This privacy statement describes how CodeGrade B.V. processes your personal data. This privacy statement concerns the personal data you provide us via our website(s). We can change this privacy statement from time to time.

1. About CodeGrade

CodeGrade B.V. is for the processing of personal data concerning this privacy statement the responsible party according to the Algemene Verordening Gegevensbescherming (“AVG”, the Dutch implementation of the General Data Protection Regulation, “GDPR”). This means that CodeGrade B.V. (hereafter: “CodeGrade”, “we”, or “us”) decides which personal data is being processed, with which objective, and in which manner. CodeGrade is responsible for a reasonable and suitable processing of your personal data.

CodeGrade has its registered office at Weteringsschans 124, 1017 XT, Amsterdam, the Netherlands. For questions you can email privacy@codegrade.com.

2. Which personal data do we process?

This privacy statement gives information about the processing of personal data of users of CodeGrade. We process the following personal data of users:

• IP address
• full name,
• email adress,
• LMS-ID (“Learning Management System” or “Virtual Learning Environment” ID),
• Any other personal data that users submit.

The (intellectual) ownership/property of anything submitted via our application remains at the original owner and does not belong to CodeGrade.

3. Why do we process personal data?

We process personal data for the objective of a correct operation of CodeGrade. We also have to comply to legal requirements for which we have to process your personal data. The user-specified personal data are processed for the following purposes:

• presenting the CodeGrade application,
• passback to LMS / VLE (“Learning Management System” or “Virtual Learning Environment”).

4. Processing objectives

In order to be able to process your personal data, the processing has to comply with one of the objectives described in the AVG/GDPR. In the case of CodeGrade this is the fulfillment of a legal agreement. In case you do not provide us with certain personal data, it could be possible that you cannot use CodeGrade. Without your personal data CodeGrade cannot operate.

5. To whom does CodeGrade provide personal data?

We do not provide personal data to third parties with the exception of IT companies that, for example, host the CodeGrade servers.

If we let third parties process your personal data and we control and retain control over the processing, we conclude a written processing agreement with these processors. In this we make agreements about, among other things, the objective, the duration and the scope of the processing, the retention periods and the security measures taken to protect the personal data.

6. Processing of personal data outside of the EU

CodeGrade only processes your data within the European Union (“EU”). This means that the servers where we save your personal data are also located within the EU. If we use third-party processors, we require them that they save personal data on servers within the EU.

7. Your rights regarding personal data

If we process your personal data, you have, under certain circumstances, the right to view it, have it corrected or deleted or restricted. You can also under certain circumstances object or request a transfer of your personal data. To make a request to us in this context, you can contact us via privacy@codegra.de. When in doubt about your identity, we could ask you to identify yourself first.

Inspection and correction: in case you want to know if we are processing your personal data or if you want to change your personal data, you can contact us.

Deletion: the AVG/GDPR offers, under certain circumstances, the possibility to have personal data deleted. We assess whether such a request can be executed. In some cases we do have to retain your personal data, for example due to a legal requirement or for the operation of CodeGrade.

Restriction: you can contact us with a request to limit the processing of your personal data if you think that your personal data is incorrect, the processing is unlawful, you need it for a legal action or if you have objected to the processing thereof.

Objection: if we process your personal data on the basis of a legitimate interest, you may object to further use of your personal data under specific circumstances.

8. How do we secure your personal data?

We have taken fitting technical and organisational measures to prevent the loss of personal data or unlawful processing. For example, your personal data can only be accessed by employees who are authorized to do so on the basis of their position.

9. How long do we store your personal data?

We do not store your personal data any longer than necessary for the objectives for which we use your personal data.

10. Questions or complaints?

If you have any questions about how we process your personal data, you can contact us via privacy@codegrade.com. We are happy to help you.

If you do not agree with our processing and/or course of action, you can submit a complaint to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). The Dutch Data Protection Authority will handle the complaint or the request and will decide a course of action.

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