1 Introduction
Erynnis Limited (“the Company”) is committed to protecting the privacy and security of your personal data in accordance with applicable data protection laws.
This Privacy Policy explains how we collect, use share and safeguard your personal data when you interact with our website and services. It also outlines your rights regarding your personal data and how to exercise them.
By using our website and services, you acknowledge that you have read, understood and accepted this Privacy Policy. We may update this Policy from time to time, and any changes will take effect upon publication. If we make significant updates, we will notify you accordingly.
This Policy applies to all users of our website: https://pipup.com/, including registered customers, prospective customers, and visitors.
2 Personal Data That We May Collect
When you create an account with Erynnis Limited, we may collect the following personal data:
- Basic Information: Your first and last name, email address, and phone number, address.
- Account & Payment Details: Billing address, payment information (e.g., credit/debit card details), and transaction history.
- Educational & User Preferences: Selected courses, learning progress, assessment and interactions with our website.
- Technical Information: IP addresses, browser type, device information, and other details collected through cookies (for more information, see our Cookies Policy).
We collect this data when you register for a user account, purchase a course, or interact with our services. Providing personal data is necessary for us to create your account, process payments, and deliver educational content. Additionally, we may collect information from communications with you, including emails, live chats, or support requests. These records help us improve our services and address inquiries.
We do not collect financial status details, tax identification numbers, or regulatory information, as our services do not involve financial transactions requiring such data.
If you are unable to provide the requested data, we may not be able to proceed with your user account creation or payment processing, and we will inform you accordingly.
3 Legal Grounds for Personal Data Processing
We may process your personal data based on one or more lawful grounds (“Lawful Bases”), depending on the specific purpose for which we use your data.
The Lawful Bases for processing your personal data include:
- Performance of a Contract: To fulfill our contractual obligations to you.
- Legitimate Interests: To pursue our legitimate interests in providing services, improving our website, and ensuring the security of our systems, provided these interests are not overridden by your rights and freedoms.
In cases where our use of your personal data does not fall under one of the above Lawful Bases, we will seek your consent. Such consent shall be freely given, and you have the right to withdraw it at any time. To withdraw your consent, please contact us by email or phone (contact details you can find on our website).
4 How We Use Your Personal Data
We process personal data in accordance with applicable data protection laws and only for legitimate purposes, including but not limited to:
- Providing, managing, and improving our services: Granting access to educational content and managing user accounts, and enhancing the user experience.
- Processing payments and handling refunds: Maintaining transaction records related to course purchases.
- Conducting research and statistical analysis: To improve our services and user experience.
- Sending service-related communications: Updates on course availability, changes to our services, or essential notifications.
- Marketing and promotional activities: Where permitted by law or based on your consent.
- Protecting your legal rights: Enforcing our Terms & Conditions and addressing disputes or claims.
- Responding to lawful requests: From regulatory authorities, law enforcement agencies, or other government entities as required by applicable laws.
5 Disclosure of Your Personal Data
We may share your personal data with third parties in the following circumstances:
- Legal requirements: When required by law or a legal process.
- Payment processing: With payment services providers and banks, to process transactions and refunds securely.
- Service providers: With third-party vendors assisting in delivering, improving, and maintaining our services (e.g., hosting providers, customer support, and analytics providers).
- Marketing and research: With third-party marketing and research agencies conducting survey or marketing campaigns on our behalf, where legally permissible.
- Business transfers: In the event of a merger, acquisition, or sale of our business or assets, with relevant third parties involved in the transaction.
- With your consent: Where you have explicitly authorized us to share your data with specific third parties.
We take appropriate measures to ensure that third parties handling your personal data comply with applicable data protection laws and maintain strict confidentiality and security standards. We do not sell your data to third parties.
6 The Safety of Your Personal Data
The Company takes the appropriate measures to ensure a level of security suitable to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access during transmission, storage, or processing.
The Company implements technical and organizational measures such as data encryption, access management procedures, IT systems risk assessment, and personal data breach response procedure. Additionally, access to personal data is limited to employees, agents, contractors, and other third parties who have legitimate need to know. These individuals will only process your data accordingly to the Company’s instructions and are subject to a duty of confidentiality.
Your personal data may be stored electronically or in paper form.
7 How Long We Store Your Personal Data
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including the provision of educational services and processing transactions. Once your personal data is no longer needed, it will be securely deleted. We will also ensure compliance with any applicable legal requirements.
Under GDPR, you have the right to request the deletion of your personal data at any time, provided it is no longer necessary for the purposes for which it was collected. If you wish to exercise this right, please contact us. We will promptly process your request unless there are overriding legal obligations that require us to retain your data for a longer period.
8 Your Rights as a Data Subject
Right of Access – You have the right to request a copy of the personal data we hold about you. We will provide you with this data upon request.
Right of Rectification – You have the right to request the correction of any inaccurate or incomplete personal data we hold about you.
Right to Erasure (Right to be forgotten) – You have the right to request that we erase your personal data, subject to certain exceptions. If it is applicable and provided no legal obligation to retain the data exists, we will erase your personal data from our records.
Right to Restriction of Processing – You have the right to request the restriction of processing your personal data where certain conditions apply.
Right to Data Portability – You have the right to request that we transfer your personal data to another organization, in a structured, commonly used, machine-readable format, where certain conditions are met. This right applies only to automated data that you have provided us with consent to use or that we have used to fulfill a contract with you.
Right to Object – You have the right to object to the processing of your personal data on grounds relating to your particular situation, including objection to processing for direct marketing purposes or where we rely on legitimate interests for processing. If applicable, we may demonstrate that we have compelling legitimate grounds to override your objection.
Right to Withdraw Consent – If we are relying on your consent to process your personal data, you have the right to withdraw that consent at any time. Please note that withdrawing consent will not affect the lawfulness of any processing carried out before you withdrew it. In some cases, withdrawing consent may limit our ability to provide certain services to you. We will inform you of any such limitations at the time of withdrawal.
Process for Exercising Your Rights
To exercise any of these rights, please send a request to: [email protected].
In certain circumstances, we may charge a reasonable fee for repeated or excessive requests. We will inform you of any applicable charges before processing your request. Alternatively, we may refuse to act on your request in these cases.
9 Contacting us About This Policy or Making a Complaint
If you have any queries regarding the contents of this Policy, wish to inform us of a change or correction to your personal data, request a copy of the data we hold about you, or wish to raise a complaint or provide comments, please contact us using the details below:
E-mail: [email protected]
We strive to respond to your request promptly, and in any case, within one month of receiving your request. If we require more than one month to process your request, we will notify you accordingly and provide updates on the status of your request.
Please note that the information provided as a result of exercising your rights will be provided free of charge. However, if your request is manifestly unfounded or excessive, particularly if it is repetitive, the Company may:
- Charge a reasonable fee to cover the administrative costs of providing the requested information, communication, or action; or
- Refuse to act on the request.
If you are not satisfied with our response to your complaint, or if your request is not handled within the specified timeframes, you have the right to lodge a complaint with our supervisory authority, the Cyprus Data Protection Commissioner. You may also lodge a complaint with the data protection authority in your country of residence.
For more information on how to contact the Cyprus Data Protection Commissioner, please visit their website: http://www.dataprotection.gov.cy.
