गोपनीयता नीति

§1. General provisions

1. This Privacy Policy sets out the rules for processing the personal data of persons using the SplitTeach platform, including Students, Educators and visitors to the Platform.
2. This Privacy Policy is a document separate from the SplitTeach Platform Terms of Service.
3. SplitTeach places particular importance on protecting Users' privacy and processes personal data in accordance with applicable law, in particular: a) Regulation (EU) 2016/679 of the European Parliament and of the Council ("GDPR"); b) the Personal Data Protection Act; c) the Act on the Provision of Electronic Services; d) rules on electronic communications and cookies; e) other applicable provisions relevant to SplitTeach's business.
4. Under the current MVP model, SplitTeach does not use SplitCoin (SCC), the SplitStars feature, or a separate mode for younger Students (SplitKids). This Policy describes only the processing of data related to the functionalities currently available on the Platform.

§2. Data controller

The controller of the personal data processed in connection with the use of the Platform is:

Where, in connection with a specific service or legal relationship, another entity is the controller of the data (in particular an Educator – in accordance with §6, §7 and §8), the User will be informed of this accordingly.

§3. What data we may process

Depending on how the Platform is used, SplitTeach may process, in particular:

1. Account data – first and last name; e-mail address; username; profile picture, if the User adds one; information contained in the profile; data necessary to secure the Account.
2. Educator data – identification data; business data; tax ID, company registration number or other identifiers; data required for verification; information about the Educator's business; data required by the Payment Operator; billing information.
3. Data on the use of the Platform – IP address; device information; browser type and version; operating system; information about activity on the Platform; dates and times of use; information about errors and technical events; technical identifiers.
4. Transaction data – information about a completed Transaction; the amount; the date; information about the purchased Offer; payment status; information necessary to handle a refund or complaint. As a rule, SplitTeach does not receive full payment card numbers where payment data is processed directly by an external Payment Operator.
5. Communication data – if the User uses the Chat or other communication features: message content; sender and recipient data; the date and time of the message; technical information related to the communication.
6. Live-related data – camera video; voice; the User's statements; information about participation in a class; technical connection data; information related to screen sharing. This data is processed only in real time and is not recorded or stored by SplitTeach after the class ends – see §9 for details.
7. Guardian data – for a minor Student: the Guardian's first and last name, contact details, and the content and date of the consent given for the minor to use the Platform and enter into Transactions, in accordance with §20.
8. Comment-related data – the content of the comment, the author's data, the date and time of publication, and – if reported – data relating to the report and how it was handled.

§4. Purposes of processing

Personal data may be processed for the purpose of:

• creating and maintaining an Account
• enabling use of the Platform
• enabling the purchase of Courses and Live classes
• enabling Educators to offer services
• handling payments
• processing refunds
• handling complaints
• ensuring the security of the Platform
• preventing fraud and abuse
• ensuring the proper functioning of Live classes
• enabling communication between Users
• handling User reports
• compiling statistics and analysing use of the Platform
• improving the Platform's functionality
• asserting or defending against claims
• fulfilling legal obligations
• maintaining accounting records and documentation required by law
• verifying Guardian consent and administering minor Students' Accounts
• carrying out marketing activities – where there is an appropriate legal basis
• sending commercial information – where the User (or, for a minor under 16, their Guardian) has given the required consent

§5. Legal bases for processing

Depending on the purpose, SplitTeach may process data on the basis of:

1. Performance of a contract – Article 6(1)(b) GDPR – applies in particular to: maintaining the Account; providing the Platform's services; processing purchases; handling Live classes; handling complaints related to the performance of a contract.
2. Legal obligation – Article 6(1)(c) GDPR – in particular regarding: accounting obligations; taxes; obligations arising from law; exercising the rights of data subjects.
3. Legitimate interest – Article 6(1)(f) GDPR – in particular for the purpose of: ensuring the security of the Platform; preventing fraud; asserting and defending against claims; carrying out analyses and statistics; ensuring the proper functioning of the Platform.
4. Consent – Article 6(1)(a) GDPR – in cases where the law requires consent, SplitTeach processes data on the basis of the User's freely given consent. Consent may be withdrawn at any time; withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

If the User is a person who has not turned 16, this consent requires confirmation by the Guardian, in accordance with Article 8 GDPR and §20 of this Policy.

