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GAIN privacy policy

GAIN is a Rewire brand (collectively, “GAIN”, “we”, “us” or “our”), fully owned by MI Company B.V., registered in the Netherlands. In our privacy policy, you can read what data we collect, why we collect it and what we do with it. We care about your privacy and we keep your personal data as safe as possible. In the process of collecting and processing your data, we always abide by the General Data Protection Regulation (GDPR) of the European Union.

This privacy policy is applicable to all services of The Global Artificial Intelligence Network (hereafter: GAIN). This includes the website, our digital learning portal, training sessions and events. Note that the website also contains links to other sites. We are not responsible for the content or privacy practices of such other sites, we encourage our users to be aware when they leave our website and to read the privacy statements of any other website that collects personally identifiable information.

GAIN acts as the data controller under the GDPR. This means that the entity manages and uses your personal data in connection with its specific relationship with you. You can find the name and address of the GAIN entity in the “Contact” section.

In this privacy policy, when we refer to “personal data”, we mean any information that identifies, relates to, describes or could be reasonably linked, directly or indirectly, to an individual, as defined by the GDPR. This includes not only private or sensitive information but also details such as your name, date of birth, and email address. It does not include aggregated or anonymized data that cannot reasonably be connected to an individual.

Table of contents

Overview of processing activities
Cookies and other tracking technologies
Your rights regarding your personal data
Data retention
Data security
Distribution of personal data to third parties
Contact
Updates to the Privacy Policy

1. Overview of processing activities

Training sessions and events

GAIN provides training sessions to its participants, in person and online. In order to provide these training sessions with the intended level of quality, GAIN processes the following personal data:

Contact information
Information on company, department, role
Enrollment & attendance information of trainings
Optional: Dietary restrictions

For specific training programs, additional information may be stored to provide the best support to training participants. For example, during multi-week programs, we may process skill progress, which includes high-level evaluations of personal strengths and development areas (e.g., presenting, coding).

Digital learning environment

When you participate in trainings provided by GAIN, you will be granted access to the digital learning management system (LMS). In this learning environment you are able to create an account including single sign-in (SSO) access, view your coming and past trainings, perform pre-work, view the training content, perform in-training exercises and evaluate the training. GAIN processes the following personal data to ensure services of the intended quality and operational continuation:

Account information and contact details
Course completions
Assignment and exam progress and results
Provided feedback to trainings and trainers
Posted content by users (e.g. on discussion forums)

Marketing

In order to improve our services and means of education, and in addition to the general profile information that is necessary to provide our services, GAIN collects feedback on training content and delivery, course completion rates, and participant engagement for marketing purposes. This information will be used on an aggregated level to inform new potential clients and participants about the services from GAIN.

As some GAIN courses are aligned with other (follow up) courses, GAIN sees it as inherent part of its service to map the possibilities for further growth for its participants. GAIN will thus collect participant information including role, work experience and sector combined with personal data obtained during trainings including feedback on training content and delivery, course completion rates, learning progress, and participant engagement metrics to provides an insight in the most suitable development path per course participants.

Any participant can manage their settings through the link provided in the communication or by contacting GAIN through info@GAINacademy.com.

Photographs made during trainings and events
GAIN captures photographs and video for marketing and community-building purposes. Non-staged imagery and background pictures that focus on the overall environment of an event will be taken based on legitimate interest. GAIN respects your privacy and personal boundaries, and therefore we ensure you will be made aware when photography/filming takes place and distancing/framing will be used in photographs/videos to avoid direct identification.

In case of staged imagery or clearly identifiable close-ups, explicit consent will be from individual by means of a written consent form or by agreeing during enrollment of an event.

Recruiting

In some cases, GAIN recruits participants on behalf of third parties to take part in GAIN’s services. In this recruitment process, personal data is stored for potential participants, that GAIN obtains from the participants directly or through their employer in case of contact information. The overall outcome of the recruiting process will be shared with your employer. The following personal data may be processed:

Contact information
Information on employer, department, role
Resumé
Capacity test results
Interview results
Extra content provided during application (e.g. e-mail contact)

Trainers
About trainers, accredited by GAIN to perform trainings, GAIN processes additional personal data. The following data is processed in order to provide the services of GAIN:

Availability
Certifications, languages and skills
Feedback provided by participants
Content provided to trainings, including suggestions, remarks and feedback

The data will be processed for operational purposes, to plan and manage trainers at training sessions and to improve our services by incorporating feedback provided by the trainer and participants. Evaluations of participants will be collected, and shared with trainers anonymously.

Third party sources
In the course of our business operations GAIN may obtain personal data from third-party sources such as clients (e.g., companies you have worked with), data providers (e.g., business data aggregators or services), or publicly available sources (e.g., social media platforms, professional networking sites like LinkedIn, and other online forums). Such information may encompass contact details, professional data, and other publicly accessible content, including information you have made available on social media platforms or other online forums. This data may be combined with information already in our possession or collected directly through GAIN to provide a personalized experience in specific training sessions.

