Educate.me sarl-s Privacy Policy

Last updated: 7 August 2026

1. Introduction
Educateme, S.à r.l. ("Educateme", "we", "us" or "our") is committed to protecting personal data and respecting the privacy of Students, Customers, website visitors and other people who interact with us.

This Privacy Policy explains how we collect and use personal data when you:
  • Visit our website;
  • Contact us or submit an enquiry;
  • Request or attend a trial or placement lesson;
  • Enrol in or pay for a course;
  • Participate in an individual or group lesson;
  • Use our learning platform or course materials;
  • Access a lesson recording;
  • Communicate with our teachers or staff;
  • Receive another educational or administrative service from Educateme.
It also explains the legal bases we rely on, the people and service providers who may receive personal data, how long data is kept and the rights available under the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Luxembourg data-protection law.
This Privacy Policy is intended to provide information about our processing. Where a particular processing activity requires consent, consent is requested separately and is not created merely by acknowledging this Policy.

2. Data Controller
The controller responsible for the processing described in this Privacy Policy is:
Educateme, S.à r.l. RCS Luxembourg: B266753
Registered address: 45, Rue de Wormeldange L-6955 Rodenbourg Luxembourg
General contact: info@educateme.lu
Data Protection Contact
For data-protection questions and requests, you may contact:
Ilia Ostretsov Email: ilia.ostretsov@educateme.lu

3. Personal Data We May Process
The personal data we process depends on your relationship with Educateme and the services you use.

3.1 Identity and Contact Data
This may include:
  • First and last name;
  • Email address;
  • Mobile or other telephone number;
  • Residence address;
  • Country or place of residence;
  • Account or videoconferencing display name;
  • Parent or legal guardian details where relevant;
  • Employer or organisation details where training is arranged by a business or other organisation.
3.2 Language, Course and Learning Data
This may include:
  • The language or languages you speak;
  • The language you would like to learn;
  • Your current, estimated or assessed language level;
  • Course selection and course format;
  • Scheduling preferences;
  • Placement-test or trial-lesson information;
  • Learning goals and relevant preferences;
  • Tutor or group allocation;
  • Homework, exercises, assessments and feedback;
  • Course progress;
  • Attendance information;
  • Information needed to issue an attendance certificate or another course document.
3.3 Payment and Transaction Data
This may include:
  • Billing name and address;
  • Amounts charged and paid;
  • Invoice information;
  • Payment status;
  • Instalment schedule;
  • Refund information;
  • Payment method;
  • Transaction identifiers;
  • Limited card-related or bank-related information returned to us by a payment service provider.
Where a specialist payment provider such as Stripe processes payment-card credentials directly, Educateme does not store the full card number, card security code or other full payment-card credentials handled by that provider.

3.4 Communications and Customer-Service Data
This may include communications sent or received through:
  • Email;
  • Telephone;
  • WhatsApp or another messaging service;
  • Website or enrolment forms;
  • CRM and customer-support systems;
  • Communications with teachers relating to the organisation or delivery of a course.
We may also keep reasonable records of requests, complaints and actions taken to resolve them.

3.5 Online Lesson Data
When you participate in an online lesson, we may process information including:
  • Your registered name and display name;
  • Live voice;
  • Live video image when your camera is used;
  • Chat messages;
  • Questions, answers and other lesson contributions;
  • Joining and leaving times;
  • Responses to attendance checks;
  • Attendance status;
  • Limited teacher observations necessary to record participation or resolve an attendance question;
  • Technical meeting, device, connection or security information made available by the videoconferencing platform.
3.6 Lesson Recording Data
Where recording access forms part of a group course, a recording may include:
  • The teacher's image and voice;
  • Teaching materials;
  • Shared screens;
  • A Student's display name;
  • A Student's voice;
  • A question, answer or other lesson contribution;
  • A chat contribution;
  • In some circumstances, a brief Student video image.
Educateme seeks to minimise unnecessary capture of Student video and private surroundings, as explained in Sections 7 and 8 below.

3.7 Website, Device and Tracking Data
Depending on the functionality used and your cookie choices, we may process:
  • IP address;
  • Browser type and version;
  • Device type and operating system;
  • Website pages or functions used;
  • Referring page or campaign information;
  • Cookie or similar identifiers;
  • Security, error and diagnostic logs;
  • Information entered into website forms.
Non-essential analytics or advertising technologies are subject to the consent rules described in Section 17.

