Privacy Policy

LAST UPDATED: JANUARY. 9TH 2025

HELLO!

Dear User, hereinafter referred to as “You” and/or “User”, welcome to the Edraak’s massive open online course (MOOC) platform (“Website”), owned by Edraak for Training and Social Development, a non-for-profit Limited Liability Company registered with the Companies Control Department under number 843 wholly owned by Queen Rania Foundation for Education and Development, of address 5 Mohammad Saad AlBatayneh Street, Amman, Jordan (the “Owner”, “Us”, “We”).

Please read the provisions of this privacy policy (“Privacy Policy”) carefully, noting that Your registration on the Website and/or Your continued usage of the same confirms that You have read this Privacy Policy and that You consent and allow Us to collect and process Your data you are sharing with us.

For the purposes of this Privacy Policy, please note that “processing” personal data means conducting operations in the forms and in the means outlined in this Privacy Policy with the aim, for instance, of collecting, recording, copying, saving, storing, organizing, revising, using, transmitting, distributing, publishing, linking with other data, making available, transferring, displaying, anonymizing, encoding, destroying, restricting, erasing, modifying, describing, or disclosing personal data.

We are committed to ensuring that Your personal data is protected once it is shared with the Website. This Privacy Policy explains when and how we collect and process Your personal data, in addition to the rights that You have over such data.

Please make sure to read this Privacy Policy before proceeding to register on or continue any use of the Website.

This Website is not primarily intended for children under the age of 18. We have implemented an age verification process. You will be required to provide Your date of birth upon registration. If You indicates that You are under 18, we will follow the necessary steps to obtain parental consent before allowing full access to the Website.

1- We do not knowingly collect, use or process personal data relevant to or concerning anyone below the age of 18 without parental or guardian consent. Any use of this Website by any individual under the age of 18 is not permitted without the child’s guardian or parent consent. Please refrain from sharing any personal data with Us or refrain from registering and using the Website if You are below the age of 18 and if Your parent or guardian has not agreed to Your use of the Website.Parents or guardians can provide this consent through our parental consent form, which will be verified [via email, phone, or other secure methods.] If you have any questions or concerns about our privacy practices, please contact our Data Protection Officer at dpo@edraak.org

2. YOUR PERSONAL DATA

We collect two types of personal data about You: (1) data collected automatically as a result of Your use of the Website (described below under “Data Collected Automatically”) and (2) data that You may choose to voluntarily provide while using the Website (described below under “Data You Provide”). We may also receive data about You from third-party sources (as described below under Data Received from Third-Party Sources).

Furthermore, Data Collected Automatically and Data Your Provide may consist of personal data which includes information which identifies You or about You, such as your name or your IP address.

2.1 DATA COLLECTED AUTOMATICALLY

“Data Collected Automatically” includes but is not limited

  • Records of your visits to the Website and engagement with educational content such as pages, videos, assessments, and posts, comments, and any other interactions you perform on course discussion forums.

  • Details of grades scored on assessments you take on the Website.

  • Online footage of interactions you performed in online lecture videos, called “pause and seek events.”

  • Information collected from cookies or other tracking technologies, Wi-Fi connection information, device ID, IP address, device location (network-based and GPS), SD information, network information, network connections, mobile number, date and time when You use the Website, location of using the Website, nature of the transaction performed on the Website, information about response time of the Website, statistics and information regarding how services of the Website are loaded or viewed, information from Your device (i.e., language settings, browser ID, cookie preferences, time zone, operating system, screen resolution and similar information about Your device settings).

    Please refer to our cookie policy here to understand when and how cookies are collected and processed.

2.2 DATA YOU PROVIDE

Data your provide may include, but is not limited to:

  • Personal Identifiers such as full name in Arabic and English, date of birth, age, country or region of residence, gender, email, education level, time zone, Website username, Website password and any other information necessary to establish an account on the Website, such as your social media accounts if you login/register using social media, namely Facebook or Google.

  • Information you add to child accounts you create for Your children on the Website through the parents’ section on the dashboard page; in which case Your child’s name, gender, academic grade and Your preference with regard to the country whose curricula You want the Child’s programs to follow will be collected. We will not share externally a child’s data, or any linkage between child and parent data.

  • Device Information, including the type of mobile device You use, a unique device identifier (for example, Your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, Your mobile operating system, the type of mobile browser You use, time zone setting, and any other information the Website may access.

  • Geolocation: IP-based geolocation data and Global Positioning System (GPS) upon requesting Your prior consent as a User during Your User experience or based on Your mobile settings.

  • Information You provide when You contact Us, including Your response(s) to surveys, recorded conversations, chat conversations with the Us, email correspondence with the Us, account status, information about others if You choose to share it with Us.

