Fervent Digital OÜ (“Fervent”, “Fervent Digital”) is serious about protecting your online privacy. This Privacy Statement explains our views and practices concerning privacy, and how they may pertain to you as a user of our website. Fervent is the data controller for the processing of personal data in relation to the use of our website.
You or Your means you as a participant in or as a user of the fervent.eu website. We or Our or Us means Fervent Digital OÜ. Our site means fervent.eu.
SECTION 1 – INFORMATION WE MAY COLLECT
Our primary purpose in collecting information from or about you is to provide you with a safe, smooth, efficient, and customised experience. Depending on the manner in which you use our Services (e.g. Private Tuition, Consulting) or Products (Online courses, Learning Materials, etc), we collect information about you that we deem necessary for providing Services and Products that optimise, secure, and ease your user experience.
Personal Information or Personal Data: Fervent may collect and process information that could be directly or indirectly associated with you; information such as your full name, company name where applicable, username and password, phone number, email address, billing or mailing address, credit / debit card information (though this is neither seen nor stored by Fervent), and other information you share with Fervent (e.g. your specific learning requirements). You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Services or Products because such information may be required in order for you to register for an account; purchase Products or Services; participate in a contest, promotion, survey; provide feedback, continuous learning and improvement; ask a question; or initiate transactions on our website. In some cases, the nature of the service we offer (e.g. 1:1 Private Tuition) means we must take the time to learn about your individual requirements, failing which we will be unable to provide an optimal learning experience for you.
Non-Personal Information: Pixel tags (“Pixels”), e.g. Google Analytics, are electronic images that allow a website to access cookies and help track marketing campaigns and general usage patterns of visitors to those websites. Pixels can recognise certain types of information, such as cookie numbers, time and date of a page view, and a description of the page where the Pixels are placed. No Personal Information or Personal Data about you is shared with third parties through the use of Pixels on our website. However, through Pixels, we may collect general information that will not personally identify you, such as: Internet browser, operating system, date of visit, time of visit and path taken through the website. Fervent may also collect other Non-Personal Information as visitors browse our website, such as the web traffic, what pages are visited, and from where visitors come. We may compile this Non-Personal Information to enable statistical analysis of our Services and Products that would be used internally or with external assistance to make improvements to our website, Services, and Products.
General guidance on consent: When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only. If we ask for your personal information for a secondary reason (i.e. newsletter subscription and marketing messages), we will ask you directly for your expressed consent and provide you with an opportunity to withdraw your consent. You may withdraw your consent at any time by clicking on an “unsubscribe” link which is offered at the bottom of every email we send. You may also withdraw your consent anytime, by contacting us at [email protected] or mailing us at: Sepapaja tn 6, Lasnamäe district, Tallinn city, Harju county, 15551, Estonia.
SECTION 2 – HOW WE USE THE INFORMATION WE COLLECT
- Purpose of the processing: To provide you access to our Services and communicate with you regarding your learning experience and use of our Services.
Legal basis for the processing: Performance of contract.
- Purpose of the processing: To market and advertise our Products and Services, including making recommendations about courses and other Services you may be interested in, conducting market research, surveys, feedback, or competitions.
Legal basis for the processing: Balancing of interests where Fervent has pursued the legitimate interest of conducting marketing activities.
- Purpose of the processing: To prevent, detect, investigate and take measures against criminal activity, piracy, fraud, and misuse of or damage to our Services or Products and to take measures against other threats against Fervent’s or a third party’s rights.
Legal basis for the processing: Balancing of interests where Fervent has pursued the following legitimate interests:
- Fervent’s interest of investigating suspicion of and taking measures against misuse of or damage to our Services or Products;
- Fervent’s and/or third party’s interest of investigating and producing evidence regarding criminal activity, piracy, fraud and other threats against its interest;
- Competent authority’s interest of conducting law enforcement activities and collecting evidence for such purposes.
- Purpose of the processing: To comply with applicable laws, regulations, court orders, government and law enforcement agencies’ requests.