3.8 Data Concerning Children
Educateme provides certain educational services to children as well as adults.
Where a Student is a minor, we may process information relating to:
  • The child;
  • The child's course, level, participation and progress;
  • The parent or legal guardian;
  • Scheduling, communication and billing arrangements.
Children's data receives additional protection as described in Section 12.

3.9 Accessibility, Health and Other Sensitive Information
A Student may choose to tell Educateme about a technical, accessibility, disability, health or other personal circumstance in order to request an appropriate arrangement.

We ask Students not to provide a diagnosis or detailed medical information unless it is genuinely necessary for the requested arrangement.

If information falling within a special category of personal data under Article 9 GDPR is processed, Educateme will do so only where an appropriate Article 9 condition and an Article 6 legal basis apply, and will limit access and retention appropriately.

4. Where Personal Data Comes From
We normally obtain personal data:
  • Directly from you;
  • From a parent or legal guardian;
  • From an employer or organisation arranging training on your behalf;
  • Through our website, enrolment forms or learning platform;
  • From teachers and course administration in connection with lessons and attendance;
  • From videoconferencing, communications and technical platforms used for the service;
  • From our payment provider;
  • From public authorities where relevant to an official programme or administrative request.
  • From advertising platforms where you submit a lead or enquiry form hosted by that platform.

Where an employer or another organisation enrols a Student, we may receive information such as the Student's name, business contact details, requested training and administrative information necessary to organise the course.

5. Purposes and Legal Bases for Processing
Educateme identifies an appropriate legal basis before processing personal data. The applicable basis depends on the purpose and the circumstances.

5.1 Enquiries, Trial Lessons and Pre-Contractual Steps
We use contact, language and course information to:
  • Respond to enquiries;
  • Organise a trial or placement lesson;
  • Understand training requirements;
  • Assess an appropriate course level or format;
  • Prepare an offer or enrolment.
Where these steps are taken at your request with a view to entering into a contract, the legal basis is normally Article 6(1)(b) GDPR.

5.2 Providing and Administering the Course
We process information necessary to:
  • Enrol the Student;
  • Schedule lessons;
  • Allocate teachers and groups;
  • Provide live educational services;
  • Provide feedback and learning materials;
  • Operate the learning platform;
  • Communicate about the course;
  • Manage the contractual relationship.
The legal basis is normally Article 6(1)(b) GDPR, to the extent the processing is objectively necessary to perform the contracted service.
The fact that a processing activity is mentioned in a contract does not by itself make that processing necessary for contract performance. Where processing is not objectively necessary for the contract, Educateme uses another legal basis where appropriate.

5.3 Payments, Invoicing and Accounting
We process payment and transaction information to:
  • Collect course payments;
  • Manage instalments;
  • Issue invoices and receipts;
  • Process refunds;
  • Maintain financial records;
  • Comply with accounting, tax and related obligations.
Depending on the activity, the legal basis is normally:
  • Article 6(1)(b) GDPR for processing necessary to perform the payment aspects of the contract; and/or
  • Article 6(1)(c) GDPR where processing is required to comply with a legal obligation.
5.4 Attendance Verification and Certificates
We process attendance-related data to:
  • Maintain accurate course records;
  • Confirm whether the registered Student is participating;
  • Distinguish actual attendance from a technical connection to a meeting;
  • Prevent unauthorised attendance or account sharing;
  • Issue accurate attendance certificates and confirmations;
  • Support training-related, nationality-related or reimbursement documentation where applicable;
  • Resolve attendance disputes or questions.
Depending on the specific processing, the legal basis may be:
  • Article 6(1)(b) GDPR, where a reasonable level of attendance verification is objectively necessary for the requested course or certificate service;
  • Article 6(1)(f) GDPR, for Educateme's legitimate interests in maintaining reliable attendance records, protecting paid course access, preventing misuse and protecting the integrity of certificates, where the necessity and balancing requirements are satisfied;
  • Article 6(1)(c) GDPR, where a particular record or verification procedure is required by an applicable legal obligation.
Where Educateme relies on legitimate interests, it considers whether the purpose can reasonably be achieved just as effectively by a less intrusive method and balances the relevant interests and rights before relying on that legal basis.

5.5 Live Camera Use
When a Student activates a camera during a live lesson, the Student's image is processed by the videoconferencing service and is visible to the teacher and, in a group lesson, other participants according to the meeting configuration.

