Privacy Policy

With this information, PhiAcademy d.o.o. Beograd-Voždovac, with all affiliated and/or contracted legal entities as listed in this document under item 3. hereunder (hereinafter: PhiAcademy, Controller or We), informs you about the processing of your Personal Data (hereinafter: Data) as well as your data protection claims and rights in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Serbian Personal Data Protection Act, in regard to the following:  

1. What Data Is Being Processed and Where Are They Sourced From?

We process the Data that we receive from you when you visit our website at www.phi-academy.com and the Data we receive from you when you use the services provided on our website www.phi-academy.com (hereinafter: Website or our Services) and/or the Data you provide us as a potential student of a PhiAcademy course.

We receive your Data from the following sources:

· From you: When you visit the Website and when you use our Services, we receive data directly from you.

If you are a Master or a Grand Master (hereinafter: Master), we receive your Data for PhiMap from the following sources:

· PhiAcademy GmbH: Our affiliate company PhiAcademy GmbH, Vienna, Austria, Wiegelestraße 10, 1230 Wien, Austria, processes the Master’s Data in its database in order to perform (execute) concluded contracts. With PhiMap, all Masters’ Data are processed at the same time. This provides the Website user with easier access to a particular Master’s Data such as the Service(s) they provide as well as their contact details. For this purpose, Master’s Data are transmitted based on your consent as well as Appendix 3 of your Master Agreement with PhiAcademy GmbH, to facilitate the fulfillment of marketing purposes from PhiAcademy GmbH to PhiAcademy d.o.o.

· From you: When you enter into a contractual relationship with a Master. 

If you are a Student, we receive your Data required for PhiMap from the following sources: 

· Your Master: If you successfully complete a course with a Master, the Master provides us with your Data. With the PhiMap all your Data are processed at the same time. This provides the Website user with easier access to the Service(s) you provide as well as your contact details. For this purpose, your Data are transmitted based on your consent and in the interest of our group, to fulfill all marketing objectives from those of the Master to PhiAcademy d.o.o.’s objectives. 

· From you: When you receive an invitation e-mail from PhiCert, and you enter your details to create a PhiCert profile, you have the option to provide your consent to appear on the PhiMap. A separate Privacy Policy is available at our PhiCert website.

We do not collect or process any special categories of Personal Data. 

2. Why Are Data Processed?

We process your Data in accordance with applicable data protection law and for specific purposes and for a specific period. The most important purposes, duration and legal basis of processing are listed below. If we collect Data from you for other purposes, we will inform you separately before collecting such Data. If you are obliged to provide Data for the respective purpose, these fields are marked with an asterisk (*). Data that is not obligatory, that is, fields which are for optional Data are not marked with an asterisk (*).

2.1. Contact Form 

Data:                   name*, e-mail address*, message (inquiry or request) *.

Purpose:             We process Data you provide when you contact us via the “Contact us directly’’ form in order to respond to your inquiry or to fulfill your request.

Legal Basis:        We process this Data based on your consent. You can withdraw your consent anytime by e-mail to: info@phiacademy.com. 

Duration:           We process the Data you provide only for the amount of time it takes to respond to your inquiries or to fulfill your requests. This duration may not exceed 15 days from the date the inquiry was made.

2.2. Newsletter

Data:                   e-mail address*.

Purpose:             We process the Data you provide when you sign up for the PhiAcademy Newsletter on our Website for the purposes of direct marketing. We will send you newsletters via e-mail and inform you about offers, services and events of PhiAcademy and our affiliate companies (e.g., PhiAcademy GmbH, Austria and CraftMaster GmbH, Austria and other entities and services we have listed in this Policy).

Legal Basis:        We process this Data based on your consent. You can withdraw your consent anytime by e-mail to: info@phiacademy.com or by clicking on the unsubscribe link provided in every Newsletter mail.

Duration:           As long as you do not withdraw your consent. In the event of withdrawal, all Data (including backups) are deleted within 7 days following withdrawal of consent.

2.3. Marketing

Data:                   name*, e-mail address*, phone number.

Purpose:             We process your Data for the purpose of direct marketing and social media marketing for offers, services and events of PhiAcademy and its affiliates (e.g., PhiAcademy GmbH and CraftMaster GmbH and other entities and services we have listed in this Policy). We may combine Data we or our providers have collected with Data collected by our affiliates to gain a more detailed picture of the needs and interests of our users. Also, your Data (buyers’, followers’ and students’ Data) may be processed to create and execute unified marketing campaigns and analytics thereof for both the Controller and PhiAcademy GmbH, and the analytics pertaining to the Phi brand in a unified manner. In this way, we can provide better service to our customers as well as keep track of our Masters' activities related to the Phi brand.