Legal basis for the processing: Compliance with a legal obligation to which Fervent is subject.
SECTION 3 – DISCLOSURE OF YOUR PERSONAL INFORMATION OR PERSONAL DATA
Fervent will never sell your Personal Information or Personal Data. Period.
For the provision of our Products and Services, we may disclose your information, which in some cases includes Personal Information or Personal Data, in the following situations:
- With our authorised service providers. Fervent may share your Personal Information or Personal Data with our authorised service providers that perform certain services and process Personal Information or Personal Data on our behalf. These services may include providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, competitions, surveys, feedback, and other features offered through our website or by Fervent. These service providers may have access to Personal Information or Personal Data needed to perform their functions but are not permitted to share or use such information for any other purposes.
- With our business partners. When you make purchases, reservations or engage in promotions offered through our website, we may share Personal Information or Personal Data with the businesses with which we partner to offer you those Products, Services, promotions, contests and/or competitions. For example, our course is currently hosted on Teachable. Buying a course from us means that Teachable will have access to your name and email address, as well as your credit / debit card information when you purchase the course via Teachable’s secure 128-bit SSL encrypted payment gateway.
- In connection with a substantial corporate transaction, such as the sale of our business; a divestiture, merger, consolidation, or asset sale; or in the event of bankruptcy. If another company acquires Fervent, that company will take on all responsibility for the information we collect, including Personal Information or Personal Data, and it will assume all rights and obligations with respect to that information. Should this happen, the acquiring company may implement its own policies with respect to your information.
Fervent may also use and share Non-Personal Information we collect with third parties to develop and deliver targeted advertising on our website or applications of third parties, and to analyse and report on advertising you see. We may combine Non-Personal Information we collect with additional Non-Personal Information collected from other sources. We also may share aggregated, non-personal information with third parties, including advisors, advertisers and investors. For example, we may engage a third party acting on our behalf to collect web log data from you (including IP address and information about your browser or operating system) when you use our website and other websites you may access during your Internet browsing session, or place or recognise a unique cookie on your browser to enable you to receive customised advertisements or content. For more information regarding your choices about how third parties collect information about you on our website see the section titled Do-Not-Track Procedures below.
Please keep in mind that all of the information that you disclose or content that you post in your user profile, forum posts, comments, or other public portions of our website becomes public information. Because this information is publicly available, we cannot control how others treat it so we ask all Users to exercise care in deciding what information they chose to share.
SECTION 4 – DATA RETENTION
We will save your Personal Information or Personal Data until you erase, delete your account, or otherwise exercise your right to erase your Personal Information or Personal Data.
SECTION 5 – ACCESS TO YOUR INFORMATION AND OTHER RIGHTS
You are, at any time and free of charge, entitled to receive a copy of the Personal Information or Personal Data that we hold about you and information about the processing thereof. Please note that Fervent needs to be able to determine your identity in order to be able to respond to your request.
If you believe that any Personal Information or Personal Data we are holding is incorrect or incomplete please send an email with your specific request to [email protected] We will work with you to make any corrections deemed necessary. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
You have the right to request that Fervent restricts the processing of your Personal Information or Personal Data under certain conditions. For example, if you contest the accuracy of the Personal Information or Personal Data, the processing may be restricted for a period enabling Fervent to verify the accuracy of the Personal Information or Personal Data or if Fervent no longer needs the Personal Information or Personal Data for the purposes of the processing but you require the Personal Information or Personal Data for the establishment, exercise, or defense of legal claims.
You have the right to have your Personal Information or Personal Data deleted without undue delay and Fervent is obliged to delete your Personal Information or Personal Data without undue delay if, for example, the Personal Information or Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed. Please note that Fervent is not obliged to delete the Personal Information or Personal Data if Fervent can show that the processing is necessary, for example, for the establishment, exercise, or defense of a legal claim.
