GDPR Privacy Policy
Last updated: February 23, 2025
This Privacy Policy describes how Pleasante ("we", "us", or "our") collects, uses, stores, and protects personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable data protection laws. By using our platform and services available at pleasante.xyz, you acknowledge the practices described in this policy.
1. Data Controller
Pleasante acts as the data controller for personal data collected through its website and online learning platform. If you have questions regarding this policy or our data practices, you may contact us at:
Pleasante
710 Geylang Rd S(389625), Singapore
Email: help@pleasante.xyz
Phone: +6563562463
2. Personal Data We Collect
We collect personal data that you provide directly, data collected automatically during your use of our services, and data received from third parties where applicable.
2.1 Data You Provide
We may collect the following categories of personal data when you register, enroll in courses, or contact us:
| Category | Examples | Purpose |
|---|---|---|
| Identity Data | Full name, username, profile photo | Account creation and identification |
| Contact Data | Email address, phone number | Communication and notifications |
| Payment Data | Billing address, transaction references | Processing payments (card data handled by payment processors) |
| Educational Data | Enrollment records, progress, assessments | Delivering and improving learning services |
| Communications Data | Messages, support tickets, feedback | Customer support and service improvement |
2.2 Data Collected Automatically
When you access our platform, we may automatically collect:
- Technical data such as IP address, browser type and version, operating system, and device identifiers.
- Usage data such as pages visited, session duration, clickstream data, and feature interactions.
- Cookie and tracking data as described in our Cookie Policy.
3. Legal Basis for Processing
We process personal data only where a lawful basis exists. The applicable legal bases under GDPR Article 6 are:
| Legal Basis | When We Rely On It |
|---|---|
| Contract performance (Art. 6(1)(b)) | To provide the services you have enrolled in or purchased |
| Legitimate interests (Art. 6(1)(f)) | To improve our platform, ensure security, and conduct analytics |
| Legal obligation (Art. 6(1)(c)) | To comply with applicable laws and regulatory requirements |
| Consent (Art. 6(1)(a)) | For marketing communications and non-essential cookies |
Where we rely on consent as the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.
4. How We Use Your Personal Data
We use personal data for the following purposes:
- Service delivery: Creating and managing your account, enabling access to courses and live sessions, facilitating instructor interaction, and processing payments.
- Communication: Sending transactional notifications, course updates, technical alerts, and responding to support requests.
- Personalization: Adapting learning paths, recommendations, and content based on your preferences and progress.
- Security and fraud prevention: Monitoring for unauthorized access, protecting accounts, and maintaining platform integrity.
- Legal compliance: Meeting obligations under applicable laws, responding to lawful requests from authorities, and resolving disputes.
- Analytics and improvement: Understanding how users interact with our platform to enhance features and content quality.
5. Data Sharing and Disclosure
We do not sell your personal data. We may share personal data with third parties only in the following circumstances:
5.1 Service Providers
We engage carefully selected third-party processors who act on our behalf, including hosting providers, payment processors, email delivery services, analytics providers, and video conferencing tools. All processors are contractually bound to process data only on our instructions and in compliance with GDPR requirements.
5.2 Legal Requirements
We may disclose personal data when required to do so by law, court order, or regulatory authority, or when necessary to protect the rights, property, or safety of our users or the public.
5.3 Business Transfers
In the event of a merger, acquisition, or sale of all or part of our assets, personal data may be transferred as part of that transaction. We will notify affected users in accordance with applicable law.
5.4 With Your Consent
We may share data with third parties where you have provided explicit consent for specific sharing activities.
6. International Data Transfers
Where personal data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place, including standard contractual clauses approved by the European Commission or other transfer mechanisms recognized under GDPR. You may request details of the safeguards applicable to any specific transfer by contacting us.
7. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention principles are:
| Data Type | Retention Period |
|---|---|
| Account and profile data | Duration of account, plus up to 3 years after closure |
| Course and learning records | Up to 5 years after course completion |
| Payment and billing records | As required by applicable financial regulations |
| Support and communications | Up to 2 years after resolution |
| Marketing preferences and consent logs | Until consent is withdrawn, then 1 year |
After the applicable retention period, data is securely deleted or anonymized.
8. Your Rights Under GDPR
As a data subject under the GDPR, you have the following rights:
8.1 Right of Access
You have the right to request a copy of the personal data we hold about you and information about how it is processed.
8.2 Right to Rectification
You have the right to request correction of inaccurate or incomplete personal data.
8.3 Right to Erasure
You have the right to request deletion of your personal data in certain circumstances, including where the data is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis applies.
8.4 Right to Restrict Processing
You have the right to request that we limit the processing of your personal data in certain circumstances, such as while the accuracy of data is being contested.
8.5 Right to Data Portability
Where processing is based on consent or contract, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
8.6 Right to Object
You have the right to object to processing based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will cease processing immediately.
8.7 Rights Related to Automated Decision-Making
You have the right not to be subject to decisions made solely by automated processing that produce legal or similarly significant effects, unless you have provided explicit consent or such processing is necessary for a contract.
8.8 Exercising Your Rights
To exercise any of the above rights, please contact us at help@pleasante.xyz. We will respond within 30 days of receiving your request. We may need to verify your identity before processing the request. There is no charge for exercising your rights unless requests are manifestly unfounded or excessive.
9. Cookies and Tracking Technologies
Our platform uses cookies and similar technologies to ensure essential functionality, remember your preferences, analyze usage, and deliver relevant content. Cookies that are not strictly necessary are only set with your prior consent, which you may manage or withdraw at any time through our cookie preferences interface. For full details of the cookies we use and their purposes, please refer to our Cookie Policy.
10. Data Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, destruction, or alteration. These measures include encryption of data in transit and at rest, access controls and authentication requirements, regular security assessments, and staff training on data protection obligations. While we take all reasonable steps to safeguard your data, no method of transmission or storage is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and affected users without undue delay.
11. Children's Privacy
Our services are not directed at children under the age of 16. We do not knowingly collect personal data from individuals under 16 without verified parental or guardian consent. If you believe we have inadvertently collected data from a child, please contact us immediately and we will take steps to delete such data.
12. Third-Party Links and Services
Our platform may contain links to third-party websites or integrate with external services. This Privacy Policy applies only to our own processing activities. We are not responsible for the privacy practices of third-party sites and encourage you to review their respective privacy policies before providing any personal data.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When material changes are made, we will notify you by email or through a prominent notice on our platform prior to the change taking effect. The "Last updated" date at the top of this page indicates when the policy was most recently revised. Continued use of our services following notification of changes constitutes acceptance of the updated policy.
14. Complaints and Supervisory Authority
If you believe that our processing of your personal data violates applicable data protection law, you have the right to lodge a complaint with a competent data protection supervisory authority. We encourage you to contact us first at help@pleasante.xyz so that we may address your concern directly and promptly.
15. Contact Us
For any questions, requests, or concerns relating to this Privacy Policy or our data processing activities, please contact us:
Pleasante
710 Geylang Rd S(389625), Singapore
Email: help@pleasante.xyz
Phone: +6563562463
Website: pleasante.xyz