Camera use may support:
  • Interactive teaching and communication;
  • Visual feedback;
  • Speaking, presentation or group activities;
  • A proportionate identity or attendance check where appropriate.
The legal basis depends on the context. Ordinary interactive use may form part of delivering the requested educational service under Article 6(1)(b) GDPR where objectively necessary. A limited camera check for attendance, course security or prevention of access sharing may be based on Article 6(1)(f) GDPR where Educateme has a legitimate interest and the necessity and balancing requirements are met.

Educateme does not impose continuous camera activation throughout every part of every lesson. Where an appropriate less intrusive attendance-verification method is sufficient, that alternative may be used.

Educateme does not use facial-recognition technology or automated biometric identification for ordinary lesson attendance.

5.6 Lesson Recordings
Where recording access is an included feature of a group course, Educateme records lessons for the educational purpose of making lesson content available to Students entitled to access that course.

Where reasonably and technically possible, ordinary recordings are configured to focus on the teacher, shared screen and teaching materials rather than on Student video feeds.
Processing of the teacher, teaching materials and the technical recording needed to provide the included replay service may be based on Article 6(1)(b) GDPR where objectively necessary to provide that contracted feature.

If a Student's display name, voice, contribution or brief image is incidentally included, Educateme will minimise such data and will rely on an appropriate legal basis for that processing, which may include Article 6(1)(f) GDPR where Educateme's legitimate interest in providing the limited-access educational recording is necessary and not overridden by the Student's rights.
Where a particular recording use requires consent or another specific legal basis, Educateme will obtain or identify that basis before the use takes place.

Participation in an ordinary lesson is not treated as blanket consent to use a Student's identifiable image, voice or contribution for advertising, testimonials, public social media or another unrelated promotional purpose.

5.7 Course Security, Fraud Prevention and Protection of Rights
We may process account, meeting, payment and technical information to:
  • Protect course access;
  • Protect Students, teachers and systems;
  • Investigate unauthorised participation or account sharing;
  • Prevent or investigate fraud or misuse;
  • Maintain information and network security;
  • Establish, exercise or defend legal claims.
Where applicable, the legal basis is normally Article 6(1)(f) GDPR, subject to the required legitimate-interest, necessity and balancing assessment, or Article 6(1)(c) GDPR where a legal obligation applies.

5.8 Legal and Administrative Requirements
We may process personal data where necessary to:
  • Comply with applicable law;
  • Respond to a competent public authority;
  • Comply with accounting, tax or other record-keeping obligations;
  • Administer an approved training programme;
  • Establish, exercise or defend legal claims.
The legal basis may include Article 6(1)(c) GDPR or Article 6(1)(f) GDPR, depending on the circumstances.

5.9 Marketing and Information About Our Services
We may use contact information to inform people about Educateme courses, products or services where applicable law permits us to do so.

Where consent is required, marketing is based on Article 6(1)(a) GDPR and the relevant electronic-marketing rules. Marketing consent is separate from ordinary course enrolment and may be withdrawn at any time.

Where applicable law permits a different legal basis for a particular communication, we will provide any required right to object or opt out.

A person is not required to agree to unrelated marketing in order to purchase an ordinary Educateme course.

5.10 Cookies, Analytics and Advertising Technologies

Where consent is required for a non-essential cookie or similar technology, the relevant processing is carried out only after the required consent has been obtained.
More information is provided in our Cookie Policy and cookie-management interface.

6. Attendance Verification in Practice
Educateme distinguishes between a Student being technically connected to an online meeting and attendance that can reasonably be verified.

Depending on the lesson and purpose, verification may include:
  • A response by microphone;
  • A response in chat;
  • Participation in an exercise or discussion;
  • A brief camera check;
  • A brief individual check;
  • Meeting joining and leaving times;
  • Limited teacher observations relating to participation.
Camera use is not normally the sole method of verifying ordinary attendance.

A Student will not be treated as absent solely because the camera is switched off where attendance can reasonably be established through another appropriate method.

Where an officially approved or regulated programme requires a particular attendance list, signature, declaration or other verification procedure, Educateme follows that applicable requirement and does not replace it solely with a camera check or meeting log where the authority requires something different.

7. Camera Use, Privacy and the Right to an Image
A live camera image can reveal information about a Student and the Student's private surroundings. Educateme therefore seeks to limit camera use to reasonable educational, participation or verification purposes.

Students are strongly encouraged and generally expected to use their camera during interactive parts of a live lesson where reasonably possible, but are not required to keep it on continuously during every part of every lesson.

