Privacy Policy

Introduction

graviluxora B.V. ("we", "our", or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, share, and protect information about you when you use our education analytics services and website.

As a data controller, we process personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws in the European Union and the Netherlands.

Data We Collect

We collect and process various types of personal data when you interact with our services. The data we collect includes information you provide directly to us, information we collect automatically when you use our services, and information we receive from third parties such as educational institutions.

Information You Provide

• Contact information (name, email address, phone number)
• Professional information (organisation, job title, department)
• Account credentials and preferences
• Communications with our support team
• Feedback and survey responses

Information We Collect Automatically

• Usage data and analytics information
• Device and browser information
• IP address and location data
• Cookies and similar tracking technologies

Educational Data

Through our analytics services, we may process educational data on behalf of our clients, including student performance data, learning analytics, and assessment information. We act as a data processor for this information under the instructions of our client institutions.

How We Use Your Information

We use the personal data we collect for various purposes related to providing and improving our education analytics services. Our use of your data is based on legitimate interests, contractual necessity, and your consent where required.

Service Provision

• Delivering our analytics services and platform access
• Processing your requests and communications
• Providing customer support and technical assistance
• Managing your account and preferences

Service Improvement

• Analysing usage patterns to improve our services
• Developing new features and functionality
• Conducting research and analytics
• Ensuring security and preventing fraud

Communication

• Sending service-related notifications
• Providing updates about our services
• Responding to your enquiries
• Marketing communications (with your consent)

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about our use of cookies, please refer to our Cookie Policy.

Data Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties. We may share your information in the following circumstances:

Service Providers

We may share data with trusted third-party service providers who assist us in delivering our services, such as hosting providers, analytics services, and customer support tools. These providers are bound by contractual obligations to protect your data.

Legal Requirements

We may disclose your information if required by law, regulation, or legal process, or to protect our rights, property, or safety, or that of our users or the public.

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction, subject to appropriate data protection safeguards.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, regular security assessments, and staff training on data protection.

However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security of your information.

Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention periods depend on the type of data and the purpose for processing.

Retention Periods

• Account information: Retained whilst your account is active and for 3 years after closure
• Service usage data: Retained for 2 years for analytics purposes
• Marketing communications: Retained until you unsubscribe
• Educational data: Retained according to client institution requirements and applicable laws

Your Rights

Under GDPR and applicable data protection laws, you have several rights regarding your personal data:

Access and Portability

• Right to access your personal data
• Right to receive a copy of your data in a portable format

Correction and Deletion

• Right to correct inaccurate personal data
• Right to erasure ("right to be forgotten")

Processing Rights

• Right to restrict processing
• Right to object to processing
• Right to withdraw consent

To exercise these rights, please contact us using the information provided below. We will respond to your request within one month, unless the request is particularly complex.

International Data Transfers

We primarily process data within the European Economic Area (EEA). When we transfer personal data outside the EEA, we ensure appropriate safeguards are in place, such as adequacy decisions, standard contractual clauses, or other approved transfer mechanisms.

Children's Privacy

Our services are not directed to children under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information.

When processing educational data that may include information about minors, we do so only under the instruction of educational institutions and in accordance with applicable laws and regulations.

Contact Information

If you have any questions about this Privacy Policy or our data practices, or if you wish to exercise your rights, please contact us:

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe we have not handled your personal data appropriately.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website and updating the "Last updated" date.

Your continued use of our services after any changes constitutes your acceptance of the updated Privacy Policy.