Legal basis for processing your personal data
In general, any processing of personal data is prohibited by law unless explicitly permitted. We handle your data only under the following conditions:

‘Consent’: If you have voluntarily agreed in an informed manner to our terms and this privacy policy, this will be considered your consent to process your personal data as outlined, unless the law specifies otherwise (Article 6 (1) (a) GDPR).
- This applies to staged / close-up photographs and video made during trainings and events
‘Legitimate Interests’: If the processing is necessary to serve our legitimate interests, such as legal or business interests, provided these interests do not outweigh your rights or interests (Article 6 (1) (f) GDPR).
- This applies to training sessions and events, digital learning environment, marketing, non-staged / background photographs and video, recruitment, trainers and third-party sources

2. Cookies and other tracking technologies

The website and learning portal of GAIN uses cookies and similar technologies (like pixels and tags) to enhance and maintain our services, improve performances, optimize marketing, and provide a better user experience by tracking preferences, securing our platform, and identifying technical issues. What cookies are, the types we use and how to disable them is explained below.

Cookies are small files stored on your computer or mobile device via your browser. They let websites remember user preferences and recognize you during and after visits. Cookies can be ‘session cookies’; (deleted when you close the browser) or ‘persistent cookies’ (stay until deleted or expired). Cookies may be set by us (first-party cookies) or by third-party partners (third-party cookies) and vary in duration. Note that our control over third-party Cookies is limited to their policies. You don’t have to accept all cookies to use our website but enabling them can enhance your experience and is necessary for certain features. A previous choice regarding the acceptance of cookies can be changed at any time by clicking on the link ‘your settings’.

How do we use Cookies?
The learning portal of GAIN uses different types of Cookies:

Necessary Cookies: these are essential for providing our services and cannot be disabled via our cookies settings. While you can remove them through your browser, doing so may significantly affect your experience. For instance, these cookies manage your login session and ensure access to specific features or areas of your account.
Performance and Analytics Cookies: these cookies help us understand how users interact with our services by collecting data on visitor numbers, usage, patterns and preferences. They improve the performance and functionality of our platform, ensuring a better user experience. Without them, our ability to enhance the services is limited.
Marketing & Advertising Cookies: these cookies track your interaction with ads and help us and our partners deliver relevant advertisements based on your browsing habits. They allow for retargeting and ensure ads align with your interests, such as showing product-related ads on other sites after visiting specific pages.
Third-Party Integration Cookies: these cookies are set by external services integrated into our platform to improve their functionality and performance or tailor their features to you.

The use of Google Analytics Cookies
Our services use Google Analytics, a web analytics tool from Google Inc. (‘Google’) that relies on cookie technology. Data collected by these cookies is typically sent to Google servers in the USA for storage. Google processes this information on behalf of the learning portal of GAIN to analyze website usage, create reports on site activity, and provide additional services related to website and internet usage. Your IP address, collected through your browser, is not combined with other Google data. For more details about Google Analytics’ privacy practices, visit https://www.google.com/policies/privacy/partners/. To opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout. We only have operational knowledge of and no control over these cookies. Consequently, we accept no responsibility or liability for these social medial cookies or for how the social media providers might use the collected information.

3. Your rights regarding your personal data

Under Articles 15-21 of the GDPR, you have the following rights regarding your personal data with the learning portal of GAIN:

Right to Access: the right to request a copy of your personal data (Article 15 GDPR). This means that you can request which personal data is registered for you, for which purposes the data is used, information about the third parties with whom the data may be shared and, where possible, information about the retention period of the data. The right to access personal data does not extend to personal data of persons other than yourself;
Right of Correction: ask us to update or correct inaccurate or incomplete data (Article 16 GDPR);
Right to Deletion: You have the right to request that we delete your personal data (Article 17 GDPR).”
“Right to Restriction: You have the right to request that we limit the processing of your data in certain circumstances (Article 18 GDPR).
Right of Objection: object to how we process your data, including for marketing purposes (Articles 21 & 22 GDPR);
Right to File Complaint(s): if unsatisfied with our handling of your data, you can contact the relevant supervisory authority (Article 77 GDPR). However, we encourage you to contact us first to address your concerns.

You can exercise your rights by contacting GAIN via the contact information as stated in section 7.

Withdrawing Consent or Objecting to Processing
You can withdraw consent for data processing at any time (Article 6 (1) (a) GDPR).

For processing based on legitimate interests (Article 6 (1) (f) GDPR), you can object, particularly for marketing purposes.

Opposing to the processing of your data
You have the right to have your data erased if any of the following applies:

The data are no longer needed for their original purpose.
You no longer consent to the processing of your data and there is no other legal justification for the processing.
You object to the processing of your data and there are no overriding grounds to continue processing.
The data has been processed unlawfully.
The data has to be erased in order to comply with EU or national law.