Legal Basis:        We process the abovementioned Data on the basis of your consent. You can withdraw your consent anytime by e-mail to: info@phiacademy.com.

Duration:           Your Data will be processed until you withdraw consent, after which we will delete your Data immediately i.e., as soon as technically possible after receiving withdrawal.

2.4. Unified Marketing and Analytics

Data:                   Account Information (identification data (name, login), contact information (business e-mail address), work related information (job title or role, social information (social contact handling data), and usage information (performance data, device data, and location data)), Inbound Content (Personal Data published or sent by third parties, (e.g., social media users), including the Controller’s social media profiles, and publicly accessible data from social media networks or other websites used for social and content management and research capabilities e.g., user IDs, social network profile names and information, social network communications (both public and private messages to the Controller), information shared across social media networks and other websites, such as comments, reviews, reactions, and engagement), Customer Care Data (Personal Data submitted by the Controller’s customers, followers, fans, and other individuals to the Controller for purposes of customer care and support (including, where applicable under the relevant Order Form, voice data) and customer content.

Purpose:             Creating and executing unified marketing campaigns and analytics thereof, and the analytics surrounding the Phi brand, in a unified manner. In this way, we can provide better service to our customers as well as keep track of our Masters' activities related to the Phi brand.

Legal Basis:        We process this Data based on your consent. You can withdraw your consent anytime by e-mail to: info@phiacademy.com.

Duration:           Your Data will be processed until you are no longer affiliated with the Phi brand as a Master, employee, contractor or in any other way, or until you unfollow our social media platforms.

2.5. PhiMap (Data Collected Via the PhiCert App)

Data:                   name*, your PhiAcademy title(s) , street name and number, city and country of residence, e-mail address*, phone number*, your photo, company name, Facebook and Instagram account.

Purpose:             We process your Data for the purpose of direct marketing for your service(s) in accordance with the course(s) which you successfully completed at PhiAcademy. Namely, PhiMap is intended to offer users data regarding your Service(s) and contact details as an easily accessible source of information at any time. Since PhiAcademy and its affiliates operate worldwide and have a large and diversified organizational structure, it is of particular interest to be able to track in PhiMap whether a person has actually successfully completed a PhiAcademy course. In this way, any misuse of the protected trademarks and the good name of PhiAcademy should be detected early and prevented to the greatest possible extent.

Legal Basis:        We process the abovementioned Data on the basis of your consent.

Duration:           Your Data will be processed until you withdraw consent, after which we will delete your Data immediately i.e., as soon as technically possible after receiving the request for withdrawal.

2.6. PhiAcademy (Freshworks Customer Care) Chat

Data:                  name*, e-mail address*, message (issue or request) *, phone number.

Purpose:            When you contact our PhiAcademy Chat to submit requests or inquiries regarding our courses, and therefore provide us with your Data, such Data will be processes to respond to your requests or inquiries regarding our courses.

Legal Basis:        We process the abovementioned Data on the basis of your consent. You may withdraw consent for using Data for marketing purposes anytime by sending an e-mail to: info@phiacademy.com. 

Duration:           Your Data will be processed until you withdraw consent, after which we will delete your Data immediately i.e., as soon as technically possible after receiving the request for withdrawal.

2.7. PhiAcademy Call Support

Data:                   name*, e-mail address*, phone number, message or questions and answers related to PhiAcademy, PhiAademy courses and PhiAademy Masters.

Purpose:             PhiAcademy Call Support is intended to offer users data regarding our course(s) via live calls when we call you, and for direct marketing purposes.

Legal Basis:        We process the Data based on your consent. You can withdraw consent to using Data for marketing purposes anytime by sending an e-mail to: info@phiacademy.com. 

Duration:           Your Data will be processed until you withdraw consent, after which we will delete your Data immediately i.e., as soon as technically possible after receiving the request for withdrawal.

2.8. Book Your Place

Data:                  name*, e-mail address*, city, country, phone number*, message or request or questions related to PhiAcademy, PhiAcademy courses and PhiAcademy Masters.

Purpose:             “Book your place” is intended to offer users direct contact to the Master whose course they are most interested in attending. By submitting the Data, you agree that the Data will be submitted to the Master of your choice and to PhiAcademy. We will also use this Data for our internal administrative purposes.

Legal Basis:        We process the Data based on your consent. You can withdraw consent to using Data for marketing purposes anytime by sending an e-mail to: info@phiacademy.com. 