§6. Educators' data

SplitTeach may process Educators' data for the purpose of: a) creating the Educator's profile; b) verifying identity and status; c) enabling the sale of services; d) handling payments; e) settling Commission; f) preventing fraud; g) fulfilling legal obligations.

Where Stripe's services are used, an Educator's data may be shared with Stripe to the extent necessary to create and operate a Connected Account and to handle payments. The Educator may be subject to additional verification processes required by the Payment Operator.

As regards grades, notes and other information about a Student created independently by an Educator in the course of teaching or assessing progress (e.g. comments on assignments, grades, opinions), the Educator is the controller of that data. In this respect, SplitTeach acts as a processor on the Educator's behalf (hosting the infrastructure), on the terms set out in a separate data processing agreement entered into with Educators.

§7. Payments and Stripe

1. SplitTeach may use Stripe's services as a Payment Operator.
2. Data necessary to process payments may be shared with Stripe.
3. Stripe may process Users' data in accordance with its own data-protection rules, acting in this respect as an independent controller, in particular in relation to compliance with anti-money-laundering rules.
4. Where Stripe Connect is used, an Educator's data may be processed for the purpose of creating and operating a Connected Account.
5. SplitTeach may receive information about the status of payments, Transactions, refunds, chargebacks and other payment events necessary for the Platform to function.
6. SplitTeach does not store full payment card data where a payment is processed through Stripe's infrastructure.

§8. Live classes, camera, microphone and screen sharing

Using Live classes may require access to: a) the camera; b) the microphone; c) speakers; d) the device's screen – when using the screen-sharing feature. Access to the camera, microphone or screen requires the appropriate permission on the User's device or browser.

The status of the controller for the video and audio transmitted during Live classes has not yet been finally determined and depends on how the transmission is technically implemented. Under Article 26 GDPR, joint controllership only exists where two entities jointly determine the purposes and means of processing – SplitTeach merely providing the transmission infrastructure while the Educator conducts the class does not automatically decide this. Before finally settling the model, SplitTeach will determine in particular: whether the video and audio are only "passed through" in real time, or stored to any extent; who decides whether recording is switched on; who sets the retention period; and who has access to a recording and can delete it. Depending on the answers to these questions, the controller may be SplitTeach, the Educator (with SplitTeach as a processor), or both parties as joint controllers. The final model, together with the material terms of any joint-controller arrangement, will be described in an update to this Policy before the Live feature is fully launched.

Live classes are not recorded under the current MVP model – see §9 for details.

§9. Recording of Live classes

1. Under the current MVP model, Live classes are not recorded – either by SplitTeach or by the Educator. Video, voice and other data transmitted during a Live class are transmitted only in real time between the participants and are not stored or retained by SplitTeach after the class ends.
2. Because the data is not stored, no separate personal-data set in the form of a recording is created, and accordingly no retention period other than the duration of the transmission itself applies to it.
3. If SplitTeach introduces a Live-recording feature in the future, this will require a separate update to this Policy before it is made available, covering in particular: the controller of the recording, the legal basis, the purpose, the scope of data and the retention period, and – where appropriate – a data protection impact assessment (DPIA) under Article 35 GDPR, given the participation of Students from age 13 in the classes.
4. The User should bear in mind that content transmitted in real time during a Live class (video, audio, a shared screen) is visible to the other participants in the class.

§10. Chat

SplitTeach may allow Users to hold conversations via an internal Chat. For the purposes of the current MVP model, SplitTeach acts as the controller of the data processed within the Chat, to the extent necessary to provide this feature and to ensure the security of the Platform – and not merely as a technical infrastructure provider. This model is adopted to give Users clarity about whom they can address with requests concerning their data, without the need to establish each party's separate responsibility for their own messages in a conversation.

