At Sinapsia Group Finland Oy (“we”, “our”, “us”), we are committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose and protect your personal data, in compliance with the General Data Protection Regulation (GDPR), the Finnish Data Protection Act (Tietosuojalaki 1050/2018), as well as the German Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG) to ensure compliance with current regulations in Germany.

1. Responsible for Data Processing

Sinapsia Group Finland Oy, with address at c/o Werstas — 440, Tykistökatu 4, 20520, Turku, Finland, is the entity responsible for the processing of your personal data.

2. Personal Data We Collect

We collect personal data that you provide directly to us, including:

• Contact Information: name, email address, telephone number, and mailing address.
• Professional details: title, employer and professional qualifications.
• Usage Data: Information about how you use our services, including log data and cookies.

3. Purpose and Legal Basis of the Treatment

We process your personal data for the following purposes:

• Service Delivery: To provide and manage our educational services.
• Communication: To send you updates, newsletters and information about our services.
• Legal Compliance: to comply with legal obligations under Finnish legislation and the GDPR.
• Legal Compliance: to comply with legal obligations under Finnish legislation, the GDPR and the current German data protection law (Bundesdatenschutzgesetz, BDSG) where applicable.

The legal bases for the processing of your data include:

• Execution of a Contract: when the treatment is necessary for the execution of a contract to which you are a party.
• Legal Obligation: when treatment is necessary to comply with a legal obligation.
• Legitimate Interests: when the processing is necessary for our legitimate interests, provided that these are not overridden by your rights and interests.

4. Sharing and Transferring Information

We do not share your personal data with third parties, except in the following circumstances:

• Service Providers: We may share data with service providers who perform functions on our behalf, subject to strict data protection agreements.
• Legal Requirements: We may disclose data to comply with legal obligations or respond to requests from public authorities.

If we transfer your data outside the European Economic Area (EEA), we ensure that there are adequate safeguards, such as Standard Contractual Clauses approved by the European Commission.

Sharing and Transferring Information

We do not share your personal data with third parties, except in the following circumstances:

• Service Providers: We may share data with service providers who perform functions on our behalf, subject to strict data protection agreements, in compliance with the General Data Protection Regulation (GDPR), the Finnish Data Protection Act (Tietosuojalaki 1050/2018) and the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG), as appropriate.
• Legal Requirements: We may disclose data to comply with legal obligations or to respond to requests from public authorities, in compliance with the regulations established in the GDPR, as well as the specific provisions of the data protection laws in force in Finland and Germany.
• International Transfers: If we transfer your data outside the European Economic Area (EEA), we ensure that there are adequate safeguards, such as Standard Contractual Clauses approved by the European Commission, in line with the additional requirements of the German BDSG and Finnish legislation, to ensure the security and protection of your data.

5. Information Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure or destruction. However, no method of Internet transmission or electronic storage is completely secure.

6. Data Retention

We keep your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Once the data is no longer needed, we will securely delete or anonymize it.

Data Retention

We keep your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws, including the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and the Finnish Data Protection Act (Tietosuojalaki 1050/2018). We comply with the requirements of both legislations to ensure that data is securely deleted or anonymized when it is no longer needed, maintaining clear procedures for defining and limiting retention periods in accordance with the principles of minimization and storage limitation.

7. Your Rights

Under the GDPR and the Finnish Data Protection Act, you have the following rights:

• Access: get confirmation as to whether we are processing your personal data, and access to them.
• Rectification: request the correction of inaccurate or incomplete data.
• Deletion: request the deletion of your data under certain conditions.
• Restriction: request the limitation of treatment under certain circumstances.
• Data Portability: receive your data in a structured, commonly used and readable format, and transmit them to another responsible party.
• Opposition: object to processing based on legitimate interests or for direct marketing.

To exercise these rights, please contact us at:

• Email: info@teacherspro.com
• Postal address: c/o Werstas — 440, Tykistökatu 4, 20520, Turku, Finland

You also have the right to file a complaint with the Finnish Data Protection Ombudsman. For more information, visit the Data Protection Ombudsman's website.

Your Rights

In accordance with the GDPR, the Finnish Data Protection Act (Tietosuojalaki) and the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG), you have the following rights:

• Access: obtain confirmation as to whether we are processing your personal data and access them, in accordance with Finnish and German regulations.
• Rectification: request the correction of inaccurate or incomplete data, a right guaranteed by the GDPR and adapted in the BDSG and the Tietosuojalaki.
• Suppression: request the deletion of your data under certain conditions, in accordance with the provisions of both the GDPR and Finnish and German regulations.
• Restriction: request the limitation of treatment under certain circumstances, in line with the requirements of both national laws and the GDPR.
• Data Portability: receive your data in a structured, commonly used and readable format, and transmit them to another controller; a right reflected in the laws of Finland and Germany and the GDPR.
• Opposition: object to processing based on legitimate interests or for direct marketing, in accordance with the data protection rights of users established in Finland and Germany.

