Brainster International

Privacy Policy

The following provisions of Brainster’s Privacy Policy shall govern the manner of use of personal data of the User, Users remedies pursuant to the General Data Protection Regulation (GDPR), procedure in the events of data breaches etc.

The Users is hereby counseled to carefully scrutinize this document.

§ Definitions

  • 1. User. “User” is defined as a natural person who has applied to and/or been accepted to Brainster’s Bootcamps on Data Science and/or UX/UI Design. The term “User” shall also extend to persons wishing to gather further information about the aforementioned Bootcamps via the Website.
  • 2. Brainster. “Brainster” for the purposes of these Terms & Conditions shall mean the Company for internet education CBC KOLEKTIV DOO Skopje, a limited liability company registered under the jurisdiction of the Republic of North Macedonia.
  • 3. Website. “Website” for the purposes of this Privacy Policy shall mean the following landing page – brainster.io
  • 4. Personal data. “Personal data” shall mean any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic cultural or social identity of that natural person. For the purposes of this Privacy Policy the term “Personal data” shall be extended to legal entities.
  • 5. Processing. “Processing” shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  • 6. Controller. “Controller” shall mean the natural or legal entity, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Macedonian applicable law(s) and the General Data Protection Regulation (“GDPR”).
  • 7. Processor. “Processor” shall mean a natural or legal entity, public authority, agency or other body which processes personal data on behalf of the controller.
  • 8. Consent. “Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him, her or it.
  • 9. Personal data breach. “Personal data breach” shall mean a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
  • 10. Supervisory authority. “Supervisory authority” shall mean an independent public authority which is established by the Macedonian government or where applicable any Member State of the European Union or third country which provides adequate protection of the right of the data subject with regards to personal data.

§ Consent

User(s) hereby agree that with the entry of the following information on the Website i.e. the entry of their respective e-mail address, name and surname, phone number, address etc. they (the User(s)) freely give their consent to Brainster for the processing of personal data relating to said User.

With the entry of personal data Users hereby agree to the Privacy Policy.

User(s) explicitly consent to the collection and use of personal data for the specific reason of providing the services of Brainster i.e. the successful rendering of non-formal educational services in the fields of Data Science & UX/UI Design.

User(s) also freely give their consent for the processing of their physical identity via video in instances where they are selected and admitted in to the respective Bootcamp for the purposes of the fulfillment of the online curriculum. In such cases, classes will be held via a video chat service chosen by Brainster that offers the adequate level of security & protection.

Notice: User(s) are hereby informed that their personal information on the Website will be gathered via a form with appropriate fields for name & surname, phone number, address, email etc. In such instances User’s personal data will be gathered in events where the User(s) applies either to the Data Science or UX/UI Design Bootcamp, wishes to secure further information regarding the aforementioned Bootcamps and/or wishes to be further contacted by Brainster.

§ Withdrawal of Consent

Users are free to withdraw consent at any time and for any reason. Withdrawal of consent and all ramifications thereof shall be addressed by the User to the contact address given in the Contact Section of this Privacy Policy.

§ Use of information i.e. personal data and other information

Personal data and other information pertaining to a specific User, described in greater detail in Section Consent of this Privacy Policy, shall be used for the specific reason of providing services that consist of non-formal education, scheduling interviews and test necessary for admittance into the respective Bootcamp, lead generation, and informing interested individuals. User(s) also agree to receive Brainster’s Newsletter.

Personal data and other information shall be used by Brainster for this reason and this reason only.

§ Breach Notification

In the event of a Personal data breach, Brainster i.e. the controller shall without undue delay, and where feasible, no later than 72 hours after becoming aware of the Personal data breach, notify said breach to the supervisory authority, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of the User. Should the notification to the supervisory authority not be made within 72 hours, it shall be accompanied by reason for the delay.