1. Message content may be processed for the purpose of: providing the Chat feature; ensuring security; preventing abuse; handling reports; asserting or defending against claims.
2. SplitTeach retains information relating to communications for as long as the Account exists and for the period necessary to handle disputes, taking applicable law into account.
3. SplitTeach does not use the content of Users' private communications for marketing purposes, unless there is an appropriate legal basis.

§11. Cookies

1. SplitTeach may use cookies and similar technologies.
2. Cookies may be used in particular to: ensure the Platform functions; maintain a User's session; remember settings; ensure security; analyse use of the Platform; carry out marketing activities – where the User has given the appropriate consent.
3. Cookies necessary for the Platform to function may be used without consent, where their use is necessary to provide the requested service.
4. Analytics, advertising or other cookies requiring consent will be used in accordance with applicable law and the User's settings, in accordance with the mechanism described in §20 for Users under 16.
5. The User may manage cookies via their browser settings and the consent-management mechanism on the Platform.
6. Detailed information about the cookies used – including the name, provider, purpose, status (necessary/requiring consent) and retention period of each cookie – is set out in a separate Cookie Policy.

§12. Analytics

SplitTeach may use analytics tools to study how the Platform is used, in particular to: measure traffic; detect errors; improve functionality; study the popularity of features; optimise the Platform. Analytics tools requiring consent will only be activated in accordance with the User's consent settings.

§13. Marketing

1. SplitTeach may carry out marketing activities relating to its own services. Electronic marketing communications will be conducted in accordance with applicable law.
2. Where sending a particular type of communication requires consent, SplitTeach will obtain the appropriate consent – for a User under 16, the Guardian's consent, in accordance with §20.
3. The User may unsubscribe from marketing electronic messages at any time, using the unsubscribe feature available in the message or by contacting SplitTeach.

§14. Recipients of data

Personal data may be transferred or made available to:

• hosting and IT infrastructure providers
• security service providers
• communication service providers
• analytics service providers
• marketing service providers – where used
• payment operators, in particular Stripe
• accounting and legal service providers
• providers of technical support services
• public authorities, where the obligation to disclose data arises from law
• other entities, where necessary to provide a given service and where there is an appropriate legal basis

§15. Transfers of data outside the European Economic Area

1. Some service providers used by SplitTeach may process data outside the European Economic Area.
2. In such a case, SplitTeach ensures an appropriate legal basis for the data transfer in accordance with the GDPR, which may include in particular: a European Commission adequacy decision; standard contractual clauses; other mechanisms provided for by the GDPR.
3. A list of the main providers and information about the mechanisms used may be set out in an additional provider table available on the Platform.

§16. Data retention period

1. SplitTeach retains personal data for the period necessary to achieve the purpose for which it was collected.
2. Account data is retained for as long as the Account is active.
3. After an Account is deleted, some data may be retained for the period required by: applicable law; tax and accounting obligations; the need to handle complaints; asserting or defending against claims (as a rule, the statute-of-limitations period for claims, 6 years); ensuring the security of the Platform.
4. Transaction data and accounting documentation are retained for 5 years from the end of the tax year, in accordance with the Tax Code and the Accounting Act.
5. Live classes are not recorded under the current MVP model, so no separate retention period applies to recordings – see §9.
6. Technical data and security logs are retained for up to 24 months, unless a longer retention period is necessary to investigate a security incident.
7. After the relevant period has elapsed, data is deleted or anonymised, unless its further retention is required by law.

§17. Data security

SplitTeach applies appropriate technical and organisational measures aimed at protecting personal data, including in particular: encryption of transmissions; access control; authentication mechanisms; security monitoring; backups; IT infrastructure safeguards; incident-response procedures. Access to data is granted only to persons or entities that need it to perform specific tasks.

