Privacy

Your privacy is paramount to Spring Technology. This Privacy Policy describes our policies and procedures on the collection, use, storage, and disclosure of your information when you use our Services and tells you about your privacy rights and how the law protects you. We are committed to creating online experiences that are private-by-design, secure-by-default, age-appropriate, and that put users in control of their information.

1. Introduction and Scope

This Privacy Policy applies to all information collected by Spring Technology (“Spring Technology,” “we,” “us,” or “our”) through our website ([www.springtechnology.com]), online courses, applications, and any related services, sales, marketing, or events (collectively, the “Services”).

We act as a ‘controller’ of the personal data collected through our Services. We never sell your personal information to anyone for any purpose. We do not give personal data to others for their own use without your permission. We hope you take some time to read through this Privacy Policy carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services.

2. Categories of Personal Data Collected

We collect various types of personal data from you, which may include, but is not limited to:

• Identification Data: Full name, address, date of birth, domicile, unique student IDs, profile picture.
• Contact Data: Email address, phone number, job titles, business email, business phone number.
• Employment and Education History: CVs, resumes, certifications, academic performance data (e.g., grades, course completion, scores, milestones), learning preferences, skills, LinkedIn profile, employment status, profession, technical specialty, years of paid work experience.
• Payment Details: Payment instrument number (e.g., credit card number), security code, billing address, purchase records.
• Usage Data: IP address, browser type, browser version, pages visited, time spent on platform, device identifiers, operating system, mobile network information, crash logs, referring/exit pages and URLs, preferences you submit, actions performed by site administrators/users, features enabled, screen size, cellular network, manufacturer.
• Communication Data: Information from surveys, support questions, forum posts, newsletter sign-ups, call recordings, messages, feedback, and interaction with chatbots.
• Audio/Visual Data: Image and voice on calls, webcam photos taken during coding assessments or online proctoring, metadata captured for calls.
• Publicly Available Information: Information from publicly accessible sources, such as social media profiles (e.g., LinkedIn, Meta/Facebook, Instagram, Whatsapp if used for login/contact).
• Diversity & Inclusion Data: Humanitarian status, diversity & inclusion data (collected with explicit consent for program analysis).

We collect personal information that you voluntarily provide to us when contacting us on the Website, expressing an interest in obtaining information about us or our products and Services, or when participating in activities initiated by us (such as events, webinars, or entering competitions). Other personal data results from your use of the Spring Technology Platform or attendance at events.

3. Purposes and Legal Bases for Data Processing

We process your personal data for the following purposes, relying on specific legal bases as required by applicable law:

Purpose of Processing	Type of Personal Data	Legal Basis
Providing and managing access to Spring Technology courses and services	Identification details, Contact details, Education and employment data, IP address, Payment data, Social media account information, Voice/Image (for onboarding/inquiries)	Performance of a contract with you
Program Recruitment & Selection	Identification details, Education and employment data, Publicly available personal information, Application data (jobs applied for, hiring status, voice/image for interviews, technical data)	User consent for entering the selection process; Performance of a contract for selected members
Delivering Spring Technology courses and admin & support activities	Identification details, Contact details, Learner performance data, Image and voice on calls, Parent/Guardian identification details (for progress updates)	Performance of a contract with you; Consent for sharing progress updates with parents/guardians
Commercial communication (marketing)	Identification details, Contact data, Technical skills, Employment and education data, LinkedIn account information, Program details, Graduation scores, Event attendance, Data on outreach/deliverability (advert engagement, website conversion actions, browsing patterns)	Legitimate interest for direct marketing to existing learners; Consent for new participants
Use of co-working spaces (hubs)	Identification details, Contact data, Education and employment data, Data collected when attending the hub (image, audio, booking/attendance)	Performance of a contract with you; Legitimate interests
Organizing marketing events and webinars	Identification details, Contact data, Education and employment data, Image (for marketing), IP/user logs	Legitimate interest for existing learners; Consent for new participants
Loyalty and rewards programs	Identification details, Data on activity in the community, Profile data, Technical data	Legitimate interest for growing the community
Feedback and Surveys	Identification details, Contact data, Education and employment data, Image/voice (for recorded meetings), Technical data, Learner preferences/satisfaction	User consent
Data analysis, statistics, and reporting	Identification details, Contact details, Humanitarian status, Diversity & inclusion data, Program analysis data, Platform engagement data, Outreach/deliverability data, User behavior	Legitimate interest; Learner consent for sensitive data
IT operations management, security, and technical issues	All personal data collected for Services	Compliance with law; Legitimate interest
Compliance with legal requests/obligations, or legal claims	All personal data collected for Services	Compliance with law; Legitimate interest
Reorganization of business (e.g., merger, acquisition)	All personal data collected for Services	Legitimate interest
Internal collaboration and communication	All personal data collected for Services	Performance of a contract; Legitimate interest

We do not collect any “special categories” of personal data as defined in the Data Protection Act 2017 (Mauritius) or the GDPR (European Union) unless explicitly provided with your consent for specific purposes (e.g., diversity & inclusion data).

4. User Rights: Access, Correction, Deletion, Portability, and Opt-Out

You have fundamental rights concerning your personal data. Spring Technology is committed to providing you with clear, actionable instructions on how to exercise these rights:

• Right to Access/Know: You can request a copy of the personal data we hold about you. We will respond to such requests within one month (for GDPR-related requests) or 45 days (for CCPA/CPRA-related requests).
• Right to Correction/Rectification: You can request corrections to inaccurate or incomplete personal data. You can often update your account information directly in your settings.
• Right to Deletion/Erasure (“Right to be Forgotten”): You can request the deletion of your personal data. While we will promptly delete data upon request, certain exceptions apply (e.g., data required for legal obligations, tax purposes, or legitimate business interests like fraud detection or transaction records). If deletion is not immediately possible (e.g., in backup archives), data will be securely stored and isolated until deletion is feasible.
• Right to Data Portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format, and have the right to transmit that data to another controller.
• Right to Object to Processing: You can object to certain types of data processing, particularly those based on legitimate interests or for direct marketing.
• Right to Opt-Out of Sale/Sharing: Under laws like CCPA/CPRA, you have the right to opt-out of the “sale” or “sharing” of your personal information for cross-context behavioral advertising. Spring Technology does not directly sell personal information for money. However, if any data sharing with advertising, marketing, or analytics vendors is considered a “sale” or “share” under certain US state privacy laws, an opt-out option will be available.
• Right to Withdraw Consent: If our processing relies on your consent, you have the right to withdraw that consent at any time. Please note that withdrawal might still allow processing if required by law or may affect service provision.

To exercise these rights, please contact us at [privacy@springtechnology.com] or through our dedicated online form at [link to your privacy request form, if applicable]. We may require you to verify your identity to process your request.

5. Data Sharing Practices with Third Parties

We may share your personal data with third parties in limited circumstances and with appropriate safeguards:

• Third-Party Vendors/Service Providers: We engage trusted third-party vendors, service providers, consultants, contractors, or agents to perform services on our behalf. These include providers for cloud storage (e.g., AWS), payment processing, analytics, customer support, email delivery, learning management systems, proctoring services, and certification bodies. These third parties are contractually bound not to reuse your personal data for their own purposes unless applicable privacy requirements are observed.
• Business Partners and Affiliates: We may share your information with affiliated companies or business partners for joint offerings, promotions, scholarships, admission requirements, or to fulfill specific services.
• Public Authorities and Legal Reasons: We may disclose your information to government agencies, law enforcement, or in response to legal processes (e.g., subpoenas, court orders) when legally required or to protect the rights, property, or safety of Spring Technology, our users, or the public.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity. We will ensure the confidentiality of your personal information and provide notice before it is transferred or becomes subject to a different privacy policy.
• Aggregated or De-identified Information: We may share non-personally identifiable information publicly and with our partners (e.g., publishers, advertisers, developers) to show trends about the general use of our services or for advertising and measurement purposes.

6. Data Security Measures and Retention Periods

Spring Technology implements robust technical and organizational measures to protect your personal data from unauthorized access, use, alteration, or destruction. These measures include:

• Encryption: Protecting data both in transit (e.g., SSL certificates) and at rest.
• Access Controls: Implementing role-based access controls, multi-factor authentication (MFA), and complex password requirements, limiting access to personal data only to authorized personnel on a “need-to-know” basis.
• System Monitoring: Automated logging of user access and security tools/procedures to detect and prevent unauthorized access.
• Regular Assessments: Conducting regular vulnerability assessments and security audits.
• Data Backup: Implementing regular data backup procedures, including remote storage where necessary.
• Staff Training: Providing ongoing training to employees on data security protocols and privacy regulations.

While we strive for 100% security, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, we cannot guarantee absolute security.

We retain your personal data only as long as necessary for the purposes for which it was collected, or to comply with legal and regulatory retention requirements (e.g., for audit, accounting, statutory terms, or handling legal claims). Generally, personal information will not be kept longer than 90 days past the termination of your account without further negotiations or agreement. When there is no ongoing legitimate business need, data will be deleted, anonymized, or securely stored and isolated if immediate deletion isn’t possible.

7. Children’s Privacy

Spring Technology’s Services are not directed to children younger than 16 years of age. We do not knowingly solicit data from or market to children under 16 years of age. If you are under 16 years old, please do not register to use the Services or provide any personal information to us.

If we learn that personal information from users less than 16 years of age has been collected without verifiable parental consent, we will take reasonable measures to promptly deactivate the account and delete such data from our records. If you believe your child has provided us with personal data without your consent, please contact us immediately at [privacy@springtechnology.com].

For users under 18 residing in California, you may have the right to request removal of unwanted publicly posted data you have shared. We will ensure such data is not publicly displayed, but complete removal from all systems is not guaranteed.

8. Use of Cookies and Other Tracking Technologies

We use cookies, web beacons, pixel tags, local storage, and other tracking technologies to collect information about your activity on our Services. This helps us identify you, track usage, remember your preferences, measure email campaign effectiveness, and provide targeted ads (where applicable and with your consent).

Cookies are small files placed on your device. We categorize them as:

• Strictly Necessary Cookies: Essential for website functionality and usually always active.
• Functional Cookies: Enable tailored experiences, such as remembering language preferences.
• Performance Cookies: Help us understand user interaction and improve service operation (e.g., Google Analytics).
• Targeting Cookies: Used for advertising purposes, often to deliver personalized ads. Spring Technology uses targeting cookies only on pages directed to adults (e.g., for marketing to potential students or partners) and explicitly states they are not used to serve third-party ads to students within the learning environment.

You can manage your cookie preferences through our “Privacy Preference Center” or cookie consent manager, typically accessible via a banner or link in the website footer. You can also set your browser to reject cookies, though this may affect certain features of our Services.

9. International Data Transfer Considerations

Spring Technology operates globally, and your personal data may be processed, stored, and accessed in countries outside of your country of residence, including the United States of America, where our central database is held. Data may also be sent to other Spring Technology offices or local hubs in various countries where we operate.

For international data transfers, we implement appropriate safeguards to ensure your data is protected, such as:

• Standard Contractual Clauses (SCCs): Contractual agreements approved by regulatory bodies (e.g., the EU Commission) that impose data protection obligations on the data importer.
• Data Privacy Framework (DPF) Certification: Participation in frameworks like the EU-U.S., Swiss-U.S., and UK Extension to the EU-U.S. Data Privacy Framework Principles, which provide a legal basis for data transfers to certified entities in the US.

By using our Services, you consent to the transfer of your information to these countries.

10. Strategies for Transparency and User Control

We are committed to transparency and providing you with control over your personal information:

• Clear Language: This Privacy Policy is written in plain, understandable language, avoiding complex legal jargon wherever possible.
• Accessibility: This Privacy Policy is easily accessible from all pages of our website, typically linked prominently in the website footer. It is also linked at every point where personal data is collected, such as during account registration, at login, and on payment forms.
• Regular Updates: We commit to regularly reviewing and updating this Privacy Policy to reflect changes in applicable laws, data processing practices, or service offerings. The “Last Updated” date at the top of this policy indicates the latest version. Material changes will be notified by prominent posting on our website or direct notification.
• Contact Information: We provide clear and accessible contact details for privacy-related questions, data rights requests, and complaints.

11. Complaints

If you have any complaints about Spring Technology’s use of your personal data, please contact us first at [privacy@springtechnology.com]. If you are still unsatisfied, you may have the right to lodge a complaint with your local data protection regulator or supervisory authority, depending on your jurisdiction.

12. How to Contact Us

For any questions regarding this Privacy Policy or to exercise your privacy rights, please contact us:

• Email: [admin@springtechnology.com]

Phone: [+2348114432440]