To exercise these rights, please contact us at:

Email: info@teacherspro.com

Postal address: c/o Werstas — 440, Tykistökatu 4, 20520, Turku, Finland

Telephone: +358 451446090

You also have the right to file a complaint with the relevant data protection authorities, either the Finnish Data Protection Ombudsman or the German Federal Data Protection Authority (BfDI). For more information, visit the website of the relevant data protection authority.

8. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the new policy on our website and, where appropriate, by other means. We recommend that you review this policy regularly.

However, we are committed to carrying out a:

Active notification of significant changes: In case of significant changes to the privacy policy, it will be updated on the website. For significant changes in the processing of personal data (for example, changes in the purposes or in the rights of users), we will carry out a direct notification to users via email.

Justification for changes: In case of significant changes, a brief explanation or justification of the changes made will be included, especially if they affect the rights of users or the processing of their data, to ensure transparency.

Review and Acceptance Option: For changes that involve user consent (such as new treatments that are not based on a legal obligation or legitimate interest), it may be necessary to request consent again.

9. Contact us

If you have questions or concerns about this Privacy Policy or our data processing practices, please contact us at:

• Email: info@teacherspro.com
• Postal address: c/o Werstas — 440, Tykistökatu 4, 20520, Turku, Finland
• Contact phone number: +358 451446090

By using our services, you acknowledge that you have read and understood this Privacy Policy.

Last updated: June 30, 2025.

This improved version of the Privacy Policy is designed to be clear, concise and comply with applicable data protection regulations, including the GDPR and the Finnish Data Protection Act.

This improved version of the Privacy Policy is designed to be clear, concise and comply with applicable data protection regulations, including the GDPR, the Finnish Data Protection Act (Tietosuojalaki 1050/2018) and the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG). In compliance with these laws, we guarantee respect for the rights of users over their personal data, such as access, rectification, deletion and portability of data, as well as the implementation of appropriate technical and organizational security measures to protect personal data against unauthorized access or undue disclosure, in line with the high standards required in both Germany and Finland.

TeachersPro Privacy Policy

This Privacy Policy (the “Policy”) sets out the conditions applicable to the processing of personal data by Sinapsia Group Finland Oy (“TeachersPro” or “we”) and its Users, at app.teacherspro.com or through other websites or applications owned by TeachersPro that refer to this Policy.

Unless otherwise required by mandatory local regulations, this Policy is governed by the laws of Finland.

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 notification on our Services and in this Policy and/or by email to the address you have provided us for these purposes.

This Privacy Policy (the “Policy”) establishes the conditions applicable to the processing of personal data by Sinapsia Group Finland Oy (“TeachersPro” or “we”) and its Users, on app.teacherspro.com or through other websites or applications owned by TeachersPro that refer to this Policy.

We are committed to complying with Finnish data protection regulations, including Finnish Data Protection Act (Tietosuojalaki 1050/2018), as well as with the data protection legislation in force in Germany, Bundesdatenschutzgesetz (BDSG), for users and situations to which it applies. Both laws complement compliance with the General Data Protection Regulation (GDPR) of the European Union, guaranteeing high standards of protection and transparency in data processing.

Unless otherwise required by mandatory local regulations, this Policy is governed by the laws of Finland.

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 notification on our Services and in this Policy and/or by email to the address you have provided us for these purposes.

RESPONSIBLE FOR TREATMENT

Full name of legal entity: Sinapsia Group Finland, Oy

Address: c/o Werstas — 440 Tykistökatu 4, 20520, Turku, Finland, registered in the Finnish Commercial Register with ID 3292556-9.

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

+358 451446090

DATA COLLECTION

In accordance with the General Regulation for the Protection of Personal Data (RGPD 2016/679 EU) (and the regulations 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 of the processing of their data in accordance with this Policy.

• Navigation. We do not collect any type of personal data if you are only browsing our Services without identifying yourself as a registered user, except in the cases indicated in the cookie 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 the name and email address and data of technicians who have accepted this form (logs, IP, time, date and similar). The mandatory data are indicated. This data is used to process your request (depending on the form) and to contact you for future notifications. The mandatory data are marked as such on the form and if not provided the request will not be accepted.
• User registration. When applying for admission to a TeachersPro service, we collect the following personal data as a Registered User (as defined in the General Conditions): country, region, name, surname and email address, photograph, password, Primary Educational Institution and Secondary Educational Institution (as indicated in the form), subscription data, and technical data as you have accepted this form (logs, IP, time, date and similar). The mandatory data are marked as such on the form and if they are not provided, registration cannot be carried out.