§18. User rights

Users have the rights arising from the GDPR, in particular:

• the right of access to data
• the right to rectify data
• the right to erasure of data
• the right to restrict processing
• the right to data portability
• the right to object to processing based on a legitimate interest
• the right to withdraw consent, where processing is based on consent
• the right to lodge a complaint with a supervisory authority

For a minor Student under 16, the above rights relating to consent-based processing may be exercised by the Guardian, in accordance with §20.

§19. Right to erasure of data

1. The User may delete their Account themselves at any time in Settings, without contacting SplitTeach. Deletion takes effect immediately and cannot be reversed.
2. On deletion, the User's profile data is erased, the content they published is removed, and all of their sign-in methods are revoked. Data on which other Users depend - in particular courses with enrolled Students, messages and comments - is retained, with its author shown as a deleted user.
3. The User may request the erasure of their data.
4. This right is not absolute.
5. SplitTeach may refuse to erase certain data where its further retention is required by law or necessary to establish, assert or defend against claims.
6. Deleting an Account does not necessarily mean the immediate deletion of all data related to earlier Transactions.

§20. Children and minors

1. Persons who have turned 13 may use the Platform in the role of Student, in accordance with §5 of the Platform Terms of Service. The Platform does not currently offer a separate mode of use for younger persons.
2. Persons aged 13 to 18 may use the Platform and enter into Transactions only with the Guardian's consent, given in accordance with §5 of the Platform Terms of Service – this threshold relates to the validity of the contracts entered into, in accordance with the Civil Code's rules on limited legal capacity.
3. Regardless of the above, where the processing of personal data is based on the User's consent (Article 6(1)(a) GDPR) – in particular consent to e-mail marketing and to cookies and analytics requiring consent – and the User has not turned 16, such consent requires expression or confirmation by the Guardian, in accordance with Article 8 GDPR. This also applies to Users aged 13–16, for whom the contract to use the Platform itself may be valid under the general rules on legal capacity.
4. In practice, this means that for Users aged 13–16, consent-based features (e-mail marketing, cookies and non-essential analytics) remain switched off by default until confirmed by the Guardian, regardless of whether the Guardian has already confirmed consent to the use of the Platform itself and to entering into Transactions.
5. SplitTeach reserves the right to verify the Guardian's consent, including by contacting the Guardian.
6. SplitTeach may restrict the ability to use certain features to persons who meet the applicable age requirements.

§21. Profiling and automated decisions

1. SplitTeach may use data to personalise how content and Offers are presented, to the extent permitted by law.
2. Where profiling is used whose nature requires additional notice to the User, the relevant information will be presented on the Platform.
3. SplitTeach will not make decisions about the User based solely on automated processing that produce legal effects concerning them, or similarly significantly affect them, unless an exception provided for by law applies.

§22. Changes to the Privacy Policy

1. SplitTeach may update the Privacy Policy in particular in the event of: changes in law; changes to the Platform's functionality; the introduction of new services; changes of service providers; technological changes; changes to how data is processed.
2. Users will be informed of material changes accordingly.
3. The current version of the Privacy Policy will be available on the Platform.

§23. Contact regarding data protection

For matters relating to the processing of personal data, SplitTeach can be contacted at:

If SplitTeach appoints a Data Protection Officer, their contact details will be provided in this Privacy Policy and on the Platform.

§24. Right to lodge a complaint

The User has the right to lodge a complaint with the competent supervisory authority if they consider that the processing of their personal data infringes data-protection law. The supervisory authority competent in Poland is the President of the Personal Data Protection Office (UODO). The supervisory authority's contact details are available on its official website.

§25. Final provisions

1. This Privacy Policy applies from the date it is published on the Platform.
2. The Privacy Policy is available on the Platform in a way that allows it to be saved and recorded.
3. Matters not regulated by this Policy are governed by applicable law.
4. Where specific Platform features require additional information about data processing, SplitTeach may present the User with additional information notices before those features are used.