A teacher may reasonably request camera activation at the beginning of a lesson, during an interactive activity or for a brief identity or attendance check where appropriate.
Students may use a blurred or appropriate virtual background and may position the camera to reduce visibility of private surroundings.

Educateme does not routinely require Students to:
  • Display the whole room or home;
  • Provide a 360-degree view;
  • Show unrelated household members;
  • Explain a private circumstance in front of the group;
  • Provide detailed medical information merely to request an alternative attendance check.
If a Student cannot use the camera for a legitimate technical, privacy, accessibility, disability, health or similar reason, the Student may inform the teacher or Educateme privately and cooperate with a reasonable alternative method.
Live participation with a camera does not, by itself, grant Educateme permission to publish or use the Student's image for an unrelated public or promotional purpose.

8. Lesson Recordings
Where recording access is included in a course:

  • Students will be informed that recording is taking place through the platform, the teacher or another clear notice;
  • Educateme will, where reasonably and technically possible, record the teacher, shared screen and teaching materials rather than the Student gallery;
  • Student video will not be intentionally included in an ordinary recording unless there is a defined purpose, an appropriate legal basis and suitable safeguards;
  • A recording may nevertheless incidentally include a Student's display name, voice, question, answer, chat contribution or brief image;
  • Students may inform the teacher or Educateme about a particular recording concern, and a reasonable privacy-preserving arrangement will be considered where practicable;
  • Access is limited to persons entitled to access the relevant course and authorised Educateme personnel;
  • Ordinary course recordings are not made publicly available;
  • Ordinary course recordings are not repurposed for advertising, testimonials or public social-media content merely because a Student appeared in the lesson.
Students are prohibited under the Terms of Service from making or distributing unauthorised recordings, screenshots or photographs of identifiable participants.

9. Who May Receive Personal Data
Educateme shares personal data only where there is an appropriate purpose and legal basis.

9.1 Teachers and Educational Staff
Subcontracted or employed teachers may receive information necessary to provide the course, including, where relevant:
  • First and last name;
  • Language and level;
  • Course and scheduling information;
  • Relevant learning information;
  • Attendance information;
  • Limited contact information where needed for the agreed service.
Teachers receive only personal data reasonably necessary for the educational and administrative tasks assigned to them.

9.2 Other Students in the Same Group
During a live group lesson, other participants may see or hear information inherent in ordinary participation, such as:
  • Display name;
  • Voice;
  • Video image when the camera is on;
  • Chat contributions;
  • Spoken answers and other lesson contributions.
Students entitled to recording access for the same group may also hear or see Student data that was incidentally included in the relevant recording.

9.3 Technology and Service Providers
Educateme uses external services to operate its business and deliver courses. Depending on the services used at a particular time, these may include:

  • Odoo CRM for customer relationship management or another customer relationship management service;
  • WhatsApp or related messaging services for communications;
  • Stripe or another payment provider for billing and payment processing;
  • QuickBooks or another accounting service;
  • TalentLMS or another learning-management system;
  • Google Workspace, including services such as Gmail and Google Drive;
  • Zoom or another videoconferencing provider for online lessons;
  • Tilda or another website hosting/page-building provider;
  • Analytics, tag-management and advertising technologies, which may include services provided by Google, Meta/Facebook and Yandex, subject to applicable cookie and consent requirements;
  • Hosting, security, technical-support and professional-service providers where necessary.

The legal role of a provider depends on the service and processing activity. A provider may act as:
  • A processor acting on Educateme's documented instructions;
  • An independent controller for some aspects of its own service;
  • Another recipient recognised under applicable data-protection law.
Where a provider acts as Educateme's processor, Educateme selects providers that offer appropriate data-protection assurances and uses the contractual arrangements required by Article 28 GDPR.

Where a provider acts as an independent controller for a particular activity, its own privacy information may also apply to that processing.

9.4 Professional Advisers, Authorities and Other Recipients
Where reasonably necessary and lawful, personal data may also be disclosed to:
  • Accountants and auditors;
  • Lawyers and other professional advisers;
  • Insurers;
  • Payment, banking or fraud-prevention providers;
  • Competent public authorities;
  • Courts or out-of-court dispute-resolution bodies;
  • An employer or organisation that purchased the training, but only to the extent justified by the training arrangement and the Student's reasonable expectations or another applicable legal basis.
Educateme does not give an employer unrestricted access to the content of private Student communications merely because the employer pays for training.

10. International Transfers
Some providers may process personal data outside Luxembourg or outside the European Economic Area (EEA).