Should the Personal data breach be likely to result in a high risk to the rights and freedoms of the data subject, the controller i.e. Brainster shall communicate the Personal data breach to the subject without undue delay. The aforementioned communication to the data subject shall describe, in a clear and plain language, the nature of the Personal data breach and shall consist of the following:

  • The name and contact details of the Data Protection Officer or other contact point where more information can be obtained;

  • The likely consequences of the Personal data breach;

  • The measures undertaken or proposed to be taken by Brainster to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effect;

User(s) acknowledge that should events arise pursuant to Article 24 Section (3) of the General Data Protection Regulation they may not be informed of the Personal data breach as defined in the previous paragraph.

§ Right of Access

User(s) have the right to obtain from Brainster confirmation as to whether or not Personal data concerning the User is being processed, the purposes of processing, the categories of personal data concerned, the recipients or categories of recipients to whom personal data have been or will be disclosed, he envisaged period for which the personal data will be stored or if not possible the criteria used to determine that period, the existence of the right of rectification or erasure of personal data, the right to lodge a complaint to a supervisory body, source of the data if said data is not collected from the User and the existence of automated decision-making, including profiling.
Furthermore, User(s) shall be provided a copy of their personal data, free of charge, in an electronic format.

§ Right to be Forgotten

Users shall have the right to obtain from Brainster the erasure of personal data concerning the User, without undue delay. Brainster shall have the obligation to erase the personal information regarding the then User now data subject should one of the following apply:

  • The Personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

  • The Data Subject withdraws consent on which the processing is based;

  • The Personal data have to be erased for compliance with a legal obligation;

§ Data Portability

User(s) shall have the right to receive Personal data concerning them, which they provided to Brainster, in a structured, commonly used and machine-readable format. User(s) shall have the right to transmit those data to another controller without hindrance from Brainster.

§ Privacy by Design

Brainster implements appropriate technical and organizational measures for ensuring, by default, only personal data which are necessary for the specific purpose of processing are processed.

Brainster processes and retains only the personal data absolutely necessary for the rendering of the services of the Platform.

Brainster has implemented data-protection principles, such as data minimization, and integrated the necessary safeguards into the processing in order to meet the requirements as stipulated by the governing law and the General Data Protection Regulation and to protect the rights of the data subjects.

§ Disclosure of Personal Data

Brainster shall not disclose personal data of the data subject to any third parties.

Notwithstanding, the previous statement Brainster shall where applicable and necessary under applicable law(s) disclose personal data to competent authorities and governing bodies.

§ Data Storage

Personal data shall be stored on Mailchimp, an all-in-one marketing platform that helps manage client & customer information, secured by login credentials and the level of security thath Mailchimp offers. Access to this database cannot be publicly accessed meaning that access can be granted only to Brainster.

§ Security

User(s) hereby acknowledge that the level of security offered is appropriate to the level of security promised and maintained by Mailchimp.

All of Mailchimp’s login pages pass data via TLS & the entire Mailchimp application is encrypted with TLS

Login pages and login via the Mailchimp API have brute force protection.

Mailchimp performs regular external security penetration test throughout the year using different vendors. Tests include high-level server penetration tests, in-depth testing for vulnerabilities inside the application, and social engineering drills.

§ Cookies and use of third party products

User(s) hereby agree that that the use of Cookies for one of or all of the following is necessary in order for Brainster to render services to its User(s): authentication, security, advertising, performance, analytics and research.

Brainster hereby acknowledges that the use of Google Analytics is incorporated to the extent of measuring how the Website is used by the User(s) and other visitors and to generate reports for Brainster’s internal use. Google Analytics does not collect any personally identifiable information about the User(S).

§ Changes to this Privacy Policy

Brainster retains the right to alter, change, revise or institute an entirely new Privacy Policy on its own discretion at any time Brainster deems fit to do so. Users shall be notified of changes to this Privacy Policy via the e-mail they have submitted upon registering on the Website.

§ Details

Company for internet education CBC KOLEKTIV DOO Skopje, a limited-liability company.
Address: St. Kosturski heroi No. 1/1-36 Skopje – Centar, Republic of North Macedonia
E-mail: [email protected]

Notice: User(s) are hereby informed that the Data Protection Officer and POC (Person of Contact) is Aleksandar Chaminski & can be contacted via the e-mail in this Section of the Privacy Policy.