Prohibited sensitive data. In ANY CASE, 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; membership of a trade union; religion, ideology and sexual orientation; health; or data relating to criminal records, procedures and sanctions or fines of any kind, linked to domestic violence or Curriculum Vitae or similar sets of personal data that provide a definition of the characteristics or personality of citizens and that make it possible to evaluate certain aspects of their personality or behavior.

PURPOSES OF DATA PROCESSING

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

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

• Management, execution and development of the Services
• Management of all Institute's own activities in relation to the User
• Maintain contacts with the User and inform them about our Services, as well as for future communications about new services, offers or promotions related to the products and services offered by TeachersPro;
• Provide you with information or registration of associated or collaborating companies of Sinapsia Group Finland Oy for your training or professional development. Even providing you with information about these companies if you accept that purpose.
• Manage any newsletters, notification emails or general commercial communications relating to the Services and products and any new features, offers or promotions that we offer,
• Comply with the applicable General and Particular Conditions, and with other legal requirements, as well as for the legal defense of TeachersPro and its interests.
• Analysis of the use of the Service for the purpose of improving it or drawing conclusions from the education sector.

LEGAL BASIS

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

• Contract Execution: The processing of registered user data is necessary for the execution of a contract to which you are a party or to take action when you request it before entering into such a 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 most secure experience. We make sure to 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 that such use has on you (unless we have your consent or the law requires or otherwise allows it). You can obtain more information on how we evaluate our legitimate interests in order to avoid any possible impact on you, with respect to specific activities, by making the inquiries you consider appropriate in the email indicated at the beginning
• Meeting a legal or regulatory obligation means processing 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 the processing of your personal data other than in connection with the sending of commercial communications by email or text message. You have the right to withdraw your marketing consent at any time by contacting us at contact@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. Get in touch with us at contact@teacherspro.com, if you need details about the specific legal basis.

THIRD PARTY DATA PROCESSING.

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

• your ratings with respect to other TEACHERSPRO Users provided for in the Services themselves; and
• data from third parties who have expressly consented to the processing of the same in our Services, that is, with the informed consent of the third party owner of such data (or of their parents/guardians, if any) as well as the express authorization in this regard with TeachersPro, once TeachersPro has submitted evidence of the corresponding consents through the procedure established on the Portal, but by email to contact@teacherspro.com.

Evidences and other resources that are uploaded to the platform: Each User must, to the extent possible, delete or anonymize any information containing personal data of third parties in the content and materials uploaded by the User to the Portal (e.g. documents with names of students or students, photographs with the faces of third parties). To the extent that 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 User content (s) to the Website or Portal containing personal data of third parties who are not Users (“Non-User Third Party Data”, for example, name and surname or photos of students, films, etc.), the User (“Responsible User”) undertakes to obtain the informed consent of such Non-User Third Parties or their Legal Guardians appropriate to this Privacy Policy and also:

• It 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 are responsible for the file or files of the said personal data under applicable legislation.
• TeachersPro is obliged and guaranteed that, at the request of the company (by email to the email address indicated at the time of registration or the one appropriately indicated for this purpose by the User through the Portal before the communication process), it will immediately send as soon as possible evidence both of compliance - on its part or that of the Responsible Third Party - both with the collection of the necessary informed consent and of the other obligations as responsible for the file or files.

TeachersPro will delete any third-party personal data provided by a User if it discovers that the publication of the same through the Portal does not comply with these conditions.

For any questions, please contact us at:

contact@teacherspro.com.

DISCLOSURE

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

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

• Service providers who 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 assets. Alternatively, we may seek to acquire other companies or merge with them, if we are part of a bankruptcy proceeding or other change of control.
• 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.

In addition, we will disclose any information, whether personal or not, about the User or the User's use of our Services (a) in accordance with a legal obligation, or (b) to comply with other obligations in accordance with the applicable regulations and rules established in the Portal Terms. In particular, your username will be visible in any contribution you make to the Portal (post, uploaded material) in order to identify your origin and/or author.

In addition, in order to provide our Services correctly and always in accordance with the instructions indicated by the User (including the configuration of the User's Service and their 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 himself):

• 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 will be able to view their personal data (this entity must request your consent and inform you of this according to the means that the entity itself deems necessary).

INTERNATIONAL DATA TRANSFER

The personal data of the User indicated for this purpose by the User (in accordance with their 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 purpose of participating in the TEACHERSPRO User community and fostering relationships between Users.

In those cases in which the Responsible User transmits “Non-User Third Party Data” content to the Website or Portal, he undertakes 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).

