TeachersPRO Privacy Policy

This Privacy Policy (the "Policy") sets forth the terms and conditions applicable to the processing of personal data by Kiivetä Group Finland Oy ("TeachersPRO" or "we" or "us") and its Users, on app.teacherspro.com or through other websites or applications owned by TeachersPRO that reference this Policy.

Unless otherwise provided by local mandatory rules, this Policy is governed by the laws of Spain.

We may modify this Policy as necessary to adapt it to future legislative or case law changes or to our business needs, without retroactive effect. We will inform you of such changes by posting a notice on our Services and in this Policy and/or by email to the email address you have provided to us for this purpose.

1. PERSON IN CHARGE OF TREATMENT

Full name of the legal entity: Kiivetä Group Finland, Oy

Address: Sparkup, Tykistökatu 4 B, 20520, Turku, Finland, registered in the Commercial Register of Finland under ID 3292556-9.

Email address for the privacy officer: contact@www.teacherspro.com

1. DATA COLLECTION

In accordance with the General Personal Data Protection Regulation (GDPR 2016/679 EU) (and the rules that develop it or any others that may replace it), TeachersPRO informs users of our Services of the collection of the following personal data by TeachersPRO, and the processing of their data in accordance with this Policy.

• Browsing. We do not collect any personal data if you are only browsing our Services without identifying yourself as a registered user, except in the cases indicated in the cookies policy or in this Policy.
• Web forms. If you send us any web form other than the registration form (Contacts, Comments), we collect the data indicated in the forms and provided by the User, including name and email address and technical data as you have accepted this form (logs, IP, time, date and the like). Mandatory data are indicated. This data is used to process your request (according to the form) and to contact you for future notifications. Mandatory data are marked as such in the form and if not provided the request will not be accepted.
• User Registration. When you apply for admission to a TeachersPRO service, we collect the following personal data as a Registered User (as defined in the General Terms and Conditions): country, region, first name, last name and email address, photograph, password, Primary Educational Institution and Secondary Educational Institution (as indicated on the form), subscription mode data, and technical data as you have accepted this form (logs, IP, time, date and the like). Mandatory data are marked as such on the form and if not provided cannot proceed to registration.

Sensitive data prohibited. In ALL CASES it is forbidden to communicate to the Portal any data that contains sensitive information relating to identifiable persons (of third parties or of you), such as: racial origin; trade union membership; religion, ideology and sexual orientation; health; or data relating to criminal records, proceedings and penalties or fines of any kind, linked to domestic violence or Curriculum Vitae or similar personal data sets that provide a definition of the characteristics or personality of citizens and allow the evaluation of certain aspects of the personality or behavior of the same.

1. PURPOSES OF DATA PROCESSING

Purposes specified by the web forms. The purpose of the personal data included in the web forms other than registration forms is indicated on each form and the options marked by the User (contact, complaint, request for information, rating, etc.).

General. The personal data we collect is used in all cases for the purposes of:

• Management, execution and development of the Services
• Management of all activities of the Institute in relation to the User.
• To maintain contact with the User and inform him/her about our Services, as well as for future communications about new services, offers or promotions related to the products and services offered by TeachersPRO;
• To offer you information or registration of associated or collaborating companies of the Institute for your training or professional development. Even offer you information about these companies if you accept this purpose.
• Manage any newsletters, notification emails or general commercial communications relating to the Services and products and any new features, offers or promotions we offer,
• To comply with the applicable General and Particular Conditions, and other legal requirements, as well as for the legal defense of TeachersPRO and its interests.
• Analysis of the use of the Service in order to improve it or draw conclusions from the educational sector.

1. LEGAL BASIS

The legal bases on which we base the processing of your personal data are:

• Execution of the Contract: the processing of registered user data is necessary for the execution of a contract to which you are a party or to take action upon your request prior to the conclusion of such contract.
• Legitimate interest: we have a legitimate interest in running and managing our business in order to provide you with the best service / product and the best and safest experience. We ensure that we consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact such use has on you (unless we have your consent or are otherwise required or permitted by law). You can learn more about how we assess our legitimate interests in order to avoid any potential impact on you, with respect to specific activities, by making any inquiries you may have at the email address listed at the top of this page.
• To comply with a legal or regulatory obligation means to process your personal data when necessary to comply with a legal or regulatory obligation to which we are subject.

As a general rule, we do not rely on consent as a legal basis for processing your personal data other than in connection with sending marketing communications by email or text message. You have the right to withdraw your consent to marketing at any time by contacting us at contact@www.teacherspro.com.

Please note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your data. Please contact us at contact@www.teacherspro.com, if you need details on the specific legal basis.

1. PROCESSING OF THIRD PARTY DATA.

In general, it is forbidden to provide us with or publish in our Services any third party data. As an exception to the above, the following third party data may be communicated on the Portal:

• your ratings of other TEACHERSPRO Users provided for in the Services themselves; and
• data of third parties who have expressly consented to the processing of such data in our Services, i.e. with the informed consent of the third party owner of such data (or their parents/guardian, if applicable) as well as the express authorization in this regard with TeachersPRO, once TeachersPRO has submitted evidence of the corresponding consents through the procedure established in the Portal, or by email to feedback@www.teacherspro.com.

Therefore, the User shall, to the extent possible, remove or anonymize any information containing personal data of third parties in the contents and materials uploaded by the User to the Portal (e.g. documents with names of pupils or students, photographs with faces of third parties). Insofar as it is not possible (with videos, sound recordings), the User must obtain the informed consent of the interested parties (or parents or legal guardians as the case may be) necessary for these treatments.