Duration:           Your Data will be processed until you withdraw consent, after which we will delete your Data immediately i.e., as soon as technically possible after receiving the request for withdrawal.

2.9. PhiScholarship

Data:                  name*, e-mail address*, street name and number, city and country of residence*, Instagram account*, education*, knowledge of English*, social media link*, professional or employment-related information*.

Purpose: We process your Data to verify whether you meet the requirements for the use of the following Service: PhiScholarship and for the purpose of managing our contractual relationship and to provide the PhiScholarship Service to you.

Legal Basis: We process this Data based on your consent and on the basis of our legitimate interests or based on the legitimate interests of third parties, in order to process your completed forms and be able to provide our Service, execute the contract and for direct marketing. You may withdraw consent to using Data for marketing purposes at any time by e-mail to: info@phiacademy.com.

Duration: Your Data will be processed until you object to such processing. Once an objection has been raised, we will delete your Data.

Beyond all of the above-mentioned, we process your Data only as long as there is a legal obligation to do so or we require the Data for the exercise or defence of legal claims.

3. Who Receives Your Data?

Within PhiAcademy and our affiliate companies PhiAcademy GmbH and CraftMaster GmbH, employees who need such Data for the purposes outlined above will receive your Data. If we are legally obliged to do so, we will also transfer your Data to public authorized bodies. In addition, companies commissioned by us (in particular IT and back-office providers) will receive your Data if they require such Data to fulfill their respective tasks. These providers are obliged to treat all Data confidentially, to process such Data only to the extent necessary to provide their services and they provide their processing activities within the European Economic Area.

We will transfer your Data to the following recipients:

PhiAcademy d.o.o. and its affiliates, if and where required, has separate and individual Service Agreements, where additional confidentiality and privacy defenses are agreed to between the parties.

Mechanisms for safeguarding transfer to countries outside the EU, such as the UK and Serbia. Transfer to the UK is based on an EU-adequacy decision, whereas transfer to Serbia is based on EU SCCs.

4. Are You Obliged to Provide Data?

To receive a message or newsletter - it is necessary that you provide the Data we need to perform our voluntary services. Those Data are marked with an asterisk (*) as obligatory. Generally, we are unable to offer our Services if such obligatory Data are not provided.

5. Cookies

5.1 Technically Required Cookies

We use cookies on our Website , which are small files stored on your device (web browser). On your next visit to our Website using the same device, the information stored in cookies will subsequently be returned to our Website. We use the Data collected through these cookies to better represent our Website and to make our offers user-friendly, for example, to evaluate the use of our Website. Some cookies remain stored on your device until you delete them. They allow us to recognize your browser on your next visit. Other cookies are only stored on our Website for the duration of your visit.

The following cookie is used:

This cookie is technically necessary for the presentation of the Website. You can deactivate the cookie setting in the settings of your browser. Please note that a general deactivation of cookies may possibly lead to functional limitations of our Website.

5.2 Cookies for Marketing and Advertising Purposes

5.3 Analytical and Behavioral Cookies

5.4 Other Analytics and Marketing tools

5.4.1 Google Analytics

We use Google Analytics cookies, a web analysis service provided by Google LLC (hereinafter: Google). These cookies transmit data concerning how you use the Website to a Google server in the USA. However, your IP address is shortened prior to transmission and the transmitted data can no longer be associated with you.

Data:                Data concerning how you use the Website (visits, sessions, frequency, time active, events and user actions).

Purpose:         Google will use the collected information to evaluate data concerning the general use of our Website and to compile Website Activities reports. For information about how Google and its affiliates use data, please visit Google's Privacy Policy, currently available at: www.google.com/privacy.html.

Legal Basis:     Data collection only takes place with your consent. This consent may be withdrawn by you at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before it is withdrawn. If you want to prevent the use of Google Analytics cookies in general, you can either do this through your browser settings or you can install the browser plug-in available via the following link: http://tools.google.com/dlpage/gaoptout.

Duration:        Your Data will be processed until you withdraw consent. Beyond that, we will process the Data only as long as there is a legal obligation to do so such as supporting claims/basis for completed financial transactions or credits issued to the final customer or we require the Data for the exercise or defense of legal claims.

Additional information concerning the tool can be found here:

https://policies.google.com/privacy.

5.4.2     Google Customer Match

The Google Customer Match feature enables us to create an audience using data such as e-mail addresses and phone numbers. Google does not receive actual e-mail addresses. Google’s system transforms the contact information we have into hashed codes, using secure hashing algorithm SHA256, a one-way hashing mechanism that is not unencrypted by Google.

