Privacy Policy
1. Preamble
The User acknowledges being informed that Babylonelearning collects certain personal data
concerning them. Such data is subject to appropriate and secure processing, in compliance
with the applicable legal provisions on the protection of personal data, including:
Algeria: Law No. 18-07 of 10 June 2018 on the protection of natural persons in the
processing of personal data.
European Union (
Ireland): Regulation (EU) 2016/679 of 27 April 2016 on the
protection of personal data (GDPR).
United States: Applicable laws and regulations depending on the competent States,
particularly regarding privacy and data security.
When you use our Babylonelearning platform, we may ask you to provide certain personal
data.
The term “personal data” refers to any information relating to an identifiable user, directly
or indirectly, as defined under applicable legislation.
The terms “User”, “Learner”, “Trainer” or “Partner” refer to any person using the
Babylonelearning website and/or services.
The terms “Babylonelearning”, “we”, “our” and “us” refer to the data controller.
Babylonelearning is committed to preserving the confidentiality of collected personal
information and protecting the data entrusted by its users. In line with its legal and ethical
obligations, Babylonelearning implements an appropriate level of security and protection to
ensure the integrity of the personal data collected online.
In general, Babylonelearning only collects personal data voluntarily provided by users,
enabling them to fully benefit from the services offered on the platform.
Each user is invited to carefully review this Privacy Policy to understand how we collect, use,
share, and protect personal data obtained.
This Privacy Policy applies to all Babylonelearning users, except when certain services are
subject to specific provisions set out in a separate policy.
2. Purpose of this Policy
The purpose of this policy is to inform you of the means implemented by
Babylonelearning to collect, process, and protect your personal data, while
respecting your rights and in accordance with the laws cited in the Preamble.
3. Identity and Contact Details of the Data Controller
The entity responsible for collecting and processing your personal data through the
Babylonelearning website and platform is one of the following companies, depending on
your country of residence or service use:
Algeria
Eurl SAK Academy
Address: Villa 82, Allée C, Bois des Cars 3, Dely Brahim, Algiers 16302
Email: [email protected]
European Union (
Ireland)
Euphrate Company Ltd
Address: POD 2 - The Old Station House, 15A Main Street, Blackrock, Dublin
Email: [email protected]
USA
Gate Ishtar LLC
Address: 90 Street, Suite 700, Office 40, Albany, New York 12207
Email: [email protected]
Each of the above-mentioned countries is subject to its own regulations regarding the
collection and processing of personal data.
4. Categories of Data Collected and Processed
We may collect various categories of personal data about you, depending on the nature and
purpose of the processing carried out.
In any case, we are committed to collecting and processing only the data strictly necessary
for the purposes described in this Policy.
The information we may collect includes, but is not limited to:
4.1. Learners (E-consumers)
a. User profile information
These data are collected when creating or updating the account. They may include:
● First and last name
● Email address
● Phone number
● Login ID and password
● Profile picture (optional)
b. Progress and usage data
Babylonelearning collects information related to your learning journey:
● Courses taken and modules accessed
● Grades, assessment results, certificates obtained
● Time spent on courses and learning progress
● Messages, comments, and interactions with trainers or other learners
c. Payment data
When a paid service is used, we collect:
● Transaction information (amount, date, payment method used)
d. Device-related data
We may collect certain technical information:
● Device model
● IP address or unique identifier
● Operating system and version
● Display language
2. Trainers / Instructors
a. Profile information
● First and last name, email address, phone number
● Login ID and password
● Professional address
● Profile picture
● Official documents (e.g., ID, diplomas, competency certificates)
● Banking information (for payment of services)
b. Content-related data
● Courses created, uploaded materials, videos published
● Usage statistics of courses (views, evaluations, learner feedback)
c. Device-related data
● Device model
● IP address or unique identifier
● Operating system and version
● Display language
3. Partners (institutional, commercial, or academic)
a. Business information
● Trade name / company name
● Address, phone number, professional email address
● Logo and description of services offered on the platform
b. Collaboration data
● Partnership history
● Participation statistics in training programs or events
● Administrative and contractual exchanges
c. Device-related data
● Device model
● IP address or unique identifier
● Operating system and version
● Display language
5. Purpose of Data Collection
Babylonelearning commits to using your data only within the scope of the platform and its
services, specifically to:
● Manage access to and use of online training services
● Ensure educational monitoring and learner progress
● Manage registrations, contracts, payments, and invoicing
● Maintain a file of registered users
● Send newsletters, informational messages, and promotional communications (with
the possibility to opt out)
● Produce usage and training evaluation statistics
● Collect and publish user feedback
● Manage potential disputes and unpaid invoices
● Comply with legal and regulatory obligations
● Personalize the user experience based on preferences
● Provide technical support and respond to contact requests
6. Data Sharing with Other Users
● Learners: certain profile data (first name, photo, progress) may be visible to trainers
and, in some cases, to other learners within forums or virtual classes.
● Trainers / Instructors: their profile (name, photo, bio, courses taught) may be visible
to learners.
● Partners: their identity and logo may be displayed when they offer training or events.
7. Legal Bases for Processing
The processing of your personal data is based on the following grounds:
● Contract execution (e.g., enrollment in a paid course)
● Legal obligation (e.g., invoice retention, tax obligations)
● Legitimate interest (platform improvement, security, fraud prevention)
● Consent (e.g., newsletter subscription, promotional communication)
8. Data Recipients
● Authorized Babylonelearning staff
● Our technical providers (payment solutions, email services)
● Our institutional and commercial partners, subject to your consent
● Competent public authorities, only within the framework of our legal obligations
9. International Data Transfers
The data collected by Babylonelearning may be processed in the countries where we
operate:
Algeria
United States
Ireland
European Union (if applicable)
Babylonelearning is committed to ensuring a level of protection equivalent to that required by
applicable regulations, regardless of the location of processing.