In those cases in which the User transmits to the Website or Portal User content/s containing personal data of non-User third parties ("Non-User Third Party Data", for example, first and last names or photos of students, filming, etc.), the User ("Responsible User") is obliged to obtain the informed consent of such Non-User Third Parties or their Legal Guardians appropriate to this Privacy Policy and also:

• Guarantees that the Responsible User himself or a responsible third party (such as an educational entity, hereinafter "Responsible Third Party") complies with the rest of the obligations that have in its category as responsible for the file or files of the referred personal data under the applicable legislation.
• It undertakes and guarantees TeachersPRO that, at the request of the company (by means of e-mail to the e-mail address indicated at the time of registration or the relevant one indicated for this purpose by the User through the Portal prior to the communication process), it will immediately send as soon as possible evidence of compliance - on its part or that of the Responsible Third Party - both of the collection of the necessary informed consent and of the other obligations as the party responsible for the file(s).

TeachersPRO will remove any third party personal data communicated by a User if it discovers that the publication of the same through the Portal does not comply with these conditions.

If you have any questions, please consult the FAQ section of the Portal or contact us at feedback@www.teacherspro.com.

1. DISCLOSURE

We treat your personal data confidentially in accordance with applicable law. Your personal data will not be disclosed or transferred to third parties without your consent, except as indicated below.

We may share your personal information with the parties listed below:

• Service providers that act as data processors, under contracts that meet the guarantees provided by law.
• Third parties with whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other companies or merge with them, if we are party to a bankruptcy or other change of control proceeding.
• Third parties with whom we must share your information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or website policies.

We will also disclose any information, whether or not of a personal nature, about the User or the User's use of our Services (a) pursuant to a legal obligation, or (b) to comply with other obligations under the applicable regulations and rules set forth in the Portal Terms. In particular, your user name will be visible in any contribution of yours on the Portal (post, uploaded material) for the purpose of identifying its provenance and/or author.

Likewise, in order to provide our Services correctly and always according to the instructions indicated by the User (including the configuration of the User's Service and his/her actions in TEACHERSPRO), the company will communicate to third parties the personal data that the User has determined to publish. Thus, sometimes (as determined by the User):

• They may be viewed by certain Users of the Service.
• They can be viewed by all Users of the Service.
• They can be viewed worldwide by all Internet users.

In addition, in the case of Registered Users sponsored by an educational entity, the entity that is sponsoring their subscription to the Premium Service may view their personal data (such entity must request their consent and inform them of this according to the means deemed necessary by the entity itself).

1. INTERNATIONAL TRANSFER OF DATA

The User's personal data provided for this purpose by the User (according to his/her instructions, as indicated in the previous clause of this Policy) may be accessed and/or viewed by other Users of the Portal in all countries of the world for the specific purpose of providing the Service, in particular for communications between Users and the evaluation of their teaching evidence. The User expressly consents to this international transfer of such personal data to other Users, for the purposes of participating in the TEACHERSPRO User community and fostering relationships between Users.

In those cases in which the Responsible User transmits to the Website or Portal content/s of "Non-User Third Party Data", he/she is obliged to obtain the informed consent of such Non-User Third Parties or their Legal Guardians appropriate to this Privacy Policy (especially but not only with respect to necessary international data transfers).

1. ACCESS AND USE BY USERS AND TEACHERS PRO OF THIRD PARTY PERSONAL DATA

The Service involves two data processing operations for which TeachersPRO is not a data controller:

(a) access by Users to the personal data of other Users that are processed under their responsibility ("Responsible User"), for which TeachersPRO is a data processor; and, if applicable,

(b) access by TeachersPRO and other Users to "Non-User Third Party Data" (as defined in clause 4 of this policy) that is processed under the responsibility of the Responsible User or a Responsible Third Party.

According to the provisions of the applicable regulations on the protection of personal data (RGPD), these accesses by a User and/or TeachersPRO (hereinafter, "Contractor") shall not be considered as communication or transfer of data, but as simple access to third party data necessary for the provision of the Services (including, but not limited to, the functionalities of visualization and evaluation of the activity of other Users), and, consequently, the Contractor, upon accessing such data, shall be considered as "data processor" of such data, and to such effect the provisions of Annex 1 shall apply.

In the event of non-compliance with the obligations set forth in Annex 1, the User as "processor" will be considered responsible for the processing and will be liable for the infringements incurred personally, exonerating TeachersPRO and any other data controller of the accessed data from any liability (without prejudice to the possibility of termination of the contract by TeachersPRO).

1. OWN AND THIRD PARTY COMMERCIAL COMMUNICATIONS

By completing and submitting your personal data (by clicking on the corresponding box), the User expressly agrees to receive commercial electronic communications from us related to the products and services of Instituto, including alerts, notifications, newsletters, offers and promotions from TeachersPRO and third parties (see next paragraph). If you do not wish to receive such commercial communications, please indicate so on the form or as indicated in each such commercial communication.

Likewise, the User consents to the sending of communications - including electronic and commercial - about services or products of TeachersPRO or third parties (partners or collaborators of TeachersPRO) for advertising or commercial prospecting in the sectors of training and education, publishing, and consumer products.

1. THIRD PARTY LINKS AND SOCIAL NETWORKING SERVICES

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of each website you visit.

