Privacy Policy

(terms of personal data processing)

Last updated: 19.06.2024

This Privacy Policy explains what personal data is collected when you visit the website located at (hereinafter – the “Website”), the services and products provided through it, how such personal data will be processed by the controller of these personal data – expla company (hereinafter – the Company and/or expla and/or we).

BY USING THE WEBSITE, YOU UNDOUBTEDLY PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND, AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree or are unable to make this promise, you must not use the Website. In such case, you must immediately (i) contact us and request deletion of your personal data; (b) leave the Website and not access or use it in any way.

By visiting the Website, you accept our Privacy Policy, and you allow expla to collect, use, and disclose personal data about you for the purposes listed below.

We may change this Privacy Policy from time to time. If we make any changes, we will notify you by updating the date at the top of this Privacy Policy. We encourage you to review the Privacy Policy when you access the Website to stay informed about our information practices and ways you can help protect your privacy.

Additional conditions for processing personal data when applying for the “Careers” section and any educational initiatives by the company expla.

1) By sending us your name, phone number, e-mail address, CV, and cover letter in the “Career” section, you additionally give your consent to the processing of such personal data and documents by us for the purpose of conducting the process of selecting candidates for the corresponding open Vacancy.

2) By filling in the appropriate fields in Google forms or in any other way provided by us when registering for our online and/or offline events, workshops (hereinafter – Events), you provide us with certain data, including an email address to send to you materials and other commercial letters. You agree that during our online/offline Events we may take photos and/or video and use these photos and/or videos on our Website and social media pages.

1. Terms

«GDPR» means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

«EEA» includes all current member states of the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.

«Processing» in respect of personal data includes collecting, storing, and disclosing to others.

2. Personal data controller

The company expla is the controller of your personal data.

3. Categories of personal data we collect

We collect personal data that you provide to us voluntarily by filling out the appropriate contact form on the Website (for example, name and email address) and by sending us your name, phone number, email address, CV and cover letter in the “Career” section. We also automatically collect data (such as cookies, your IP address, information about your interaction with the Website, technical information about your device, etc.).

3.1. Data you voluntarily give us

We process personal data that you provide to us voluntarily by filling out the appropriate contact form on the Website (for example, name and email address) and by sending us your name, telephone number, email address, CV and cover letter in the “Career” section.

3.2. Data we collect automatically:

  • Data about how you found us

We collect data about your referring app or URL (that is, the app or place on the Internet where you were when you tapped/clicked on our ad).

  • Device and location data

We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID.

  • Usage data

We record how you interact with our Website. For example, we log what pages you have viewed, the features and content you interact with, how often you use the Website, how long you are on the Website

  • Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Website. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.

Cookies are used, in particular, to automatically recognize you the next time you visit our website. As a result, the information, which you have earlier entered in certain fields on the website may automatically appear the next time when you use our Website. Cookie data will be stored on your device and most of the times only for a limited time period.

4. The purpose of processing your personal data

We process your personal data:

4.1. To provide our services

This includes enabling you to use the Website in a seamless manner and preventing or addressing Website errors or technical issues

4.2. To provide you with customer support

We process your personal data to respond to your requests for technical support, service information or any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about the performance of our Website, security, notices regarding our Terms and Conditions of Use, or this Privacy Policy.

4.3. To research and analyze your use of the Website

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Website. We also use such data for statistical analysis purposes. This enables us to better understand what categories of users use our Website. As a consequence, we often decide how to improve the Website based on the results obtained from this processing

4.4. To send you marketing communications

We process your personal data for our marketing campaigns. As a result, you will receive news about our company, educational and other Events, our vacancies, information about our products, or new features available on the Website. We may send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe by following the instructions in the footer of the marketing emails.

4.5. To enforce our Terms and Conditions of Use and to prevent and combat fraud

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your personal data with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).

4.6. To comply with legal obligations

We may process, use, or share your personal data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

5. Legal basis for processing your personal data

In this chapter, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Chapter 3. This section applies only to EEA-based users.

We process your personal data under the following legal bases:

5.1. to perform our contract with you;

According to this legal basis, we:

  • Provide our services (in accordance with our Terms and Conditions of Use);
  • Customize your experience of using the Website;
  • Provide you with customer support;
  • Communicate with you regarding your use of our Website.

5.2. for our (or others) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;

We rely on legitimate interests:

  • to research and analyze your use of the Website

Our legitimate interest for this purpose is our interest in improving our Website so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website easier and more enjoyable or to introduce and test new features).

  • to send you marketing communications

The legitimate interest we rely on for this processing is our interest to promote our Website in a measured and appropriate way.

  • to enforce our Terms and Conditions of Use and to prevent and combat fraud

Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Website, and non-compliance with our Terms and Conditions of Use.

5.3. to comply with legal obligations.

6. With whom we may share your personal data

We may share your personal data with third parties that help us operate, provide, improve, integrate, customize, support, and market our Website. We may share some sets of personal data, in particular, for purposes and with parties indicated in Chapter 3 of this Privacy Policy. The types of third parties we may share personal data with include, in particular:

6.1. Service providers

We may share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

  • cloud storage providers;
  • data analytics providers;
  • communication service providers;
  • marketing partners (in particular, social media networks, and marketing agencies).

6.2. Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, confidentiality, safety, or property, and/or that of our affiliates, you, or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

6.3. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Personal data is generally one of the transferred business assets in these types of transactions. We may also share such personal data with any affiliated entity (for example, parent company or subsidiary) and may transfer such personal data in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

7. Rights of personal data subjects

The subject of personal data has the following list of rights:

  • Accessing, reviewing, updating, correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website.
  • Deleting your personal data. You can request erasure of your personal data as permitted by law.

When you request the deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such an event, we will fulfill your request after we have complied with our obligations.

  • Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.

If you are based in the EEA, you have the following rights in addition to the above:

  • The right to file a complaint with a supervisory authority. You have the right to file a complaint with the competent supervisory authority for the protection of personal data, in particular in the EU member state where you live, work or where the alleged violation occurred. However, we really want you to contact us directly before such an appeal.
  • The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to us as described below.

To exercise any of the above rights, please send your request to [email protected].

8. Age limitation

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.

9. International personal data transfers

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the services set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

10. Security

The Company takes reasonable measures to protect your personal data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

11. Storage of personal data

We will store and use personal data for as long as necessary to provide quality services and for as long as such use is deemed appropriate by the Company.

12. Contact us

You may contact us with any questions regarding this Privacy Policy at any time by e-mailing [email protected].

By filling out the contact form or sending your CV to the Website, you automatically agree to receive informational or promotional mailings from the Company and/or its partners.