Where Chapter V GDPR requires safeguards for an international transfer, Educateme uses an appropriate transfer mechanism, which may include:
  • A European Commission adequacy decision;
  • The European Commission's Standard Contractual Clauses;
  • Another transfer mechanism permitted by the GDPR.
Where appropriate, Educateme or the relevant provider assesses whether supplementary measures are required in light of the circumstances of the transfer.

A copy of the relevant safeguards may be requested at ilia.ostretsov@educateme.lu.

11. Retention of Personal Data
Educateme keeps personal data only for as long as necessary for the purpose for which it was collected and for any additional period justified by applicable legal, accounting, contractual, certification or claims requirements.
Where a fixed retention period cannot appropriately be stated for every record, the criteria below are used to determine retention.

11.1 Enquiries and Pre-Enrolment Information
Enquiry and trial-lesson information is kept for the period reasonably necessary to answer the enquiry, organise the requested service and carry out reasonable follow-up.
If the enquiry does not lead to a course, information is deleted or anonymised when it is no longer reasonably needed for those purposes, unless another lawful purpose applies, such as an ongoing marketing subscription or a legal claim.

11.2 Student and Course Administration
Student, enrolment, learning and course-administration information is kept during the educational relationship and afterwards for the period reasonably necessary to:
  • Administer the completed course;
  • Answer course-related questions;
  • Issue or verify certificates;
  • Handle complaints;
  • Meet contractual or regulatory requirements;
  • Establish, exercise or defend legal claims.
11.3 Accounting and Payment Records
Invoices, accounting records and transaction information are kept for the periods required by applicable Luxembourg accounting, tax and commercial-record legislation and for any additional period lawfully necessary to resolve a payment dispute.

Payment service providers may have their own legally justified retention periods for information they process as separate controllers.

11.4 Attendance and Certification Records
Attendance records are retained for the period reasonably necessary to:
  • Administer the course;
  • Issue or verify an attendance certificate;
  • Meet requirements applicable to an approved or regulated programme;
  • Support a legitimate reimbursement, training-leave or administrative request;
  • Resolve an attendance dispute;
  • Establish, exercise or defend legal claims.
More detailed verification material is not kept longer than reasonably needed for those purposes.

11.5 Lesson Recordings
Recordings are kept for the recording-access period applicable to the relevant original course, as communicated through the course arrangements, learning platform or other course information.

After that access period ends, recordings are deleted from active systems or irreversibly anonymised when they are no longer required for the educational purpose, subject to the shortest reasonable operational period needed to complete deletion from ordinary backups and technical systems.

A particular recording may exceptionally be retained for longer where necessary for an active complaint, legal claim, security incident or legal obligation. Access remains restricted during any such extended retention.

11.6 Marketing Records
Marketing contact information is kept while the person remains subscribed or while another lawful marketing basis applies.
If a person unsubscribes or objects, Educateme may retain a limited suppression record so that the preference can be respected and future marketing is not sent in error.

11.7 Consent and Compliance Records
Where processing is based on consent, Educateme may keep evidence of the consent and any withdrawal for the period reasonably necessary to demonstrate compliance or resolve a dispute.

At the end of the applicable retention period, personal data is deleted or anonymised unless another lawful basis requires or permits further retention.

12. Children's Privacy
Educateme provides certain educational services to children as well as adults.
Where the Student is a minor:
  • The course contract is entered into by or with the valid authorisation of a parent or legal guardian where required;
  • Relevant privacy information is made available to the parent or guardian where appropriate;
  • Information addressed directly to a child is communicated as clearly and appropriately as reasonably possible having regard to the child's age and understanding;
  • Educateme seeks to minimise unnecessary collection and disclosure of the child's data;
  • Access to information about the child is limited to people who need it for a legitimate educational, administrative, safeguarding or legal purpose;
  • Particular care is taken when relying on legitimate interests because children merit specific protection under the GDPR.
Where processing of a child's personal data is based on consent and applicable law requires consent or authorisation from a person holding parental responsibility, Educateme will obtain the required authorisation.

Recordings involving minors are subject to the minimisation, access and purpose restrictions described in this Policy.

A child's identifiable image, voice or lesson contribution is not used publicly for advertising, testimonials or social-media promotion merely because the child participated in a lesson. Any optional public use requires a separate lawful process and, where required, the appropriate involvement of the parent or legal guardian and the child.

