د محرمیت پالیسي

This privacy policy applies specifically to the Begum Academy mobile application. Our privacy policy is based on our commitment to these privacy principles: We are deeply
committed to creating a safe and secure online environment for you. The protection of your
information is a priority for us, and we are implementing protocols to ensure the security of your
data. Additionally, our staff is highly vigilant about the security and confidentiality of information.
We do not sell your personal information to third parties. As an NGO, the Begum Organization for
Women places education at the heart of its mission, and your trust is our priority. Our goal is not to
make a profit, but to offer you free access to quality education. We strive to provide you with access
to your personal information, and we take the protection of your data very seriously. We are
committed to respecting your privacy rights. We take extra precautions to protect the privacy of
young learners, as outlined in our children’s privacy notice. We are working to implement
appropriate restrictions to ensure that children cannot post or disclose their personal information
through their accounts. We do not display third-party advertisements on Begum Academy. Our
mission is to provide you with world-class education, not to sell you products.

Overview

The Begum Organization for Women is a nonprofit organization based in France. We use the
information we collect to provide you with an optimal experience and to fulfill our mission of
offering free and accessible education to all girls and women, particularly those in Afghanistan. Our
goal is to promote the empowerment of girls and women, especially in areas where access to
education is limited. However, our platform is open to all women and girls, including Afghan
refugees in other countries, and anyone seeking to access our courses.
We are deeply committed to protecting your privacy. We understand the importance of
confidentiality for our users, and we are dedicated to creating a safer environment for learners of all
ages. This privacy policy explains how information is collected, used, disclosed, and protected by
Begum Academy when you use our mobile app and online services.

Article 1. Principles regarding the collection and processing of personal data

In accordance with Article 5 of the European Regulation 2016/679, personal data must be:

Processed lawfully, fairly, and transparently with respect to the data subject;
Collected for specified, explicit, and legitimate purposes and not further processed in a
manner incompatible with those purposes;
Adequate, relevant, and limited to what is necessary in relation to the purposes for which
they are processed;
Accurate and, where necessary, kept up to date. All reasonable measures must be taken to
ensure that inaccurate personal data, with regard to the purposes for which they are
processed, are erased or rectified without delay;
Stored in a form that allows the identification of data subjects for no longer than is necessary
for the purposes for which they are processed;
Processed in a manner that ensures appropriate security of the collected data, including
protection against unauthorized or unlawful processing and against accidental loss,
destruction, or damage, using appropriate technical or organizational measures.

Processing is only lawful if, and to the extent that, at least one of the following conditions is met:

The data subject has given consent to the processing of their personal data for one or more
specific purposes;
The processing is necessary for the performance of a contract to which the data subject is a
party or for the implementation of pre-contractual measures taken at their request;
The processing is necessary for compliance with a legal obligation to which the data
controller is subject;
The processing is necessary to protect the vital interests of the data subject or another natural
person;
The processing is necessary for the performance of a task carried out in the public interest or
in the exercise of official authority vested in the data controller;
The processing is necessary for the purposes of the legitimate interests pursued by the data
controller or by a third party, except where such interests are overridden by the interests,
fundamental rights, and freedoms of the data subject requiring the protection of personal
data, particularly when the data subject is a child.

If you have any questions about the processing of your data or your rights, please feel free to
contact us for more information at [email protected]

Article 2. Collection of information

We collect information in several ways, depending on how you use our Service and the settings of
your account:

Information collected directly from you: such as when creating your account, communicating
with us, or engaging in specific surveys or activities.
Information collected from third parties: such as information provided by parents, teachers, or
other partners in our educational program.
Information collected automatically: such as information about your use of our service.

Here are examples of the information we collect:

Name, age, gender
Email address
Country and province (if applicable, for users in Afghanistan)
School grade (relevant to our courses)
Father’s name
School documents (optional)
Previous school
Identication document, such as Tazkira (required for exam registration)

I. Information you provide to us:

Contact and prole information. When you create an account on the Begum Academy
app, we may collect information such as your name, email address, date of birth, age-related
data (for compliance purposes), school document, etc. We also collect the necessary
information for authentication, such as your password. During or after registration, you may
also choose to provide additional information in your prole, such as your Tazkira.
Your communications with us. We may collect information when you contact us, for
example, if you request assistance, send us an email, provide feedback or ask questions, ll
out a user survey, or communicate with Begum Academy in any other way (including via
third-party services).
Your interactions with our services. We may also collect information when you interact
with the features of the app, such as our interactive learning tools or other elements that we
may offer.

II. Information we may receive about you from other sources

Information obtained from other users. We provide certain features on our app that allow
other users to provide us with information about you. For example, one of our teachers may
provide us with information related to students, or a parent may provide us with information
about a Minor User, such as when the parent links their account with their child’s and
provides certain information about them.
Information provided by our partners and other sources. We may also receive
information from partner organizations with which we collaborate. If we combine
information from other sources with the personal information we collect via our app, we will
treat the combined information as personal data in accordance with this privacy policy.

III. Information we collect automatically.

Information about your use of our application. We may collect data regarding your usage
of our application, such as the number of videos you have watched, the types of exercises
you have participated in, the number of times you have attempted a quiz, the subjects
studied, the time spent solving a problem, the time spent on the mobile application, quiz and
exam results, and data related to conversations and activities on Begum Academy (including
the discussion forum and interactions with teachers). This helps us tailor educational
experiences to better meet your needs.

Article 3. Use of information

Begum Academy uses the collected information for the following purposes:

Providing access to the Begum Academy educational platform.
Personalizing your learning experience, such as recommending courses tailored to your level
and learning goals.
Communicating with you about your account, our Service, and new educational resources.
You may unsubscribe from these communications at any time.
Enabling your participation in special educational initiatives conducted in partnership with
organizations that support Begum Academy’s mission.
Understanding and improving our Service, developing new educational resources, and
measuring the impact of our programs.
Measuring our impact for our funding partners.