Some personal data may be transferred to affiliated companies, partners, or providers
located outside
Algeria (notably in
the United States,
Ireland, and the
European Union), in order to ensure:
● The provision of Babylonelearning services
● Their continuous improvement
● Their security
● Compliance with our legal obligations
These transfers are carried out with appropriate safeguards, in accordance with applicable
personal data protection laws in each jurisdiction. For certain sensitive data, your explicit
consent may be requested prior to any transfer.
You may exercise your rights of access, rectification, objection, and deletion of your personal
data at any time.
10. Retention Period of Personal Data
Babylonelearning retains your personal data only for the time strictly necessary to
achieve the purposes described in this policy. The retention period depends on the
type of data, the category of user concerned, and the purpose pursued.
● User management (learners, instructors, partners): data is kept for the duration of
the contractual relationship and until the expiration of the applicable statutory
limitation periods.
● Transaction and billing data: kept for the legal period required by tax and
accounting regulations.
● Statistics and audience data: kept for a maximum period of 24 months.
● Data related to marketing activities (newsletters, communications): kept until
you unsubscribe or withdraw your consent.
Users may request the deletion of their account at any time. Some data may be retained
beyond deletion, but only as required by legal, regulatory, or dispute-prevention obligations.
11. Security
Babylonelearning implements all necessary precautions as well as appropriate
organizational, technical, and administrative measures to preserve the security,
integrity, and confidentiality of your personal data.
These measures are designed to prevent:
● the alteration or accidental loss of your data,
● unauthorized access to your data,
● or disclosure to unauthorized third parties.
In the event of an intrusion, loss, or breach of personal data, Babylonelearning commits to
informing you within the required deadlines and implementing all necessary corrective
measures.
12. Cookies
Cookies are small text files stored on your browser when you use our website. They
help improve your user experience and facilitate your navigation.
12.1 Types of cookies used:
● Technical cookies (mandatory): used to ensure the proper functioning of the
website and platform (login, language selection, display, session tracking, forms).
They are essential for using the services and are retained for a maximum of 6
months.
● Analytical cookies (statistics): Babylonelearning may use tools such as Google
Analytics to measure site traffic (number of visits, pages viewed, session duration,
origin of visits). Your IP address may be collected in anonymized form to determine
the general connection location (city).
● Advertising cookies: currently, Babylonelearning does not use advertising cookies.
Should this change, you will be informed in advance and your consent will be
required, with the option to refuse them.
12.2 Managing cookies:
You can configure your browser to accept or refuse the storage of cookies. Refusing certain
cookies may, however, limit or prevent some features of the platform from functioning
properly.
13. Integration of Analysis and Feedback Tools in the
Platform
13.1 Integrated Tools
Among the solutions that may be used are, for example:
● Survey tools integrated into the platform, enabling contextual surveys to better
understand user expectations and experiences;
● Behavioral analysis solutions, allowing anonymized recording of usage sessions and
visualization of user paths via heatmaps.
These tools are deployed in compliance with confidentiality principles and data minimization.
13.2 Processing Objectives
The data collected through these tools aims to:
● Gather real-time qualitative feedback,
● Identify users’ priority needs,
● Detect friction points or areas for improvement in the user experience,
● Adapt user journeys and platform functionalities based on actual usage,
● Guide decisions regarding product development.
13.3 Purposes of Processing
The processing carried out is based on specific, explicit, and legitimate purposes, such as:
● Continuous improvement of user experience and interface design,
● Optimization of platform functionalities,
● Occasional deployment of integrated surveys to gather user opinions to guide
product evolution.
14. Consent
When you choose to provide your personal data, you expressly consent to
Babylonelearning collecting and using it in accordance with this policy and applicable
legislation in eligible countries (Algeria
, United States
, Ireland
, European
Union
).
You also expressly consent to the company:
● Sharing your data with its subcontractors, particularly regarding the signing of
electronic contracts carried out through secure online platforms,
● Sending you notifications of any kind (alerts, SMS, emails, or via messaging apps
linked to your phone number such as WhatsApp or Viber) from Babylonelearning.
If you no longer wish to receive such notifications, you may inform the company by writing to:
[email protected].
15. User Rights
15.1 Right of Access, Rectification, Objection, and Deletion
You have the right to obtain access to, rectification, or deletion of your personal data. Any
request must be sent to the following email address: [email protected].
It is recalled that any individual may, for legitimate reasons, object to the processing of their
personal data.
15.2 Right to File a Complaint
The user is informed of their right to lodge a complaint with the competent data protection
authority in their country of residence (
Algeria,
United States,
Ireland,
European Union).
However, it is recommended to first contact Babylonelearning at the email address provided
above in order to attempt an amicable resolution before making an official complaint.
16. Modifications
Babylonelearning reserves the right to amend this policy, subject to the applicable
laws in each of the eligible countries mentioned.
Such modifications will take effect upon their publication on the Babylonelearning website.
Continued use of our services after this date shall constitute acknowledgment and
acceptance of the new policy.
If you do not agree with these modifications, you must immediately cease accessing or using
our services.
17. Effective Date
This policy has been effective as of its publication date on the Babylonelearning website.