The website may integrate social networking services. You understand that we do not control such services and are not responsible for the manner in which they operate. While we may provide you with the ability to use such services in connection with our website, we do so merely as an option and, like you, we rely on those third-party services to operate properly and fairly.

You should be aware that personal data you voluntarily include and transmit online in a blog, social network or other publicly accessible medium may be viewed and used by others. We cannot control such uses of your personal data, and by using such services, you assume the risk that personal data provided by you may be viewed and used by others.

1. DATA SECURITY

We have implemented appropriate security measures to prevent your personal data from being lost, accidentally used or accessed in an unauthorized manner, modified or disclosed; however, due to the inherent open nature of the Internet, we cannot guarantee the security of information provided online. We also limit access to your personal data to employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data in accordance with our instructions and are subject to a duty of confidentiality.

We have implemented procedures to address any suspected personal data breaches and will notify you, as well as any relevant regulatory body of any breach where we are required to do so by law.

1. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes for which we have collected it, including to comply with legal, accounting or reporting requirements.

In determining the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and applicable legal requirements.

In some circumstances, you may ask us to delete your data: see Delete requests below for more information.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use and retain this information indefinitely without notice.

1. YOUR LEGAL RIGHTS

In certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This allows you to receive a copy of the personal data we hold about you and to verify that we are processing it lawfully.
• Request correction of personal data we hold about you. This allows you to correct any incomplete or inaccurate information we hold about you, although we may need to verify the accuracy of the new information you provide.
• Request the deletion (erasure) of your personal data. This allows you to ask us to delete your personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to the processing (see below), where we may have processed your information unlawfully or where we are required to delete your personal data in compliance with local law. However, please note that we may not always be able to comply with your deletion request for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to the processing of your personal data where, although you have a legitimate interest (or that of a third party), there is something about your particular situation that makes you want to object to the processing in this area because you consider that it has an impact on your fundamental rights and freedoms. You also have the right to object when we process your personal data for direct marketing purposes. In some cases, we may be able to demonstrate that we have legitimate and well-founded interests in processing your information that override your rights and freedoms.
• Request the restriction of the processing of your personal data. This allows you to ask us to stop processing your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) when our use of the data is unlawful but you do not want us to delete it; (c) when you need us to retain the data, even if we no longer need it to exercise or defend legal claims; or (d) you have objected to our use of your data, but we must verify whether we have legitimate reasons to use it.
• Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used and readable format. Please note that this right only applies to automated information that you authorized us by consent to use, as well as information necessary to enter into any contract with you.
• Withdraw consent at any time where we rely on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will notify you if this is the case at the time you withdraw consent.

You will not have to pay any fees to access your personal information (or to exercise any of your other rights). However, we may charge you a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to ask you for specific information to help us confirm your identity and secure your right to access your personal data (or exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it. We may also contact you to request further information in relation to your request in order to expedite our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us more than one month if your request is particularly complex or if you have made a series of requests. In this case, we will notify you and keep you updated.

You may file a complaint with the relevant data protection authorities.

To exercise your rights, please contact us at contact@www.teacherspro.com.

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General conditions of use of the TeachersPRO platform

1. Preamble

Kiivetä Group Finland Oy (the "Company") makes available to Internet users the platform: TeachersPRO (hereinafter "TEACHERS PRO" or the "Portal") accessible at www.teacherspro.com (the "Website").

Access to and/or use of TeachersPRO, and any other TeachersPRO website that references these conditions, is completely voluntary and confers the status of User. Every User accepts, from the moment in which he/she accesses, these General Conditions of Use (the "General Conditions"), the "Data Protection Policy" of TEACHERS PRO. Consequently, the User must carefully read the aforementioned legal documents before accessing and using any of the Website's services.

The User may access, print, download and save these General Conditions at any time. These General and Particular Conditions, as well as our Privacy Policy, will be permanently accessible on the portal through the TeachersPRO Legal Conditions link.

The User guarantees that he/she is of legal age, and that he/she is accessing the Portal in his/her professional, teaching or similar capacity. Otherwise, the User must not access or use the Portal, much less register as a User.

TeachersPRO reserves the right to modify the content of the General or Particular Conditions and our Privacy Policy, the new versions of which will be applicable to new users as of the date of their publication. Users already registered will be informed of any modifications 30 days in advance, and such modifications will be considered accepted at the time of any access by the User to TeachersPRO subsequent to such modification. We recommend that the User consult these Terms and our Privacy Policy frequently and in particular after being notified of any changes.

More legal and general information about TeachersPRO and the use of the Portal can be found in the legal notice.

2. Object

These General Terms and Conditions regulate the access and use of the TeachersPRO Portal and the corresponding services, and in particular its various functionalities, contents and forms of learning and continuous improvement (the "Service" or "Services").

The purpose of TeachersPRO is to provide an online teaching learning process and a community of users interested in this training process and our new educational platform, where any user can improve their teaching skills and share and comment on this learning with their peers.

3. Account Subscription

The subscription process will be online through the Portal. Once the contracting process has been completed, the User will receive an e-mail confirming the subscription to the address provided by the User for this purpose (the "Confirmation"). Then, once the contract has been perfected, the User will be entitled to the benefits indicated on the Website for users registered in "Open" mode.

Your "Open" account will remain in effect until you terminate your account or we terminate your account in accordance with clause 14 below.

The user registered in Open mode will be able to subscribe to TeachersPRO's paid products indicated on the Website, and in particular to upgrade to Premium mode with an annual subscription to the paid services.

