the Student to review the lesson content.
• Access: Access to recordings is strictly limited to senior staff, the specific instructor for training purposes, and the Client/Student upon request. Recordings are never shared publicly or with third parties, except as required by law.
• Retention: Recordings are stored securely and automatically deleted after a limited period (e.g., 90 days), unless a specific incident requires a longer retention for investigation.
• Your Rights: You have the right to object to the recording of lessons by contacting us in advance.

6. DATA SHARING AND DISCLOSURE

We do not sell your personal data. We may share your information only as follows:

• Authorized Instructors: To provide the tutoring services, our vetted instructors will have access to the Student's first name and relevant learning information. They are bound by strict confidentiality agreements.
• Third-Party Service Providers: With vendors who perform services for us, such as web hosting, analytics, and payment processing. They are contractually obligated to protect your data.
• Third-Party Tools: Our lessons may be conducted on platforms like Zoom or Discord. Your use of these platforms is subject to their own privacy policies, which we encourage you to review.
• Legal Requirements: We may disclose your information if required by law or in the good faith belief that such action is necessary to comply with a legal obligation or protect the safety of our users.

7. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your own. We ensure that any such transfers comply with UK GDPR and are protected by appropriate safeguards, such as Standard Contractual Clauses.

8. YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights including:

• Right to Access: You can ask for a copy of your personal data.
• Right to Rectification: You can ask us to correct inaccurate data or complete incomplete data.
• Right to Erasure ("Right to be Forgotten"): You can ask us to delete your personal data in certain circumstances.
• Right to Restrict Processing: You can ask us to limit the use of your personal data.
• Right to Data Portability: You can request that we transfer your data to another organization.
• Right to Object: You can object to our processing of your data, especially for direct marketing.

To exercise these rights, please contact us at [email protected]. We will respond to your request within one month.

9. CHILDREN'S PRIVACY

We are committed to protecting children's privacy. We provide services for children, but we only collect personal information from parents or legal guardians on their behalf. We require verifiable parental consent for the collection of a child's data. If you believe we have inadvertently collected information from a child without proper consent, please contact us immediately.

10. COOKIES AND TRACKING TECHNOLOGIES

We use cookies to operate and secure our Website, remember your preferences (like language), and gather analytics. You can control cookies through your browser settings. For more details, please see our full Cookie Policy (if applicable) or contact us.

11. "DO NOT TRACK" SIGNALS

Our Website does not currently respond to "Do Not Track" (DNT) signals.

12. LINKS TO OTHER WEBSITES

Our Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We have no control over and assume no responsibility for the content or privacy practices of any third-party sites.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you by posting the new policy on this page and updating the "Last Updated" date. We encourage you to review this page periodically.

14. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us:

By Email: [email protected]
By Phone: +44 7597 730 403