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

The Service involves two data treatments for which TeachersPro is not responsible for processing:

(a) Users' access to the personal data of other Users who are treated under their responsibility (“Responsible User”), for which TeachersPro is a data processor; and, where appropriate,

(b) the access of TeachersPro and other Users to “Non-User Third Party Data” (as defined in clause 4 of this policy) that are treated under the responsibility of the Responsible User or a Responsible Third Party.

As established in the applicable European personal data protection regulations (RGPD), these accesses by a User and/or TeachersPro (hereinafter, “Processor”) will not be considered communication or transfer of data, but rather of simple access to third-party data necessary for the provision of the Services (including but not limited to, the functions of viewing and evaluating the activity of other Users), and, consequently, the Processor, —when accessing such data- will consider” processor” of such data, and for this purpose the provisions of Annex 1 shall apply.

In case of breaching the obligations set out in Annex 1, the User as “processor” will be considered responsible for the treatment and will be responsible for the violations that he has personally incurred, exonerating TeachersPro and any other person responsible for the file of the accessed data (without prejudice to the possibility of terminating the contract by TeachersPro).

OWN COMMERCIAL COMMUNICATIONS AND THOSE OF THIRD PARTIES

By filling in and sending us their personal data (by clicking on the corresponding box), the User expressly accepts to receive electronic commercial communications from us related to Instituto products and services, including alerts, notifications, newsletters, offers and promotions from TeachersPro and third parties (see next paragraph). If you do not want to receive these commercial communications, please let us know in the form or as indicated in each of these commercial communications.

In addition, the User consents to the sending of communications - including electronic and commercial communications - about their own services or products or those of third parties (partners or collaborators of TeachersPro) for advertising or commercial prospecting in the fields of training and education, publishing, and consumer products.

THIRD-PARTY LINKS AND SOCIAL MEDIA 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 recommend that you read the privacy notice of each website you visit.

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

You should be aware that personal data that you voluntarily include and transmit online on a blog, social network or other publicly accessible medium can 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 the personal data you provide may be viewed and used by third parties.

DATA SECURITY

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, 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 it. They will only process your personal data according to our instructions and will be subject to a duty of confidentiality.

We have implemented procedures to deal with any suspected personal data breach and will notify you, as well as any relevant regulatory entity, of any breach as long as we are required to do so by law.

We have implemented the necessary technical and organizational security measures to protect your personal data against loss, use or unauthorized access, modification or disclosure, in compliance with the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and the Finnish Data Protection Act (Tietosuojalaki 1050/2018). These measures include restricted access controls and encryption protocols that limit access to your personal data only to employees, agents, contractors and third parties who need to know it for business reasons. These individuals and entities will process your personal data in accordance with our instructions and will be subject to a duty of confidentiality, in accordance with the requirements of both laws.

In addition, we have implemented specific procedures to manage any suspected personal data breach and, in the event of a breach, we will notify you and the competent regulatory authorities, such as the Finnish Data Protection Commissioner or the German Data Protection Authority (BfDI), in compliance with the notification requirements of both legislations.

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DATA RETENTION

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

To determine 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 the applicable legal requirements.

In some circumstances, you can ask us to delete your data: see Deleting 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.

YOUR LEGAL RIGHTS

Under 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 “request for access to a data subject”). This allows you to receive a copy of the personal data we hold about you and to verify that we are lawfully processing it.
• Request the correction of the personal data we hold about you. This allows you to correct any incomplete or inaccurate data we have about you, although we may need to verify the accuracy of the new data you provide to us.
• Request the deletion (cancellation) of your personal data. This allows you to ask us to delete your personal data when there is no good reason for us to continue processing it. You also have the right to ask us to delete your personal data when you have successfully exercised your right to object to the processing (see below), when we may have processed your information illegally or when we must delete your personal data in compliance with local law. However, please note that we may not always be able to comply with your removal request for specific legal reasons that you will be notified, if any, at the time of your request.
• To object to the processing of your personal data when, even if 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, since 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 can demonstrate that we have legitimate, legitimate interests in processing your information that outweigh your rights and freedoms.
• Request the restriction of the processing of your personal data. This allows you to ask us to suspend the processing of 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 illegal 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 opposed our use of your data, but we must verify if 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 to information necessary for the conclusion of any contract with you.
• Withdraw consent at any time when we rely on consent to process your personal data. However, this will not affect the legality 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 let you know if this is the case at the time you withdraw your consent.

You won't have to pay any fees to access your personal data (or to exercise any of the 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 under these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure 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 does not have the right to receive it. We may also contact you to request more information in connection with your request to expedite our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us more than a 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 data protection authorities that you consider appropriate.

To exercise your rights, please contact us at:

 contact@teacherspro.com.