The site will automatically display the price and payment methods available for making payments. Currently, payments can only be made through the payment gateway Stripe whose services are subject to their own legal conditions, privacy policy and legal texts that you must accept (you can check the information of that company and services here) and by credit cards "Visa", "MasterCard", "American Express" among others. In the future we may add or change payment gateways and means of payment without the need to modify these General Conditions, but always informing in the Web Site.

The Registered User is informed and accepts that, in accordance with the regulations in force and due to the fact that this is a contract to supply digital content that is not provided in material form, with the simple execution of the contract and the provision of an information society service (the confirmation by e-mail from us of the completion of the contracting procedure) he/she will not have the right of withdrawal (the right of a consumer to renounce the service - without the need for any reason - and to be refunded the price already paid) since he/she will already be able to use the Services and functionalities of TeachersPRO.

However, the User may unsubscribe at any time in accordance with clause 14, however, this does not obligate TeachersPRO to refund any payments already made to the company.

Those Users whose subscription to the Service is paid for by a third party (the "Sponsored User(s)" and the "Sponsor" respectively), are, informed and agree that even if they have followed the subscription process except for payment, the provision of the Service is conditional upon the agreement between the Company and the Sponsor and/or the instructions (e.g. termination of the Service to certain Sponsored Users) that TeachersPRO receives from the Sponsor.

4. Certification of Studies

TeachersPRO certification systems of an unofficial nature. The requirements and standards, as well as their characteristics, can be consulted on the Web Site.

TeachersPRO reserves the right to deny certification to those Users who have not met the minimum requirements and, therefore, have not reached the appropriate level to obtain the certificate of studies.

The User agrees to follow the pace of study and to take full advantage of the course, completing all the activities set by TeachersPRO within the deadlines specified.

5. Price, Validity of Bids and Prices; Payments

Payment of the price of subscriptions. Except for Sponsored Users, the User agrees to make the relevant payments in the terms and forms accepted in the subscription process of the corresponding products purchased by the User (independent products or periodic subscriptions).

The User accepts that unless otherwise agreed, the subscription payments and prices may be modified without retroactive effect (a) by giving 30 days' prior notice on the Portal and/or by electronic communication to the e-mail address indicated at the time of registration (or the relevant one indicated for this purpose by the User through the Portal prior to the communication process) (b) in the event of changes in the tax regulations applicable to the price of the Service, automatically with regard to the impact of such taxes on the total price to be paid by the User. In case of non-acceptance of the modification, the User must unsubscribe from the Service within the indicated term.

Validity of offers. The subscription modalities offered on the Portal, and their prices, will be available for purchase as long as they are in the catalog of products displayed through the Portal. The prices are those indicated on the Portal on the date of the order and are valid except for typographical or computer errors (especially particularly obvious errors), Users are recommended to consult updated versions of the Portal to avoid errors.

In the event that at any time there is an error of this type in the price, at all times beyond the control of TeachersPRO, we will proceed as soon as possible to correct it. If there is a typographical error in any of the prices shown and any bona fide User has made a decision based on such error, we will notify the User of such error and the bona fide User will have the right to cancel its subscription without any cost on its part. The offers will be duly marked and identified as such, conveniently indicating the previous price and the price of the offer.

VAT. The prices indicated by TeachersPRO on the Portal include, unless expressly stated otherwise, the Value Added Tax (VAT) applicable in Finland or other taxes that may be applicable and, in any case, shall be expressed in the Euro currency (€).

Delinquency. Failure to pay entitles TeachersPRO to suspend the Service and access to the Platform and, in any case, the right to claim the same. Furthermore, in the event of repeated non-payment or non-compliance with any of its obligations by the User, TeachersPRO reserves the right to suspend the User's purchase account by notifying the User by email (to the email address indicated for such purposes by the User in its registration or appropriately indicated for such purposes by the User).

Electronic Invoice. The User has at his disposal the simplified electronic invoice in his account of the Portal. The User expressly consents to have at his disposal the electronic invoice and to have it at his disposal in the manner described in this clause. If the User wishes to receive the invoice digitally or on paper, it will be sufficient to request it to feedback@www.teacherspro.com.

Sponsored Users. This clause does not apply to Sponsored Users while they hold such status.

6. TeachersPRO rights and obligations

TeachersPRO undertakes to provide the Services to Users in a diligent and professional manner, in accordance with and subject to the limitations set forth in these Terms.

User acknowledges that it is technically not possible to achieve 100% availability of TeachersPRO. However, TeachersPRO will endeavor to keep the Portal available as constantly as possible. Especially for maintenance, security or capacity reasons, as well as due to events that cannot be influenced by TeachersPRO (e.g., public communication network anomalies, power outages, etc.), there may be short interruptions or temporary suspension of services on TeachersPRO.

TeachersPRO reserves the right to modify without prior notice, the design, presentation and/or configuration of this Portal, as well as some or all of the Services, and to add new services. Except in exceptional cases, TeachersPRO will not close or modify any modules or learning functionalities in the process of delivery without prior notice.

TeachersPRO may remove from TeachersPRO at any time and without prior notice or justification any content that violates these Terms and Conditions.

TeachersPRO reserves the right, at any time and without prior notice or justification, to suspend or deny access to TeachersPRO, as well as to terminate the User's membership and terminate our contractual relationship, to those users who breach any of these General Conditions or the Particular Conditions applicable to them, without prejudice to the right to demand compensation and indemnification for any damage or harm that TeachersPRO or third parties may have suffered as a result of such breach.