If you provide your email address to Fervent, you will always have the opportunity to opt out of receiving email newsletters and promotions through the unsubscribe link in the email communications or by logging into and changing the preferences for your user account. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party (such as a credit card processing partner, e.g. PayPal) before you changed your preferences or updated your information, you may have to change your preferences directly with that third party.
You have the right to object, on grounds relating to your particular situation, at any time to Fervent’s processing of your Personal Information or Personal Data if the processing is based on, for example, legitimate interests. If you object to such processing, Fervent will no longer be entitled to process your Personal Information or Personal Data based on such legal basis, unless Fervent can demonstrate compelling legitimate grounds for the processing which overrides your interests, rights, and freedom or if it is conducted for the establishment, exercise, or defense of a legal claim.
You have, under certain conditions, the right to receive the Personal Information or Personal Data concerning you and which you have provided to Fervent, in a structured, commonly used and machine-readable format and have the right to transmit such Personal Information or Personal Data to another data controller without Fervent trying to prevent this, where Fervent’s processing of your Personal Information or Personal Data is based on a contract or consent and the processing is carried out by automated means. In such case you have the right to request that the Personal Information or Personal Data shall be transmitted from Fervent directly to another data controller, where technically feasible.
You also have the right to withdraw your consent, if applicable. If you withdraw your consent, please note that this does not affect the lawfulness of the processing based on your consent before its withdrawal and that Fervent may, under certain circumstances, have another legal ground for the processing and therefore may be entitled to continue the processing.
If you are unhappy with our processing of your Personal Information or Personal Data or of an alleged infringement of the General Data Protection Regulation or other applicable data privacy laws, you may lodge a complaint with a competent supervisory authority, for example in the country of your habitual residence, place of work.
SECTION 6 – OUR POLICY CONCERNING CHILDREN AND AGE OF CONSENT
SECTION 7 – SECURING YOUR INFORMATION
Fervent takes a range of security measures designed to protect your Personal Information or Personal Data and keep it confidential (unless it is non-confidential by nature) and free from any unauthorised alteration. For example, only authorised employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use the most reputed companies to manage and process financial information, ensuring you only pay on secure payment gateways. Additionally, we use firewalls to help prevent unauthorised persons from gaining access to your personal information.
Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. As the safety and security of your information also depends on the precautions you take, we ask you not to share your password with anyone.
Our shopping cart solution is hosted and managed by WooCommerce. They provide us with the online e-commerce platform that allows us to sell some of our products and services to you. Your data relating to purchases made via WooCommerce is stored through WooCommerce’s data storage, databases and the general WooCommerce application. They store your data on a secure server behind a firewall.
SECTION 8 – THIRD PARTIES AND OTHER INFORMATION COLLECTORS
SECTION 9 – DO-NOT-TRACK PROCEDURES
Note that any Do-Not-Track instructions from your browser or similar mechanism will not affect our collection of the data that you voluntarily provide to Fervent through such means as browsing our website, signing up for any of the Services, Courses, or any Products entering Personal Information or Personal Data into information fields on our website, or posting on any of our forums or blogs. Be advised that third parties are free to collect any information that you volunteer to Fervent that is visible to the public. Therefore, please do not provide Fervent with any information that you do not want collected.
SECTION 10 – TRANSFER OF PERSONAL INFORMATION TO COUNTRIES OUTSIDE THE EU / EEA
Fervent is incorporated in Estonia. Your data is, for the most part, held inside the European Union. Some transfers outside the EU are necessary, however.
Your Personal Information or Personal Data is transferred to and processed by third party payment providers (such as Paypal, Teachable) and your bank. Such transfers are necessary for performance of the contract between you and Fervent (article 49.1 (b) of the GDPR).
SECTION 11 – NO RIGHTS OF THIRD PARTIES
QUESTIONS AND CONTACT INFORMATION
Fervent Digital OÜ,
Sepapaja tn 6, Lasnamäe district,
Tallinn city, Harju county,
Email: [email protected]