  • Data about Your Device: including, language settings, browser ID, cookie preferences, data collected from cookies or other tracking technologies and similar information about Your device settings.

2.3 DATA RECEIVED FROM THIRD-PARTY SOURCES

We may obtain contact details and other personal data about you from our affiliates and from other third parties, including:

  • Service providers that help us determine a location in order to customize certain products to your location;

  • Partners with which we offer co-branded services or engage in joint educational promotion activities; and/or

  • Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

2.4 HOW WE PROCESS YOUR DATA

All data collected and processed by Us shall serve non-commercial purposes, and will be collected and processed exclusively for maintaining and developing the Website, as well as complying with local and foreign regulatory standards including Anti-Money Laundering (AML), Know-Your-Customer (KYC), and Counter Terrorism (CT).

We will only use the information outlined above for the purposes for which it is provided and to fulfill our legal or regulatory obligations.

The Website only uses IP address and Internet Log-On Date (Cookies) to collect standard log-on information and details of visitor behavior patterns; which in turn enables us to analyze and improve the content of our Website and the navigation experience of users. We do not use this information for any commercial reasons whatsoever.

Where we use your data, we process it on the following bases:

  • Performance of a contract to which you as a data subject are a party (including in connection with the retention of records detailing your learning progress and performance for the purpose of saving your course progress and certificates).

  • For Our legitimate interest in carrying out the following activities:

    ◦ Internal research purposes, for example, the improvement of course design and operation.

  • The following research purposes (unless you decide to opt-out when registering or subsequently):

    ◦ Internal research in connection with how the Website is used.

    ◦ For the purpose of sending you updates regarding online courses offered by the Owner.

  • Improving Your experience on the Website.

  • The publication of scientific papers in journals or conferences. No data that identifies You is ever shared in a scientific publication. We only publish aggregated or anonymized data.

  • Internal Business Purposes: We may use your data for internal business purposes, including without limitation, to help us improve the content and functionality of the Website, to better understand our Users, to improve the services offered on the Website, to enforce our Terms of Service, to manage Your account and provide you with customer service, and to generally manage the services and our business.

  • Educational Promotion of our Activity: We may use Your data to contact you in the future for our educational promotion purposes, including without limitation, to inform you about services or events we believe might be of interest to You, to develop educational promotional materials and provide those materials to You, and to display content and advertising on or off the services that we believe might be of interest to you. In particular, you should note that we may use information we receive or collect regarding users in accordance with the terms of this Privacy Policy, including in the manner set forth above.

  • Other Purposes: If the Owner intend to use any data in any manner that is not consistent with this Privacy Policy, you will be informed of such different use prior to or at the time at which the data is collected, or we will obtain your consent before such collection and prior to such different or inconsistent use.

We aim not to collect any unnecessary data from you and do not process your information in any way other than as specified in this Privacy Policy. We make every effort to maintain the accuracy of your Personal Data, which we store, and to ensure all of your Personal Data is up to date. However, you can assist us with this by promptly contacting us if there are any changes to your data. We shall not be responsible for any losses you suffer arising from any inaccurate, inauthentic, deficient, or incomplete personal information that you provide to Us (Terms of Service).

2.5 HOW DO WE KEEP YOUR DATA SECURE?

We are committed to protecting Your privacy and prioritizing the security of Your personal information including children. We take all necessary steps to ensure that Your data is kept private and protected from unauthorized use in accordance with this Privacy Policy.

2.6 HOW LONG WE STORE YOUR DATA

We will only retain the data You provide to us through the Website for as long as is necessary for the purpose for which it was collected and in accordance with any consents provided in accordance with the applicable data protection laws and regulations.

2.7 WHO DO WE SHARE YOUR DATA WITH?

We may share Your personal data with third parties who operate a portion of the services of the Website or who process data on our behalf, but only where we place obligations on them in relation to the security of the data and require them to use the data only as we instruct. This includes technical service providers who handle technical support as is necessary for the technical provision of services.

We may from time to time share your personal data with the following parties for the purpose of improving course content, and improving educational promotional operations:

  • Our internal course management team;

  • Our visibility and promotion;

  • Our internal leadership team;

  • With external educational researchers for the purpose of conducting educational research. In which case Your data is anonymized; and

  • Third parties we partner with for the purposes of course creation, operation, or evaluation (including instructors, teaching assistants, and personnel from organizations that partner with Us for the purpose of a course you are enrolled in) and promotional agencies we partner with for Our specific promotional educational needs. All third parties who receive personal data from Us sign a data processing agreement that mandates they use your data only for the purposes for which We contracted them and in accordance with the applicable data protection laws and that the third party deletes your personal data within 10 days of the termination or completion of the contract.

3. YOUR RIGHTS AS A USER

You have specific rights as a User of the Website and a data subject under the Jordanian Data Protection Law. We are keen to provide You with all the protection you deserve as a User of Our website.