TeachersPRO is not obliged to provide other users with the data and/or information provided by the User when such data and/or information violate legal provisions or these General Conditions or the Particular Conditions.

7. User Obligations

The User undertakes to make a diligent and loyal use of TeachersPRO and of the services accessible from this Portal, under its entire responsibility and with total subjection to the Law, to the good customs and to the present General Conditions and, in its case, the Particular Conditions that may be applicable, as well as maintaining the due respect to the other users.

Registration. TeachersPRO conditions the use of most of its services and functionalities of TeachersPRO to the registration of the User upon completion of the corresponding form and the creation of a user account, selecting an identifier (ID or login) and a password that the User undertakes to keep and use with due diligence. The aforementioned registration shall be carried out in the manner expressly indicated in the service itself.

User Account. The use of the User account (the "User Account") is personal and non-transferable, not being allowed the transfer, even temporarily, to third parties. In this sense, the User must adopt the necessary measures for the custody of the password selected by him/her, avoiding the use of the same by third parties. Consequently, the User is solely responsible for the use of its password, with full indemnity for TeachersPRO. In the event that the User knows or suspects the use of his/her password by third parties, he/she must inform TeachersPRO as soon as possible.

User Information. All information provided by the User, whether Registered or not, through the services available on TeachersPRO must be truthful, accurate and complete. For these purposes, the User guarantees especially the authenticity of all data provided as a result of the completion of the forms necessary for the subscription of the Services. Similarly, it will be the responsibility of the User to keep all information and content provided to the Institute permanently updated so that it responds at all times to the real situation of the User. In any case, the User shall be solely responsible for any false or inaccurate statements made and for any damages caused to TeachersPRO or third parties for the information provided.

Conduct of the User. The User is obliged to respect the applicable laws, these General Conditions and the Particular Conditions of application and the rights of third parties when using the contents and services available on TeachersPRO. It is also prohibited the reproduction, distribution, transmission, adaptation or modification, by any means and in any form, of the contents of the Portal (texts, designs, graphics, information, databases, sound and/or image files, logos, etc.) and other elements of the Portal, unless prior authorization of their legitimate owners (note that TeachersPRO sometimes indicates that it can share such content, for example by clearly indicating that it shares them under open Creative Commons licenses) or when it is permitted by law.

Without prejudice to the obligations indicated above of a general nature, the User is prohibited from the following actions:

• Publish libelous or slanderous content, regardless of whether such content affects other users or other persons or companies.
• Publish content that violates the fundamental rights of people, may seek the weakness of other Users, lack of courtesy in the network, disturb or may generate negative opinions in our users or third parties.
• Publish contents that contravene the principles of legality, honesty, responsibility, protection of human dignity, fundamental rights and/or human rights, protection of minors, protection of public order, protection of privacy or personal data, consumer protection and intellectual and industrial property rights of TeachersPRO or third parties.
• Annoying other Users (especially by spamming).
• Use legally protected content (e.g. by legislation relating to intellectual property, trademarks, patents, utility models or aesthetic models) without having the right to do so, or advertise, offer or distribute legally protected goods or services.
• Employing TeachersPRO in a manner that is not diligent or contrary to good faith (e.g., evaluating the activity of other users in an arbitrary manner or with fraudulent arrangements).
• Carrying out or encouraging anti-competitive actions, including those aimed at progressive customer acquisition (such as chain, snowball or pyramid schemes).
• Use mechanisms, software or scripts in connection with the use of TeachersPRO.
• Blocking, overwriting, modifying or copying, unless it is necessary for the proper use of the Services and the Websites. For example, copying using "Robot/Crawler" type search engine technologies is not necessary for the proper use of the Portal's services and is therefore expressly prohibited.
• Disseminate and publicly reproduce content from TeachersPRO or other users, without prior authorization.
• Any action that is likely to impair the functionality of TeachersPRO's technical infrastructure and connections, especially to overload them.
• In general, to use any of the materials and information contained in TeachersPRO for purposes that are unlawful and expressly prohibited in these General Terms and Conditions and in the applicable Special Conditions, or that are contrary to the rights and interests of TeachersPRO and the services of TeachersPRO, its members and/or third parties.

Confidentiality. The User undertakes to maintain the strictest confidentiality regarding the contents and data of TeachersPRO or its Users to which it may have access within the Portal, and not to communicate them to third parties or use them for any purpose other than their participation in the Portal. Except for data that is not personal data and that can be clearly inferred to be non-confidential content or data (e.g., public data or content, links to open Internet pages or content, or content clearly designed to be shared with unregistered Users).

Responsibility. The User is aware of, and voluntarily accepts, that the use of the Service takes place, in any case, under his sole and exclusive responsibility. The User who breaches these General Conditions or the Special Conditions of application, and/or who, in any way (including the introduction or dissemination of "computer viruses"), damages, disables, overloads, deteriorates or prevents the normal use of the materials and information contained in TeachersPRO, the information systems or the documents, files and all kinds of content stored in any computer equipment (hacking) of TeachersPRO, its members or any other user of TEACHERSPRO, shall be liable to them and indemnify them against any damage or harm.

8. Content provided by TeachersPRO Users

The User declares that he/she is the legitimate owner of the intellectual and industrial property rights of the contents provided by the User on TeachersPRO ("User Content"), or authorized for their distribution and communication on TeachersPRO. Each User is solely responsible for obtaining any type of authorization, permission or license, if necessary for the performance and publication of any User Content. User warrants compliance with the provisions of the Privacy Policy regarding the processing of personal data of third parties, both TeachersPRO users and non-users.

