This is the privacy policy of Algorithmics Global FZE.

By using our platform, websites, services, products, software ("Services"), you understand and agree to the collection and use of your and your child's information in accordance with this privacy policy. Our privacy policy applies to all visitors, users, clients, and other natural persons who access to our Services ("you" or "your") provided we execute the function of data controller (joint data controller) with respect to your and/or your child's personal data.

This policy applies to the extent it does not contradict service agreement signed between our (sub)franchisee and respective data subject. In case of any discrepancies, privacy and confidentiality clauses of that service agreement prevail over the provisions of this privacy policy.

PLEASE READ THIS POLICY ATTENTIVELY.

1. WHO WE ARE

IN SHORT: We are a group of companies developing an interactive platform for children whose parents are interested in their children receiving after-school programming classes. Customers get access to its functionality through our (sub)franchisees. We obtain and process personal data regarding our (sub)franchisees' clients as well as limited personal data of representatives of our potential (sub)franchisee in accordance with applicable legislation.

We, at Algorithmics Global, have developed an interactive platform for children whose parents are interested in their children receiving after-school programming classes ("Platform"). We do not provide services to Customers directly. We attract trusted providers to become our (sub)franchisees. We grant them access to the functionality of Platform, administer the Platform, provide (sub)franchisees with all information that they need to start and operate business, support them in the course of their business' launch, check the quality of their services, and do other things that franchisors typically do with respect to their franchise network.

We therefore mainly obtain and process two kinds of personal data of our (sub)franchisee' clients: (1) when they provide our (sub)franchisee with their personal data as well as with the personal data of their children or (2) when we receive additional data directly from our (sub)franchisee' client in certain limited cases. We also process limited personal data of representatives (agents, employees or otherwise) of our potential (sub)franchisees.

While we also process some personal data of representatives (agents, employees or otherwise) of our existing (sub)franchisees, such processing is out of scope of this policy. We request our (sub)franchisees to obtain the consent of respective data subjects for such processing and rely on it. If for whatever reason they did not receive your consent for us to process your personal data, please contact us immediately using contact details provided below.

This privacy policy explains how we collect, use, share and protect information in relation to our Services. Our Services, other than the Platform and contact forms of our websites, are not designed to target data subjects specifically. Even if any personal data processing of data subjects takes place, this happens inadvertently or incidentally.

We process personal data of EU data subjects in accordance with the General Data Protection Regulation (the "GDPR"), the GDPR-based legislation and the other applicable privacy legislation.

2. HOW TO CONTACT US

IN SHORT: You can find our contacts below. Our representative in a concrete country is the (sub)franchisee with whom you entered into service agreement. If in doubt, contact us at dpo@alg.academy

You may contact Algorithmics Global regarding data processing issues using the following contact details: dpo@alg.academy

You may contact Algoritmika Cyprus using the following contact details: ruffel.holdings@com

Pursuant to GDPR, Algorithmics has to appoint our representative in EU. Even though you can always contact Algoritmika Cyprus for any matters, we appoint our (sub)franchisees to be Algoritmika Group representatives in EU. In most cases this is the company with which you entered into a service agreement for provision of after-school programming classes to your child.

If in doubt as to our EU representative in your given case, please contact us at dpo@alg.academy

3. 1. WHAT INFORMATION WE COLLECT

IN SHORT: We collect personal data that you provide to us such as your and your child's name, age, country, contact information. We get some personal data when you and (or) your child use the services of our (sub)franchisee to the extent they enter this information into our platform. We also collect some information directly from you in a limited number of cases. Finally, we collect some personal data automatically.

(a) What data we collect

Data you disclose to us

When you contact with us with the purpose to discuss our after-school programming classes for children, we get access to the following personal data:

• your name
• your location (country and address)
• your contact phone number
• your contact e-mail address
• your age

When you contact with one of our (sub)franchisees, we get access to your and/or your child's personal data that they put into our Platform with respect to you and/or your child:

• your name
• your location (country and address)
• your contact phone number
• your contact e-mail address
• your date of birth and your age
• your passport details
• your legal basis for exercising parental rights with respect to your child
• your child's name
• your child's gender
• your child's age
• your child's contact phone number
• your child's contact e-mail address
• other information with respect to you and/or your child that our (sub)franchisees put into our Platform

Data we get when and (or) after you use the services provided to you by our (sub)franchisee

When you enter into agreement with one of our (sub)franchisees, we additionally get access to the following data that they put into our Platform with respect to you and/or your child:

• your child's individual progress with the services that our (sub)franchisee provides to you
• your and your child's preferred (sub)franchisee
• pages you or your child viewed
• the features you or your child use
• error reports
• links you or your child click on to leave or interact with our Platform
• other applications your child use on his or her device
• other information with respect to you and/or your child that our (sub)franchisees put into our Platform

After you enter into agreement with one of our (sub)franchisees, we may get in contact with you directly in a limited number of cases and receive the following data with respect to you and/or your child:

• your and your child's feedback with respect to Platform
• your and your child's feedback with respect to services that our (sub)franchisee provides or have provided to you, including your impression as to the quality of these services
• your and your child's feedback as to our (sub)franchisee compliance with our standards and policies

Data we get when you contact us on behalf of our potential (sub)franchisee

If you are a representative (agent, employee or otherwise) of our potential (sub)franchisee and you approach us with the purpose to discuss entering into franchise agreement, Algorithmics Global gets the following personal data with respect to you:

• your name
• your location (country)
• your position with our potential (sub)franchisee
• your contact phone number
• your contact e-mail address
• your age (if you are above 16 years old)

(a) What data we collect automatically

We also collect the following data:

• Internet Protocol (IP) address when you or your child log into the Services and respective log information and error messages
• browser type that you or your child use when you access our websites
• type of device (personal computer/notebook, mobile device), respective unique device identifiers, such as device Media Access Control (MAC) address, precise location data, device motion data, or both, if you or your child grant permission to do so in your device settings
• time of access to our websites

(b) What data we receive from cookies

We will also receive information from cookies. We have special policy for cookies and for your convenience we placed it on our web-site algorithmicschool.com

(c) What data we have to have

We noted above that we administer the Platform and therefore we get access to all information that our (sub)franchisee inputs in it. It is impossible to restrict us from getting access to this information. You should not enter into agreement with our (sub)franchisee if you don't want that we get access to your and your child's data.

You however may opt-out that we contact you directly albeit we don't recommend doing that because in this case we may not guarantee that you receive services satisfying all standards that we impose on our (sub)franchisees.