سياسة الخصوصية

LAST UPDATED: April 04, 2022

This statement (“Privacy Policy”) explains what we do with students’ personal data which we receive through the educational services (the, “Services”), provided by OTrain and how students enrolled on a course provided by OTrain can exercise their rights over it.

Who we are and how to contact us

We are OTrain is a commercial-profit Limited Liability Company and it is wholly owned by Queen Rania Foundation for Education and Development of 61 Al-Sherif Naser Ben Jamil Street, Amman, Jordan (“OTrain”). References to “we”, “our” or “us” means OTrain. We offer an open online learning platform to students looking to advance their education via a platform known as, “OTrain”. We are the controller of your data. This means that we are responsible for deciding how we collect, store and use personal information about you. We may from time to time engage third parties to process your information and we may also process your information ourselves (as described further below).

If you have any questions or concerns about the information in this Privacy Policy, or about our handling of personal data more generally, or if you would like more detailed information, you should email us at [info@otrain.com.jo] or write to us at [61 Al-Sherif Naser Ben Jamil Street, Amman, Jordan] for the attention of “Privacy Officer”.

The information we collect about you and why we collect it

By registering an account on OTrain and in turn using our Services, we will collect from you the following information (“Personal Data”):

  • Your name
  • Your email address
  • Your year of birth
  • Highest education level achieved
  • Gender
  • Country of residence/origin
  • Phone numbers (Teachers)
  • Social media accounts (If you login/register using social media, namely Facebook or Google)
  • Records of your visits to OTrain and engagement with educational content such as pages, videos, assessments, and posts, comments, and any other interactions you perform on course discussion forums
  • Details of grades scored on assessments you take on OTrain 
  • Online footage of interactions you performed in online lecture videos, called “pause and seek events”
  • Records of creation of virtual classrooms by teachers on OTrain 
  • Information you add to child accounts you create for your children on OTrain through the parents’ section on the dashboard page

If you are a parent or a guardian creating an account for your child,

the following child (“Personal Data”) will be collected:

  • The child’s name
  • The child’s gender (optional)
  • The child’s academic grade
  • The country whose curricula you want the child’s programs to follow

OTrain will never share externally a child’s Personal Data, or any linkage between child and parent data.

Our legal basis for using your Personal Data

Where we use your Personal Data, we process it on the following bases:

  • Performance of a contract to which you as a data subject are a party (including in connection with the retention of records detailing your learning progress and performance for the purpose of saving your course progress and certificates); and
  • For the legitimate interest of OTrain carrying out the following activities:
    • Internal research purposes, for example the improvement of course design and operation;
    • The following research and marketing purposes (unless you decide to opt-out when registering or subsequently):
      1. Internal research in connection with how the OTrain platform is used; and
      2. For the purpose of sending you updates in respect of online courses offered by OTrain;
    • Improving the platform user experience of OTrain; and
    • The publication of scientific papers in journals or conferences. No data that identifies you are ever shared in a scientific publication. We only publish aggregated or anonymized data.

We will never collect any unnecessary Personal Data from you and do not process your information in any way, other than as specified in this Policy.

We make every effort to maintain the accuracy and completeness of your Personal Data, which we store, and to ensure all of your Personal Data is up to date. However, you can assist us with this by promptly contacting us if there are any changes to your Personal Data. We shall not be responsible for any losses you suffer arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

How long we will keep your Personal Data

For EU users and users in other countries with data protection legislations that require personal user data to be deleted after some time, your account data will be deleted automatically after 7 years of inactivity. Inactivity is defined as the absence of interaction with course content. Following 7 years of inactivity, we will contact you with a 1 month prior notice, informing you that your Personal Data will be deleted from the computers on which it is stored, and giving you the option to request your Personal Data is retained for another 7 years.

For users in all other countries, your account data will be saved by OTrain until you submit a request for us to delete your data through the Website, after which your data will be deleted according to the timeline provided by the Website when you request the deletion.

OTrain may shorten the retention period for your Personal Data depending on the amount, nature, and sensitivity of your Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Who we share your Personal Data with

We may from time to time share your Personal Data with the following parties for the purpose of improving course content, and improving marketing operations:

  • The internal course management team;
  • The internal marketing team; and
  • The internal leadership team.
  • Third parties we partner with for the purposes of course creation, operation, or evaluation (including instructors, teaching assistants, and personnel from organizations that partner with OTrain for the purpose of a course you are enrolled in) and marketing agencies we partner with for OTrain’s specific marketing needs. All third parties who receive personal data from OTrain sign a data processing agreement with OTrain that mandates they use your Personal Data only for the purposes for which OTrain contracted them and in accordance with GDPR or any other applicable data regulations, and that the third party deletes your personal data within 10 days of the termination or completion of the contract.

We may also from time to time share your Personal Data (in an anonymised form) with external educational researchers for the purpose of conducting educational research.

Transfer of your Personal Data to other countries

We only transfer your Personal Data outside the EEA where we have a legal basis for doing so and where we require that your personal information is protected to the same standard as it would be protected in the EEA. We do this by entering into data sharing agreements with the recipients of your Personal Data based outside the EEA which comply with the EU Commission’s standard clauses for the transfer of personal information.

If you would like further details about our transfer of your personal information outside the EEA or details of the safeguards put in place in relation to your personal information please contact the “Privacy Officer” at OTrain.

Use of your Personal Data for automated decision-making

We do not make any automated decisions using this information.

Changes to this policy

Except to the extent limited by applicable law, we reserve the right to update this policy to reflect changes to our information practices by prominently posting notice of the update on our Services, and as required, obtaining your consent. Any updates will become effective immediately after posting the updates to this policy and apply to all information collected about you, or where required, upon your consent. You agree that you will review this policy periodically. If we make any changes to this policy, we will change the “Last Updated” date above.

Your rights and how to exercise them

European and UK privacy laws give you certain rights in respect of the data that we hold about you. Below is a short overview of those rights.

  • With some exceptions, you have the right to have a copy of the Personal Data that we hold about you. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs. Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish.
  • You have the right to have the Personal Data we hold about you corrected if it is factually inaccurate.
  • In some circumstances, you have the right to have Personal Data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, if we are obliged to do so by law).
  • You have the right to require us to stop using your Personal Data for marketing purposes.
  • You also have the right in some circumstances to request that temporary restrictions are placed on how we process your Personal Data, For example if we are processing it on the basis of our legitimate interest, and you contest to our assessment that our interest is not overridden by your fundamental rights and freedoms.
  • If we are processing your Personal Data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue. In some cases, the only way for OTrain to stop that processing would be through terminating your accounts. OTrain will request your confirmation before terminating your account, through the email address through which you request to withdraw your consent. If you do not provide written confirmation within 21 days for OTrain  to terminate your account, your request to withdraw your consent will be considered canceled.

In order to protect you and others, we may require you to prove your identity before you exercise these rights.

If you are unhappy with how we have handled your Personal Data, you have the right to complain to your local data protection authority.