The User assigns to TeachersPRO on a non-exclusive basis the rights of reproduction and public communication, distribution and transformation through TeachersPRO's interactive spaces on any User Content, for the entire world and for the entire legally established term of protection and all possible purposes (especially but not only the provision and management of the Service). The assignment of rights also includes both the use of all such materials for teaching purposes and their publication in the public virtual spaces in which you interact in TeachersPRO. This license will expire upon termination of the User's membership, without prejudice to keeping a copy of the User Content in TeachersPRO's backup copies for the legally required period of time.

Without prejudice to the prohibitions indicated above, TeachersPRO does not permit the distribution or communication of User Content that deteriorates the quality of the Service or that does not meet the quality parameters established in TeachersPRO.

TeachersPRO does not monitor or supervise the User Content. However, TeachersPRO reserves the right to remove those contents that TeachersPRO considers inappropriate to the characteristics and purposes of TeachersPRO or contrary to these Terms and Conditions or the applicable Particulars (especially but not only in the event that such User Content has been reported). In the event that TeachersPRO must remove User Content, TeachersPRO may also terminate its contractual agreement with the User or temporarily and/or partially suspend its Services to such User.

If you believe that Content posted on TeachersPRO violates this policy, please contact us as set forth below in 10 Notifications.

In order to draft an appropriate legal clause regulating the use of a ChatGPT-based AI to provide expert constructive feedback to TeachersPRO users, it is essential to consider the current legal framework in Finland related to data protection, user privacy, and the use of artificial intelligence. Given my latest point of knowledge in April 2023, relevant legislation would include the EU General Data Protection Regulation (GDPR) applicable in Finland, as well as local Finnish privacy and technology laws.

The clause should specifically address consent to the use of personal data, the purpose of data processing, transparency about how AI is used, and security measures taken to protect user data. Below, I provide you with an example of how such a clause could be drafted, although I strongly recommend you consult with a technology and data protection lawyer in Finland to ensure compliance with current and country-specific legislation.

9. Use of Artificial Intelligence for Constructive Feedback Clause in TeachersPRO
10. Acceptance and Consent: By using the TeachersPRO platform, you expressly agree to the use of artificial intelligence (AI) technologies, including one based on ChatGPT, to analyze evidence of your educational practice and provide personalized constructive feedback. This analysis will be performed respecting your profile and the history of evidence provided to the platform.
11. Purpose of Data Processing: The information collected and analyzed by AI will be used exclusively for the purpose of improving the quality and relevance of the feedback provided, contributing to your ongoing professional development. This process is based on our commitment to educational excellence and support to the teaching community.
12. Transparency and User Rights: TeachersPRO is committed to maintaining transparency about the operation of AI and the use of your data. You have the right to request information about the data processed, obtain a copy of such data, and require rectification or deletion of such data, in accordance with the EU General Data Protection Regulation (GDPR) and applicable Finnish law.
13. Security and Data Protection: We are committed to implementing the necessary technical and organizational security measures to protect your personal data against unauthorized access, alteration and any form of illegitimate processing. This includes data encryption, restricted access to authorized personnel, and regular security audits.
14. Applicable Law and Modifications: This clause is governed by the laws of Finland and the regulations of the European Union, including the GDPR. TeachersPRO reserves the right to modify this clause at any time, in accordance with legislative changes or improvements to our AI practices. Any changes will be communicated through our platform and will become effective immediately upon posting.
15. Intellectual and Industrial Property Rights

Except as expressly set forth in these General Terms and Conditions and the Particular Conditions of application or in the Creative Commons licenses linked to specific contents, all intellectual and industrial property rights of the contents of TeachersPRO and/or available on or through this portal are reserved.

The texts, designs, images, databases, logos, structure, trademarks and other elements of TeachersPRO are the property of TeachersPRO and are protected by the laws and international treaties on intellectual and industrial property. Any reproduction, transmission, adaptation, translation, modification, communication to the public, or any other exploitation of all or part of the content of TeachersPRO, made in any form or by any means, electronic, mechanical or otherwise, is strictly prohibited without prior written permission from TeachersPRO or third party owners. Any infringement of these rights may result in appropriate civil or criminal judicial or extrajudicial proceedings.

11. Notifications and complaints

For the purposes of preserving the possible rights of TeachersPRO or third parties, in the event that a User or third party considers that there has been a violation of its own rights or those of third parties, or generally a breach of these General Conditions or the applicable Particular Conditions, by the publication of a certain content on TeachersPRO, the User or third party must notify said circumstance, in writing, to Instituto Escale, S.L., CIF B-65809667 and registered office at C/. Numancia, no. 185, 2o. 2a, 08034 Barcelona and email to contact@www.teacherspro.com, indicating (under the email subject "Legal infringement"):

- Identification and indication of the allegedly unlawful content (by URL or other means of locating the content).

- Explanation or justification of why it is considered unlawful or infringing.

- If applicable, identification data of the interested party who is the owner of the allegedly infringed rights. If the claim is filed by a third party other than the interested party, he/she must indicate the representation he/she is acting on behalf of the interested party.

- Accreditation of the existence, ownership and validity of the aforementioned infringed rights.

- Express declaration in which the interested party accepts responsibility for the truthfulness of the data and information provided in the notification referred to in this point.

- Signature and contact information (preferably email and/or telephone).

The User also has the option to make such notification through the "Report" button whose operation is detailed in this link.