Please note that the following list of rights may not be exhaustive and could apply differently to You as a User of Our Website.

3.1 ACCESSING YOUR DATA

You have the right to be informed about, to access, and to view any personal data We collect and keep about You, as well as request information on how Your personal data has been collected and processed by Us.

This right to access is provided to You free of charge. To make a request, please contact Us/our Data Protection Officer at: dpo@edraak.org

3.2 RECTIFYING, AMENDING, OR UPDATING YOUR DATA

You have the right to request the erasure, the rectification, the update of any personal data You have provided to us in the past. We will take reasonable steps to inform those with whom we have shared Your data about Your requests.

In all cases, you acknowledge that We shall have the right to review Your request to approve or reject Your request to rectify, erase, hide, or update any data You have provided during Your use of the Website. The decision to reject or approve Your request shall be made in accordance with Your rights under the applicable Jordanian laws.

You agree that if Your request to delete or erase Your data is accepted, it may result in preventing You from accessing the Website thereafter. We shall keep record of any request You have made to have Your data rectified, updated, hidden, deleted, or erased for an indefinite period.

3.3 REVOKING CONSENT

You maintain the right to revoke any consent which You have provided to the Owner, whether explicitly, or implicitly by using the Website, by submitting a declaration of revoking consent to the Owner. Revoking any consent that has already been granted may result in limiting or preventing Your access to the Website.

The Owner shall keep record of any declaration You have made to revoke Your consent for compliance purposes.

3.4 LIMIT OR REJECT HOW YOUR DATA IS COLLECTED OR PROCESSED

You may submit a request to Us to limit the manner in which your Data is collected or processed. If Your request is accepted, it may limit or prevent Your access to the Website. The Owner shall keep record of any request You have made to limit or reject the manner in which Your data is processed or collected for compliance purposes.

3.5 REQUEST THE TRANSFER OF YOUR DATA

You may submit a request to Us to have any of Your data transferred to a third-party. We shall do Our best to comply with such a request as applicable under Jordanian Law within an appropriate and timely manner. We may request further documentation from You or from the concerned third-party in this circumstance as to ensure the safety of Your data and the compliance with the relevant Laws.

The Owner shall keep record of any request You have made to have Your data transferred to a third-party for as long as legally required under the applicable law.

3.6 KNOWING OF ANY BREACHES OR VIOLATIONS OF YOUR DATA

We shall do Our best to inform You of any breaches to the safety of Your data, as well as of any violations that have taken place in respect to Your personal data within (24) hours of discovering any such breach and/or violation in accordance with the applicable data protection laws and regulations.

We will inform You of the necessary steps to be taken in regard to the breach and/or violation as well as of any consequences of such an event. We will take all required measures to inform any relevant authorities of such breaches or violations, which may entail disclosing Your personal data.

3.7 PARENTAL ACCESS AND CONTROL

Parents and guardians can manage their child's account settings and privacy preferences. This includes reviewing and approving the data collected, understanding how it is used, and requesting the deletion of their child's personal data. To manage these settings, or have questions with regard to our practices, parents can contact our support team at info@edraak.org , our Data Protection Officer at dpo@edraak.org or access the parental control panel through their account.

3.8 CHANGES TO THIS PRIVACY POLICY

Except to the extent limited by applicable law, We may modify this Privacy Policy at any time by posting the updated Privacy Policy on the Website or, obtain your consent or elsewhere by any means. Your continued use of the Website following the posting of updated Privacy Policy constitutes Your acceptance of the updated Privacy Policy. You agree that you will review this policy periodically. If we make any changes to this policy, we will change the "Last Updated" date above.

4. GENERAL PRINCIPLES

4.1 GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by and construed in accordance with the laws of the Hashemite Kingdom of Jordan, and in the event of any dispute arising out of the Privacy Policy or the Website, You hereby submit to the exclusive jurisdiction of the competent Courts of Palace of Justice in the Hashemite Kingdom of Jordan.

4.2 FORCE MAJUERE

Subject to Our obligations under the applicable Jordanian Laws with regard to security breaches committed by third-party, We shall not be liable in respect of any breach of this Privacy Policy due to any cause beyond Our reasonable control including any data breach or security breach committed by a third party and/or any act of God, inclement weather, act or omission of Government or public telephone operators or other competent authority or other party for whom We are not responsible.

4.3 TERMINATION AND ACCESS RESTRICTION

We hereby reserve the right to terminate or suspend Your access to the Website and/or all or some of the services of the Website at any time, with or without cause. Upon notifying You, Your right to use the Website and/or services will immediately cease. Please note that Your rights under Jordanian data protection law related to Your personal data previously processed before termination or access restriction shall be preserved.

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