Unsubscribe from marketing communication
You can manage your settings for receiving our communication or unsubscribe through the link provided in the communication. You can also contact GAIN directly to stop receiving communication or change the communication you would like to receive.

4. Data retention

We retain personal data based on legal storage periods and delete or block it once these periods end or the purpose for storing is no longer relevant, following data protection regulations. If you have consented to a longer storage period, we will delete or block your data when that period ends or if you withdraw your consent. How long certain data is stored depends on the nature of the data and the purposes for which it is processed. The storage period can, therefore, differ per goal. Personal data on training sessions and events, the digital learning environment, recruiting and from trainers will be stored no longer than five years after last contact, in order to ensure operational continuation in case of additional trainings / events by the participant.

After the retention period has expired, your personal data will be deleted or anonymized. Anonymization means that your personal data is stripped of all possible identifying characteristics. What remains is statistical data that can no longer be linked to your person in any way. These statistical data are important to us because we can GAIN insight into the use of our products and services.

5. Data security

We comply with applicable data protection laws. We have taken technical and organizational measures to ensure the protection of data. The data processed via GAIN is subject to the same protection standards as the data processed at Rewire (ISEAE3402). For more information on the variety of measures; please reach out to info@rewirenow.com.

6. Distribution of personal data to third parties

GAIN is committed to safeguarding the personal information you share with us. This section outlines the specific situations in which your personal information may be disclosed to third parties.

Your organization
If you’re using GAIN Services in connection with your employer or other organization or entity, your company’s own account administrator or manager may have access to some information associated with you and connected with the GAIN domain they manage.

Personal data connected to course completions and attendance will be shared with your account administrator to comply with the agreements made with your employer and thereby serve the legitimate interests of GAIN and your employer.

For multi-week training programs, GAIN may ask for participants consent to share additional personal data. Information on training progress, personal development and personal skills will be shared with your account administrator or manager. Training participants may grant consent using an explicit written consent form given by. It serves the participants best interest, to aid in their professional development.

Personal data may also be shared with your organization for recruitment purposes for the services of GAIN. We ask your prior consent to share personal data processed for recruitment purposes.

GAIN trainers
When you enroll for a training session, the trainer has access to enrolment, assignment, pre-work and exam information of that specific training session. Feedback will be shared in an anonymized form only.

GAIN community
In our community you are able to upload and share comments or feedback publicly with other GAIN users. Any information that you disclose in this forum is not confidential, and GAIN may use it for any purpose.

Service providers
To provide our services effectively, GAIN engages third-party companies ("sub-processors") to process personal data on our behalf. GAIN ensures that each sub-processor implements appropriate technical and organizational measures to protect your data in compliance with applicable data protection laws. GAINs sub-processors include: Microsoft Azure & 365, Amazon Web Services for administration of personal data and Docebo as provider for the digital learning environment.

Distribution of data to other countries
We may share your data with our offices or partners in other countries. This shall only be done to a country outside of the European Economic Area without an adequate level of protection if such transfer is allowed under applicable law and involved parties guarantee the same level of protection as required by the GDPR. GAIN transfers data on the basis of an Adequacy Decision by the European Commission (Article 45, GDPR). When the participant or employer is located outside the European Economic Area or countries that fall under Article 45, GDPR, only the personal information that is necessary to perform the agreement between GAIN and the participant will be shared (Article 49, GDPR).

Other cases in which we may distribute your data
There are special circumstances in which we may distribute your data to other third parties than our partners. We may disclose your information if there is a reasonable belief that disclosing this information is necessary to identify, contact, or bring legal action against someone, to detect fraud, or to protect our rights or property or the safety and security of our website, our business or the general public.

7. Contact Information

If you have any questions regarding this privacy policy, please contact us.

MIcompany B.V., trading under the name Rewire, Mauritskade 55G, 1092 AD Amsterdam, Email: info@gainacademy.com

As an individual using our services, you have the rights regarding the data that is collected about you, as described in section 3 of this privacy policy. You can submit a request to exercise any of the rights by sending an email to info@gainacademy.com with:

your name;
your address;
your fixed and/or mobile phone number;
a copy of your valid proof of identity.

We provide you with a reply to your request without undue delay and at the latest within one month.

8 Changes to this privacy policy

We may change all or part of our Privacy Policy from time to time to reflect our data collection practices, in case of new features involving your personal data, or as required by the law. The version published on the GAIN main website will be the most current version in force. Changes to our Privacy Policy will be effective immediately once published. We invite you to periodically review our Privacy Policy to be informed of any relevant changes, especially before providing any data to us. Where required, we will actively inform you of such updates.

Contact Details

GAIN Academy
Mauritskade 55G,
1092 AD AMSTERDAM
info@gainacademy.com
https://rewirenow.com
T. +31 20 715 52 90
F. +31 20 715 52 91