In both cases TeachersPRO undertakes to investigate the matter indicated in the notification (hereinafter "Complaint"), and will communicate with the complaining User, as well as the reported User, if applicable, to resolve the matter in the most efficient manner possible, and making reasonable efforts to preserve and defend its own rights and the rights of Users and third parties. TeachersPRO reserves the right, in any event, to remove any reported content, temporarily or permanently, at its discretion.

12. Warranties and liability

TeachersPRO. TeachersPRO does not undertake to monitor User Content or User activity on TEAGHERSPRO and therefore cannot make any warranties about User Content of any kind.

Except in those cases expressly described in these General Terms and Conditions and the rest of TeachersPRO's regulatory framework, TeachersPRO only accepts liability for direct (consequential) damages and to the maximum extent permitted by applicable law shall not be liable for indirect damages (lost profits) that may be due to lack of accuracy, completeness, timeliness, as well as errors or omissions in the information and services provided by TeachersPRO which may be accessed through the same.

TeachersPRO assumes no liability whatsoever:

• For the contents, data and/or information provided by the Users of the Portal, in particular, but not limited to, the opinions expressed by the Users and the actions carried out by the Users through the Portal, forums, communities, or other tools for participation or opinion; or
• For the contents of external websites to which there are links. In particular TeachersPRO does not guarantee that these contents are true, fulfill a certain purpose or can serve that purpose.

TeachersPRO does not guarantee the availability, continuity or infallibility of the operation of the Portal, and consequently excludes, to the maximum extent permitted by current legislation, any liability for damages of any kind that may be due to the lack of availability or continuity of the operation of TeachersPRO and the Services provided therein, as well as errors in access to the various web pages or those from which, where appropriate, such services are provided.

TeachersPRO shall not assume any liability for the non-performance or delay in the performance of any of the obligations assumed under these general conditions, if such non-performance or delay is the result or consequence of an event of force majeure or fortuitous event admitted as such by Jurisprudence.

The Sponsored User. The User Sponsored by an educational entity agrees that, as set forth in the Privacy Policy, the Sponsor may have access to information about its use of the Service, the cost of which is being borne by the Sponsor. The Sponsored User warrants to TeachersPRO that the Sponsor has sufficiently informed the Sponsored User in this regard and (by means unrelated to TeachersPRO) obtained the Sponsored User's consent to this transfer of personal data for the purposes that the Sponsor has indicated to the Sponsored User.

13. Links to third party sites

TeachersPRO includes within its contents links to sites owned and/or managed by third parties in order to facilitate access to information available through the Internet.

TeachersPRO does not assume any responsibility derived from the existence of links between the contents of this site and contents located outside this site or any other mention of external contents to this site. Such links or mentions are for informational purposes only and in no case imply the support, approval, marketing or any relationship between TeachersPRO and the persons or entities authors and / or managers of such content or owners of the sites where they are located.

14. User Noncompliance and Indemnity

If the User breaches the clauses of these Terms of Use and/or the applicable legal regulations:

• User shall indemnify and hold TeachersPRO and any other User or injured third party harmless from and against any and all claims, liabilities, losses, damages, costs and expenses (including attorneys' fees) arising out of any claim arising out of such breach(es).
• TeachersPRO reserves the right to cancel and/or delete the Contents of the User, to expel and deny access to TeachersPRO, as well as to terminate the contractual relationship with the User and cancel the User's account, without the User being able to claim any compensation whatsoever, as well as to claim the corresponding indemnities from the User.

15. Resolution

General. The User may unsubscribe at any time, through the process established in the Portal. Otherwise, by email to TeachersPRO at legal@www.teacherspro.com, attaching a copy of your identity document, which will be verified by TeachersPRO before giving you the cancellation.

TeachersPRO may terminate the contractual relationship with its Users in the following cases:

- By discontinuing all Portal Services, at its discretion, upon at least 30 days' notice.

- For breach of these Conditions by the User, by means of a notification sent to the User's contact email address.

- When required by judicial or administrative order.

Upon termination of this contractual relationship (to one or more Users), TeachersPRO will remove all User Content communicated by such User/s, except for those Contents that for technical reasons or due to the continuity or validity of the use of the contents and materials available on the platform (discussion threads, materials posted and commented by third parties, events or materials shared among several Users, etc.), TeachersPRO cannot remove. In the latter case, it will use reasonable efforts to anonymize the Content of the corresponding User(s) remaining on the Portal.

Specifications with respect to Sponsored Users. Notwithstanding the foregoing, Sponsored User agrees that in the event Sponsor ceases to pay for the Service (either permanently or temporarily), TeachersPRO may retain your data for the purpose of continuing to provide the Service to you. The system will automatically display the price and payment methods available to continue receiving the Service. If the User (until then a Sponsored User) then complies himself with the obligation included in condition 5 "Price, Validity of Offers and Prices; Payments", he will continue to receive the Service. If the User does not comply with this obligation, TeachersPRO may terminate any contractual relationship with the User.

It should be noted that TeachersPRO is not obligated to offer a trial period in these cases since the User is already familiar with the Service.

16. Applicable Law and Jurisdiction.

The present Legal Conditions and the rest of the conditions of the portal will be governed by the Spanish legislation, without prejudice to the law of obligatory application in any jurisdiction where the consumer User is domiciled.

