This Privacy Policy governs the manner in which the Company collects, uses, maintains, and discloses information collected from users (each, a “Student” or "User") of the Snoopgame Online Course. This Privacy Policy applies to the website, the Online Course, and all services offered by the Company.
The Data Controller responsible for your personal data under the EU General Data Protection Regulation (GDPR) is SnoopGame OÜ, registered in Estonia under registry code 16453554 , with its registered office at Endla 4, 10142, Tallinn, Estonia (hereinafter referred to as the "Company", "we", "us", or "our").
The data processing between the Company and the Learning Management System (LMS) platform Kwiga is governed by a Data Processing Agreement (DPA) in compliance with Article 28 of the GDPR.
1. What Personal Data We Collect
We may collect personal identification information from Students in a variety of ways, including, but not limited to, when Students register on the platform, enroll in the Online Course, subscribe to a newsletter, fill out a form, or interact with our services.
Depending on your actions, we may collect:
Identity Data: First name, last name.
Contact Data: Email address, billing address, phone number.
Financial Data: Payment details (processed securely via third-party payment gateways; we do not store full credit card numbers).
Technical Data: IP address, browser type, login data, time zone setting, and operating system collected via cookies and the LMS platform.
Students can always refuse to supply personal identification information, except that it may prevent them from enrolling in the Online Course or using certain platform features.
2. Legal Bases and How We Use Collected Information
The Company collects and uses Students’ personal data under the following legal bases permitted by the GDPR:
Performance of a Contract (Art. 6(1)(b) GDPR): To process your enrollment, manage your account, provide access to the Online Course on Kwiga, respond to your customer service requests, and provide technical support.
Legal Obligation (Art. 6(1)(c) GDPR): To comply with applicable accounting and tax laws in Estonia (e.g., preserving invoice and payment history).
Legitimate Interests (Art. 6(1)(f) GDPR): To personalize the user experience, understand how our Students as a group use the services, improve our Online Course, and send administrative updates pertaining to your purchase.
Consent (Art. 6(1)(a) GDPR): To send periodic marketing emails or newsletters. You can opt-out/unsubscribe at any time by clicking the link at the bottom of any email.
3. Sharing Your Personal Information
We do not sell, trade, or rent Students' personal identification information to others. However, to provide our services, we share necessary data with trusted third-party service providers (Data Processors) who adhere to strict data protection standards:
LMS Platform: Kwiga, for hosting the course content, tracking student progress, and managing profiles.
Payment Processors: Secure gateways such as [Stripe / PayPal / etc.] to securely process payments.
Email Marketing & Analytics Tools: Providers used for sending course-related notifications, marketing emails, and analyzing platform usage.
State Authorities: Only when required by mandatory law (e.g., Estonian Tax and Customs Board).
4. Data Transfers Outside the EEA
Your personal data is primarily stored within the European Economic Area (EEA). If any of our third-party service providers process data outside the EEA, we ensure that appropriate safeguards are in place, such as EU Standard Contractual Clauses (SCCs), to guarantee a level of data protection equivalent to the GDPR.
5. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Account info and course progress data are stored as long as your account remains active.
Financial and transaction data are retained for 7 years to comply with Estonian accounting and tax legislation.
6. Your Rights Under the GDPR
As a resident of the European Union, you have the following rights regarding your personal data:
Right of Access: You have the right to request copies of your personal data.
Right to Rectification: You have the right to request that we correct any information you believe is inaccurate.
Right to Erasure ("Right to be Forgotten"): You have the right to request that we erase your personal data under certain conditions.
Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data.
Right to Object to Processing: You have the right to object to our processing of your personal data (e.g., for direct marketing).
Right to Data Portability: You have the right to request that we transfer the data we have collected to another organization.
To exercise any of these rights, please contact us at our support email provided below. You also have the right to lodge a complaint with a supervisory authority, in particular the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at [email protected].
7. Third-Party Websites
Students may find content or links in our Online Course that lead to the websites and services of third parties. We do not control the content or links that appear on these websites and are not responsible for the practices employed by websites linked to or from our Online Course. Browsing and interaction on any other website is subject to that website's own terms and privacy policies.
8. Changes to This Privacy Policy
The Company has the discretion to update this Privacy Policy at any time. When we make material changes, we will notify you by sending an email to the address registered in your account or by placing a prominent notice on the LMS platform at least 14 days before the changes take effect.
9. Your Acceptance of These Terms
By enrolling in the Online Course, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not enroll in the Online Course.
10. Contacting Us
If you have any questions about this Privacy Policy, the practices of this Online Course, or your dealings with this site, please contact us at:
Email: [email protected]
Postal Address: Endla 4, 10142, Tallinn, Estonia