13. Security
Educateme uses appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
Measures may include, depending on the system and risk:
  • Access controls and authentication;
  • Restricted administrative access;
  • Secure cloud and communication services;
  • Appropriate staff and teacher instructions;
  • Contractual data-protection requirements for processors;
  • Backup and recovery procedures;
  • Security and access logging;
  • Procedures for responding to privacy and security incidents.
No internet-based or electronic system can be guaranteed to be completely secure, but Educateme reviews safeguards having regard to the nature of the data and the relevant risks.

14. Automated Decision-Making and Profiling
Educateme currently does not use personal data for solely automated decision-making that produces legal effects or similarly significantly affects a person within the meaning of Article 22 GDPR as part of ordinary language-course enrolment, teaching or attendance.

Educateme also does not currently use automated profiling to make such decisions about Students.

If this changes, this Privacy Policy will be updated and the information required by applicable law will be provided.

15. Your Data-Protection Rights

Subject to the conditions and limitations in the GDPR, you may have the right to:
  • Access personal data Educateme holds about you and obtain information about its processing;
  • Rectify inaccurate or incomplete personal data;
  • Erase personal data where the legal conditions for erasure are met;
  • Restrict processing in the circumstances provided by the GDPR;
  • Data portability for eligible data processed by automated means on the basis of consent or contract;
  • Object to processing based on legitimate interests on grounds relating to your particular situation;
  • Object at any time to direct marketing and related profiling;
  • Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal;
  • Lodge a complaint with a competent supervisory authority, including the Commission nationale pour la protection des données (CNPD) in Luxembourg.
A request to erase data does not require Educateme to delete information that must or may lawfully be retained, for example to comply with a legal obligation or establish, exercise or defend a legal claim.

16. Exercising Your Rights
To exercise a data-protection right or ask a privacy question, contact:

Ilia Ostretsov Email: ilia.ostretsov@educateme.lu
You may also contact Educateme at info@educateme.lu.
Educateme may take reasonable steps to verify the identity of the person making a request where necessary to protect personal data.
Requests are normally answered within one month of receipt. That period may be extended where the GDPR permits an extension, in which case the requester will be informed as required by law.
Data-subject rights are generally exercised free of charge, subject to the limited exceptions provided by the GDPR for manifestly unfounded or excessive requests.
If you believe your data-protection rights have been infringed, you may lodge a complaint with:
Commission nationale pour la protection des données (CNPD) Luxembourg
You are not required to contact Educateme before exercising your right to complain to the CNPD, although we welcome the opportunity to investigate and resolve concerns directly.

17. Cookies and Similar Technologies
Educateme uses cookies and similar technologies on its website.

Some technologies are necessary for the website, forms, security or requested functionality to operate. Other technologies may be used for analytics, measurement, advertising or social-media purposes.

Where applicable law requires prior consent, non-essential cookies and similar technologies are activated only after the user has made the relevant consent choice.

The website may use technologies or services associated with providers such as Google, Meta/Facebook and Yandex, depending on the current website configuration and the user's consent choices.

For more information about the cookies and similar technologies currently used, their purposes, providers, durations and available controls, please see Educateme's Cookie Policy and cookie-consent interface.
Refusing non-essential analytics or advertising cookies does not prevent a person from purchasing an ordinary Educateme course solely because of that refusal.

18. Third-Party Websites and Services
Educateme's website, communications or platforms may contain links to third-party websites or services.

Where a third party processes personal data as an independent controller, its own privacy policy applies to that processing. Educateme is not responsible for an independent third party's privacy practices merely because a link to that service appears on our website.
Where a provider processes personal data on Educateme's behalf as a processor, Educateme remains responsible for meeting its own GDPR obligations concerning the selection and use of that processor.

19. Changes to This Privacy Policy
Educateme may update this Privacy Policy to reflect changes in:
  • Services;
  • Technology;
  • Service providers;
  • Processing activities;
  • Legal or regulatory requirements;
  • Privacy and security practices.
The current version will display the date on which it was last updated.
Where a change materially affects an existing processing activity or the rights of affected people, Educateme will take reasonable steps to provide additional notice where required by law.
Previous versions may be retained for record-keeping and evidentiary purposes.

20. Contact Information
For general privacy questions or requests:
Educateme, S.à r.l. 45, Rue de Wormeldange L-6955 Rodenbourg Luxembourg Email: info@educateme.lu
Data-protection contact: Ilia Ostretsov ilia.ostretsov@educateme.lu
RCS Luxembourg: B266753 VAT number: LU34042185