For any questions that may arise or actions to be exercised arising from the provision of services and contents of TeachersPRO and on the interpretation, application, enforcement or breach of the provisions herein, TeachersPRO and the User:

• in all cases both parties agree to try to resolve them amicably. For this purpose you can send us your complaint to the e-mail address feedback@www.teacherspro.com under the subject "complaint".
• if you are a Consumer User and the law determines that you may submit to a certain jurisdiction, that rule of submission to jurisdiction shall apply.
• if the above assumption is not applicable nor is there any mandatory law to the contrary, expressly waiving any other jurisdiction that may correspond to them, they submit to the jurisdiction of the Courts and Tribunals of Barcelona.

The European Commission also provides an online dispute resolution platform available at the following link: http://ec.europa.eu/consumers/odr/.

Questions?

For any questions regarding these conditions, please contact TeachersPRO by email at info@www.teacherspro.com.

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Legal Notice

Holder's data

You are accessing the website of Kiivetä Group Finland Oy ("the Company") published on the Internet at www.Teacherspro.com (hereinafter the "Website"), a company with registered office at Avenida Diagonal, no. 532, 7º, 08006, Spain, registered in the Commercial Register of Finland, with ID 3292556-9.

You can contact us through the web form, or at contact@Teacherspro.com (email) or +358 45 144 60 90 (phone).

Use of the Web Site

This Web Site may be visited by any user freely and, except for Premium Services, free of charge. User" means any natural or legal person who accesses or has accessed this Website. By using the Website and in particular by sending us your data in a contact form, the User accepts our legal conditions, including our Privacy Policy. For certain sections of the Website, the user must register.

Intellectual and Industrial Property

All intellectual and industrial property rights to any content of this Web Site are owned by the Company or its licensors and are protected by national and international laws. These rights are reserved in favor of the Company and/or its licensors. The reproduction, copying, public communication, distribution, modification, transformation, suppression, manipulation and any other form of use, whether for profit or not, of all or part of this Website or any of its contents, without the prior and express written authorization of the Company or to the extent permitted by applicable law, are expressly prohibited in any case.

Personal Data Protection (Privacy Policy)

The provisions of our Privacy Policy shall apply to any personal data provided or processed through this Web Site.

Contacts

The User agrees to receive e-mails from us in connection with the Website and the Company's services, if he/she uses the Company's contact form or explicitly consents to receive e-mails from us in other ways. The Company will not provide your e-mail address to any third party (unless you expressly authorize us to do so). The User consents that we may send him/her electronic communications regarding his/her requests for information or possible contracts, or when so established by law, as well as to send him/her commercial offers of our own or of certain third parties, in accordance with our privacy policy.

Links

On the Website the User may find links to other websites managed by third parties. The establishment of any links, forwards or associations ("links") with other web pages (www), made possible from the Website, does not imply that there is any kind of relationship, collaboration or dependence between the Company and the person responsible for the external website, and does not imply a guarantee by the Company to the User with respect to its services.

Others

The Company reserves the right to modify or delete at any time and without prior notice the contents, services and information contained in this Web Site.

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TeachersPRO: Cookies Policy

On the platform www.teacherspro.com (hereinafter the "Website") and its App, owned by Kiivetä Group Finland Oy, a company with registered office at Avenida Diagonal, no. 532, 7º, 08006, with ID 3292556-9 ("the Company") uses its own and third party cookies in order to analyze and improve the use of the Website and our services by identifying the user in certain functionalities.

What is a cookie?

A cookie is any type of file or device that is downloaded to a user's terminal equipment for the purpose of storing data that can be updated and retrieved by the entity responsible for its installation. The cookies used cannot read data from the hard disk.

What kind of cookies do you accept when browsing www.Teacherspro.com?

Identification Cookies. These cookies are used so that the user does not need to enter his password more than once in certain functionalities of the Website.

The analytical cookies are those that allow the responsible for them, monitoring the analysis of the behavior of users of the website or application to which they are linked. The information collected through this type of cookies is used to measure the activity of the websites, application or platform and for the elaboration of browsing profiles of the users of these sites, applications and platforms, in order to introduce improvements based on the analysis of the usage data of the users of the service.

In addition, so that the user can easily share content on social networks we use plug-in cookies (Facebook Connect plug-in) to exchange content on social networks or use their functionalities. These are cookies that website or application operators can integrate into their platform, in particular to enable social network users to exchange the content they want with their "friends" (they also offer other similar functionalities such as posting comments or identification on a web platform by means of the identifier on the social network).

Third parties involved in cookies that the "Web site" employs:

The third parties involved in the use of the cookies we use are the following information society service providers, and you can consult their conditions on cookies in the following links:

"Google" (we use their analytics cookies):
https://www.google.com/policies/technologies/cookies/

"Facebook" (we use their connectivity cookies):
https://www.facebook.com/about/privacy/cookies
https://developers.facebook.com/docs/plugins/

Withdraw consent

It is necessary to consent to the Cookies Policy of this Web Site to use the services of the Web Site as cookies are an inseparable part of our service.

To withdraw consent to this Cookie Policy:

• First, you must stop browsing the "Website" or you will be deemed to be re-consenting to this Cookie Policy.
• You must then delete the cookies stored on your equipment (computer or mobile device) through the settings and configurations of your Internet browser (we provide links explaining how to do this a few lines below).
• You should not return to browse the Website or you will be deemed to be re-consenting to this Cookie Policy.

There are instructions available to configure how cookies work and delete them in these browsers (which are the most used) Chrome, Firefox, Internet Explorer 10, Internet Explorer 9, Internet Explorer 8, Safari and Opera. For other programs you should consult the help documentation for each browser.