Data:                Name*, e-mail-address*, address (street name and number, city, postal code, county), chosen license, metadata (registration data, subscription data, clicks, etc.)

Purpose:         We process your Data for the purpose of remarketing, direct marketing and social media marketing in the Google Customer Match tool. We may combine Data we or our providers have collected with Data collected by our affiliates to gain a more detailed picture of your needs and interests.

Legal Basis:     Data collection only takes place with your consent. This consent may be withdrawn by you at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before it is withdrawn.

Duration:        Your Data will be processed until you withdraw consent. Beyond that, we will process the Data only as long as there is a legal obligation to do so such as supporting claims/basis for completed financial transactions or credits issued to the final customer or we require the Data for the exercise or defense of legal claims.

Additional information concerning the tool can be found here:

https://support.google.com/google-ads/answer/6334160?hl=en

https://policies.google.com/technologies/partner-sites?hl=en

https://policies.google.com/privacy

5.4.3     Facebook

We also use the Facebook Audience Pixel analysis tool from Facebook Ireland Limited. All data collected by this pixel is encrypted by Facebook using "hashes".

Data:                Data concerning the way you use the Website (visits, sessions, frequency, time active, events and user actions).  

Purpose:         Measures the effectiveness of our advertising.

Legal Basis:     Data collection only takes place with your consent. This consent may be withdrawn by you at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before it is withdrawn.

Duration:        We store your Data only as long as it is necessary for the purposes for which we have collected your Data, we are legally obliged to do so or we have a corresponding overriding interest in such storage. Beyond that, Data processed with your consent will no longer be stored if you withdraw consent, unless there is a legal obligation to do so such as supporting claims/basis for completed financial transactions or credits issued to the final customer or we require the Data for the exercise or defense of legal claims.

Additional information concerning the tool can be found here:

https://www.facebook.com/policy.php.

5.4.4     Facebook Custom Audiences

Facebook’s Customer List > Custom Audiences feature enables us to create an audience using data such as e-mail addresses and phone numbers ("Audience"). When using this feature, your Data is locally hashed on our system before we upload and pass it on to Facebook ("Hashed Data") to be used to create an Audience.

Data:                Name*, e-mail-address*, address (street name and number, city, postal code, country), chosen license, metadata (registration data, subscription data, clicks, etc.).

Purpose:         We process your Data for the purpose of remarketing, direct marketing and social media marketing in the Facebook Customer List > Custom Audiences tool. We may combine Data we or our providers have collected with Data collected by our affiliates to gain a more detailed picture of the needs and interests of our customers.

Legal Basis:     We process this Data on the basis of your consent.

Duration:        We store your Data only as long as it is necessary for the purposes for which we have collected your Data, we are legally obliged to do so such as supporting claims/basis for completed financial transactions or credits issued to the final customer or we have a corresponding overriding interest in such storage.

Additional information about the tool can be found here:

https://www.facebook.com/legal/terms/customaudience

5.4.5     TikTok

Data:                Data concerning the way you use the Website (visits, sessions, frequency, time active, events and user actions).    

Purpose:         Measure the effectiveness of our advertising.

Legal Basis:     Data collection only takes place with your consent. Consent may be withdrawn by you at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before it is withdrawn. The comparison of the Data with Data stored by us is based on your consent. You can withdraw consent at any time by e-mail to: info@phiacademy.com.

Duration:        We store your Data only as long as it is necessary for the purposes for which we have collected your Data, we are legally obliged to do so or we have a corresponding overriding interest in such storage. Beyond that, Data processed with your consent will no longer be stored if you withdraw consent, unless there is a legal obligation to do so such as supporting claims/basis for completed financial transactions or credits issued to the final customer or we require the Data for the exercise or defense of legal claims.

Additional information concerning the tool can be found here: 

https://www.tiktok.com/legal/privacy-policy?lang=en

5.4.6     Pinterest

Data:                Data concerning the way you use the Website (visits, sessions, frequency, time active, events and user actions).   

Purpose:         Measure the effectiveness of our advertising.

Legal Basis:     Data collection only takes place with your consent. This consent may be withdrawn by you at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before it is withdrawn. The comparison of the Data with the Data stored by us is based on your consent. You can withdraw your consent at any time by e-mail to: info@phiacademy.com.

Duration:        We store your Data only as long as it is necessary for the purposes for which we have collected your Data, we are legally obliged to do so or we have a corresponding overriding interest in such storage. Beyond that, Data processed with your consent will no longer be stored if you withdraw consent unless there is a legal obligation to do so such as supporting claims/basis for completed financial transactions or credits issued to the final customer or we require the Data for the exercise or defense of legal claims.

