Effective date: May 10, 2021
Felser Ltd. ("us", "we", or "our") operates the https://www.pagsprofile.com website (hereinafter referred to as the "Service").
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
Using the Service, you as a User will be asked to confirm your understanding of and - where appropriate – consent to this policy and the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from http://www.pagsprofile.com.
Service
Service is the https://www.pagsprofile.com website operated by Felser Ltd.
Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small files stored on your device (computer or mobile device).
Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors
Data Processor means any natural or legal person who processes the data on behalf of the Data Controller.
Sub-Processors (or Service Providers)
We may use the services of various Service Providers in order to process your data more effectively.
1.1 Client: any organisation, enterprise or any living individual that is subscribing to the Service (and their contact persons). In other words, the school, teacher, professional, parent or legal guardian that is purchasing the Subscription to the Service.
1.2 User: is any living individual who is using our Service and is the subject of Personal Data.
1.3 Assessee: Data Subject is any living individual for who the Service is being used for and is the subject of Personal Data.
2.1 Every school, teacher, professional, parent or legal guardian (our ‘client’ or ‘clients’) strives for a psychosocial analysis tool that achieves the best personalised learning trajectory for their child to succeed.
PAGS is the psychosocial analysis tool of choice to achieve efficient communication, interaction and analysis, while ensuring that the ultimate management of the application remains with the Client.
2.2 Since the management remains with the Client, the GDPR designates the Client as the data controller. Consequently, the Client must comply with all obligations under the GDPR (Regulation (EU) 2016/679 of 27 April 2016). For example, the Client will adequately inform the Data subject about their personal data processed, the processing operations it performs or instructs and of course their rights as a Data subject and person whose personal data is processed.
2.3 PAGS processes the personal data purely on behalf of the Client. PAGS is merely a data processor that ensures the proper technical functioning of PAGS. In doing so, PAGS may in turn, to a limited extent, engage third parties to assist it in doing so.
We collect several different types of information for various purposes to provide and improve our Service to you.
While using our Service, certain personally identifiable information is processed that can be used to contact or identify you ("Personal Data"). Such personally identifiable information may include, but is not limited to:
Administrative data (e.g., name, address, email address, phone number, login credentials, etc.)
Medical Data (limited to disabilities and notes)
Behavioural data (knowledge, performance, skill data in behavioural field)
Cognitive data (knowledge, performance, skills data in the cognitive field)
Developmental progression metrics
Usage Data
Cookies
3.2.1 In order to provide and maintain our Service, we may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
3.3.1 We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
3.3.2 Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
3.3.3 You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
Felser Ltd. processes the collected data upon instruction from the Client for the following purposes:
To provide and maintain our Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Service
To monitor the usage of our Service
To detect, prevent and address technical issues
5.1 At the time of enrolment or onboarding, the Client informed you about the processing of your personal data in the context of your treatment and counselling through the use of the Service.
5.2 The Client processes your data primarily on the following grounds:
The performance of a contract with you
You have given permission to do so
The processing is in the Client’s legitimate interests and it is not overridden by your rights
For payment processing purposes
To comply with the law
The provision of health or social care or treatment
5.3 Through use of the Service, you confirm this legal basis.
6.1 Felser Ltd. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
6.2 Felser Ltd. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
6.3 Felser Ltd. will retain your Usage and Personal data for research purposes within the terms of a separate research agreement if applicable.
7.1 Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
7.2 If you are located outside The Netherlands and choose to provide information to us, please note that we transfer the data, including Personal Data, to The Netherlands and process it there.
7.3 Your acknowledgment of this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
7.4 Felser Ltd. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
If Felser Ltd. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, Felser Ltd. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Felser Ltd. may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of Felser Ltd.
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability
9.1 The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
10.1 If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Felser Ltd. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
10.2 If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
10.3 In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Felser Ltd. relied on your consent to process your personal information.
10.4 You may exercise these rights at any time by sending us an email to info@pagsprofile.com or by writing to Felser Ltd., 8 Becquerel Court, West Parkside, London, SE10 0QQ and provided that you comply with our reasonable requests to verify your identity.
10.5 Such requests will be forwarded by us to the Client, which will handle your request as the controller.
10.6 You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
11.1.1 We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
11.1.2 We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
11.1.3 The payment processors we work with are:
PayPal / Braintree
Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
Stripe
Their policy can be viewed at https://stripe.com/en-gb-be/privacy
GoCardless for Xero
Their policy can be viewed at https://gocardless.com/privacy
Xero as an invoicing system
Their policy can be viewed at https://www.xero.com/about/legal/privacy/
12.1 Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
12.2 We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
13.1 Users must keep a signed parental consent for anyone under the age of 18 that https://pagsprofile.com is being used for/upon. User must provide these consent forms within 24 hours after Felser Ltd. request to do so.
13.2 If you are a legal guardian and you know or suspect that we unlawfully store data of your Child, please contact us immediately by email info@pagsprofile.com If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
14.1 We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
14.2 We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
14.3 You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy, please contact us: