Privacy Policy
1. About this policy
QPlayLearn is an online learning platform operated by Algorithmiq Oy. This policy explains how we collect and use personal data on buy.qplaylearn.com in connection with the shop and the purchase of, and access to, courses, and your rights under the GDPR and Finnish data protection law. qplaylearn.com has its own privacy policy. Analytics on qplaylearn.com are covered by that site’s privacy policy and the QPlayLearn Cookie Policy, not this policy.
It applies to visitors, account holders, and course purchasers using buy.qplaylearn.com. It replaces earlier QPlayLearn and QCards privacy policies.
2. Data controller
Algorithmiq Oy is the data controller: Algorithmiq Oy
Trading as: QPlayLearn
Registered office: Kanavakatu 3c, 00160 Helsinki, Finland
VAT: FI31319372
Business ID: FI31319372
Last updated: 19.10.2026
General contact email: contact@qplaylearn.com
We have not appointed a Data Protection Officer.
3. Data we collect and how we collect it
When you create an account, buy a course, or contact us through buy.qplaylearn.com, we may collect your first name and surname, email address, billing address, order details, purchase history, payment confirmation (transaction reference number), and information you provide in your message.
When you use a course, we collect course progress, completion, and certificate data. Articulate Reach 360 collects and hosts this course data.
When you use buy.qplaylearn.com, we automatically collect your IP address, browser type and version, device type and operating system, pages visited, and time spent on pages. We collect this information through cookies and server logs.
We get most personal data directly from you. We receive payment confirmation and the transaction reference from Revolut, and course progress, completion and certificate data from Articulate Reach 360.
4. Why we use your data
We process personal data only where Article 6 GDPR allows it. Our legal bases are:
Contract (Article 6(1)(b) GDPR)
We use your data to process orders and payments via Revolut, provide purchased courses, manage accounts, issue invoices and receipts, and provide customer support.
Providing order and billing data is needed to conclude the contract and meet accounting law. Without it, we cannot sell courses or give you access to them. Marketing data is optional.
Legal obligation (Article 6(1)(c) GDPR)
We use your data to meet Finnish accounting requirements and other applicable legal or regulatory requirements.
Legitimate interests (Article 6(1)(f) GDPR)
We use your data to keep buy.qplaylearn.com and the course service secure, prevent fraud and abuse, and improve our services and user experience, where these interests are not overridden by your interests or fundamental rights.
Consent (Article 6(1)(a) GDPR)
We use consent for marketing about QPlayLearn courses and offers. We ask for consent clearly and separately.
You can withdraw consent at any time by contacting contact@qplaylearn.com or using the unsubscribe link in a marketing email. Withdrawal does not affect earlier lawful processing.
5. Sharing and international transfers
We do not sell personal data. We share it only as needed with the following recipients:
Articulate Global LLC (United States) provides our learning management system (Rise 360 / Reach 360) and hosts course content and learner progress data. It acts as our data processor. The service is hosted in an EU data center. Any access from the United States relies on the EU-US Data Privacy Framework or Standard Contractual Clauses. A copy of the applicable safeguards is available from contact@qplaylearn.com.
Revolut processes card payments through checkout. It is an independent controller for its own regulatory and compliance purposes. We do not store or access card details. During payment, Revolut may set its own analytics and advertising cookies under its own policy. See Revolut’s privacy policy for more information.
We use n8n, which is self-hosted on our VPS, for workflows. Our VPS host, [VPS host name and location], acts as our data processor.
We share invoice and transaction data with Finnish tax authorities and our accountants as required by Finnish law.
The shop does not use analytics or advertising cookies.
We mainly process personal data in the EU/EEA. If data is transferred outside the EU/EEA, we use safeguards required by Chapter V GDPR.
Revolut operates within the EU/EEA. If it transfers data outside the EU/EEA, it must use appropriate safeguards. See Revolut's privacy policy for details.
6. Retention and security
We keep personal data only as long as needed for the stated purposes or required by law.
• Invoices and other accounting vouchers: retained for 6 years from the end of the financial year.
• Accounting books and financial statements: retained for [10] years.
• Course account data, including course progress, completion data, certificate data, and account details: retained for the 2-month course access period plus [X] months after access expires. If you repurchase a course, the data may be retained for longer.
• Marketing consent records: retained until you withdraw consent, plus a reasonable additional period for record-keeping purposes
• Support emails: retained for 12 months after the matter is closed.
• Server logs: retained for 12 montha.
• Checkout withdrawal consent records, including the timestamp and order number: retained for the limitation period of consumer claims.
After the applicable period, data is securely deleted or anonymised.
We use appropriate technical and organisational measures to protect personal data from unauthorised access, loss, destruction, or alteration. These include encryption in transit, access controls, a secure self-managed VPS for our WooCommerce store and n8n workflows, and regular security reviews.
No internet transmission is completely secure, but we take reasonable steps to protect your data.
7. Your rights and complaints
You can exercise your rights by contacting contact@qplaylearn.com. We respond within one month; we may extend this by two further months for complex or numerous requests and will tell you. Requests are free unless manifestly unfounded or excessive; in that case, we may charge a reasonable fee or refuse to act.
Access (Article 15 GDPR): You can ask whether we process your personal data and request a copy and information about its use.
Rectification (Article 16 GDPR): You can ask us to correct inaccurate data or complete incomplete data.
Erasure (Article 17 GDPR): You can ask us to delete your data in certain circumstances, including when it is no longer needed or you withdraw consent and no other legal basis applies.
Restriction (Article 18 GDPR): You can ask us to restrict processing in certain circumstances, such as while we verify accuracy or assess an objection based on legitimate interests.
Data portability (Article 20 GDPR): Where processing is based on consent or contract and automated, you can receive your data in a structured, commonly used, machine-readable format and transfer it to another controller.
Objection (Article 21 GDPR): You can object to processing based on legitimate interests. We will stop unless compelling grounds override your rights, or the processing is for legal claims.
Automated decision-making (Article 22 GDPR): You have the right not to be subject to a solely automated decision with legal or similarly significant effects. We do not currently use automated decision-making or profiling.
Withdrawal of consent (Article 7(3) GDPR): You can withdraw consent at any time. This does not affect earlier lawful processing.
To exercise your rights, email contact@qplaylearn.com. We may need to verify your identity.
Complaints
You can complain to the Finnish Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto) through tietosuoja.fi, or to the supervisory authority in the EU/EEA country where you live or work.
8. Cookies
The shop uses only strictly necessary cookies. Revolut sets its own cookies during payment under its own cookie policy. Full details are in the QPlayLearn Cookie Policy.
9. Changes to this policy
We may update this policy to reflect changes in our practices, services, or applicable law. We will post material changes on buy.qplaylearn.com and, where appropriate, email registered users.
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