Additional information concerning the tool can be found here: 

https://policy.pinterest.com/en-gb/privacy-policy#section-residents-of-the-eea

5.4.7     Snapchat

Data:                Data concerning the way you use the Website (visits, sessions, frequency, time active, events and user actions).  

Purpose:         Measure the effectiveness of our advertising.

Legal Basis:     Data collection only takes place with your consent. This consent may be withdrawn by you at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before it is withdrawn. The comparison of the Data with the Data stored by us is based on your consent. You can withdraw your consent at any time by e-mail to:  info@phiacademy.com.

Duration:        We store your Data only as long as it is necessary for the purposes for which we have collected your Data, we are legally obliged to do so or we have a corresponding overriding interest in the storage. Beyond that, Data processed with your consent will no longer be stored if you withdraw consent unless there is a legal obligation to do so such as supporting claims/basis for completed financial transactions or credits issued to the final customer or we require the Data for the exercise or defense of legal claims.

Additional information concerning the tool can be found here: 

https://www.snap.com/en-GB/privacy/privacy-policy. 

5.4.8     LinkedIn

Data:                Data concerning the way you use the Website (visits, sessions, frequency, time active, events and user actions).  

Purpose:         Measure the effectiveness of our advertising.

Legal Basis:     Data collection only takes place with your consent. This consent can be withdrawn by you at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before it is withdrawn. The comparison of the Data with the Data stored by us is based on your consent. You can withdraw your consent at any time by e-mail to: info@phiacademy.com.

Duration:        We store your Data only as long as it is necessary for the purposes for which we have collected your Data, we are legally obliged to do so or we have a corresponding overriding interest in the storage. Beyond that, Data processed with your consent will no longer be stored if you withdraw consent unless there is a legal obligation to do so such as supporting claims/basis for completed financial transactions or credits issued to the final customer or we require the Data for the exercise or defense of legal claims.

Additional information concerning the tool can be found here: 

https://www.linkedin.com/legal/privacy-policy.

5.4.9   Hotjar

Data:                Device’s IP address (stored in a de-identified format); device screen resolution; device type (unique device identifiers), operating system, and browser type; geographic location (country only); preferred language used to display the Hotjar enabled site; mouse events (movements, location and clicks); keypresses; referring URL and domain; pages visited and date and time when Website pages were accessed.  

Purpose:         We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our Services with user feedback.

Legal Basis:     Data collection only takes place with your consent. This consent may be withdrawn by you at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before it is withdrawn. 

Duration:        Your Data will be processed until you withdraw consent. Beyond that, we will process the Data only as long as there is a legal obligation to do so such as supporting claims/basis for completed financial transactions or credits issued to the final customer or we require the Data for the exercise or defense of legal claims.

Additional information concerning the tool can be found here: 

https://www.hotjar.com/legal/policies/privacy/.

6. Your Rights in the Context of the Processing of Your Data

If we process inaccurate or incomplete Personal Data, you have the right to rectification or completion of such Data. You may also request the deletion of the Personal Data which have been processed unlawfully. If it is unclear whether your Personal Data is inaccurate, incomplete, or unlawfully processed you may request us to restrict the processing of your Data until this issue has been resolved. If processing is based on consent or on a contractual relationship, you also have the right to receive your Personal Data processed by us in a structured, commonly used and machine-readable format (data portability).

Any consent given may be revoked at any time with future effect. This does not affect the lawfulness of the processing prior to the revocation. If we process your data based on our legitimate interest, you have the right to object to the processing of your Personal Data on grounds relating to your particular situation. You further have the right to object to where we process your Personal Data for direct marketing purposes.

To exercise your data protection rights, please contact us using the contact details provided below.

If you believe that we have violated your rights when processing your Data, please contact us. This is the only way we can process your concerns as quickly as possible. You also have the right to lodge a complaint with a supervisory authority in Serbia: www.poverenik.rs and in Austria: www.dsb.gv.at.

7. Automated decision-making and Profiling

We do not use Automated Decision-making according to Article 22 of the GDPR.

8. Who is Responsible for the Processing of your Data and How Can You Contact the Controller?

PhiAcademy d.o.o. Beograd-Voždovac, Bulevar oslobođenja 137, Belgrade, the Republic of Serbia is responsible for data processing activities.

9. Who Can You Contact?

If you have any requests or concerns, you can contact us directly by post or e-mail via the following addresses: 

PhiAcademy d.o.o. Beograd-Voždovac

Bulevar Oslobođenja 137, 11000 Belgrade 

Republic of Serbia

or

e-mail: info@phiacademy.com