We may also use non-personal data (such as de-identified, anonymized, or aggregated usage
information and feedback) for product development, research, analysis, and other purposes,
including analyzing, improving, or measuring the impact of our programs, or conducting
educational research.

How Begum Academy uses this information:

Providing access to the educational platform: Begum Academy uses your information to
authenticate and authorize your access to our educational resources. Your data also helps us
personalize your dashboard and present relevant content upon login.
Personalizing your learning experience: By analyzing your interactions with the platform
(courses taken, exercises completed, quizzes passed), we can recommend content tailored to
your profile and learning objectives.
Communicating with you: We use your contact information to send personalized
notifications (new courses, updates, events), respond to your inquiries, and invite you to
participate in surveys. This data helps us better understand your needs and improve our
services accordingly.
Enabling your participation in educational initiatives: Your information allows us to
inform you about opportunities to expand your knowledge, such as university partnerships,
exchange programs, specialized workshops or lessons,… We may also use your data to
assess your eligibility for these programs and offer suitable learning paths.
Understanding and improving our services: We anonymously analyze browsing data to
identify the most used features, challenges encountered, and areas for improvement. This
information helps us develop new functionalities, optimize platform usability, and create
higher-quality content.
Measuring our impact for our funding partners: By collecting data on your progress,
achievements, and satisfaction, we can demonstrate the effectiveness of our educational
programs. This data allows us to measure our social impact and secure additional resources
to support our mission.

Article 4: Your rights over your data

I. Accessing, updating, and correcting your information

You can access, update, and correct your personal information at any time by logging into your
account and modifying the relevant details in the “Profile” section.

II. Deleting your account and information

To request the deletion of your information at any time, please log into your account, go to the
settings, and contact the administrators support. You will be able to send them a message requesting account deletion, and the request will be processed as soon as possible.

Please note that your information will be retained in a backup for a maximum period of one week
following the account deletion.

In some cases, we may not be able to delete all information. For example, we may need to retain
certain data to prevent future fraud or abuse, for archival purposes, or for other legitimate business
reasons, or if required by law. Any retained personal information will remain subject to the terms of
this privacy policy.

Article 5. Retention of personal data

Begum Academy is committed to retaining your personal data only for as long as necessary to
provide our services and fulfill our objectives. Below is an estimate of the retention periods for
different categories of data:

Identification data (name, surname, father’s name, gender, Tazkira, email address):
Retained until your account is deleted.
Activity data (courses attended, exercises completed, quizzes passed): Retained for 5 years
after your last activity on the platform to help us continuously improve our services and
measure the impact of our programs.
Communication data (messages, interactions with support): Retained for 2 years after the
last exchange, unless required for dispute resolution or legal compliance.
The retention periods of your data are determined based on the nature of the data, the purposes of
processing, and applicable legal obligations.

In all cases, we commit to:

Informing you of any significant changes to our data retention practices.
Allowing you to access and rectify your personal data if it is inaccurate.
Offering you the option to delete your account at any time by sending an email to the
administrators.

I. Why do we retain your data?

To provide you with a personalized experience: Your activity data allows us to
recommend suitable courses and track your progress.
To improve our services: Analyzing your data helps us identify strengths and weaknesses in
our platform and implement necessary improvements.
To comply with legal obligations: We are required to retain certain data for a period defined
by law.

In summary, we retain your data only for the strictly necessary duration and take all necessary
measures to ensure its security and confidentiality.
These retention periods are provided for informational purposes and may be adjusted based on
regulatory changes and our operational needs.

II. How we retain and delete student personal data

We will not knowingly retain students’ personal data beyond the period necessary to achieve an
educational goal, unless authorized by the student, or the parent.

Users (or their parents) can delete their accounts and associated personal information at any time
through their profile by requesting it from admin support. For more instructions, please refer to the
section “Article 4: Your rights over your data”; “II. Deleting your account and information.”

Article 6. Information disclosure

Begum Academy places great importance on protecting the personal information you provide to us.
We do not sell your personal information to third parties. This section explains the circumstances
under which we may disclose personal information to third parties.

We may disclose personal information:

To vendors, consultants, and other service providers working on our behalf.
To other users associated with your account, such as a parent or a teacher.
As part of business transactions, such as mergers or acquisitions.
For compliance reasons, for example, when it is reasonably necessary to protect the safety
and security of our users or our service, or when permitted by law.
To offer you educational opportunities, such as programs or other initiatives aligned with
your learning objectives.

We may also disclose de-identified or aggregated information that does not reasonably identify an
individual.

Article 7. Security of your personal information

Begum Academy is committed to protecting the security of your personal information.

Here are some of the measures we implement to safeguard your personal data:

We do not use cookies or collect data related to your IP address.
We protect your personal information through encryption during its transmission over the
Internet and encrypt your personal data.
We use reasonable organizational and technical security measures designed to help protect
the confidentiality and security of your personal information.

Here are some tips to help you protect your personal information:

Your password will be created automatically. We encourage you to change it, create a strong
one, and update it every 6 months.
We encourage you to carefully consider what you share online and to stay informed about
online security.

We implement reasonable security measures to protect our Service and your personal information,
but no security measure is foolproof.

Learn more: Security of your information

The security of your information is a priority for Begum Academy.

To protect your privacy and security, we take reasonable measures to verify your identity before
granting access to your account or making corrections to your information. For example, we may
ask you to provide certain details to confirm your identity. We strongly encourage you to create and
maintain a strong password to enhance the security of your account.

We use reasonable security measures, including physical, administrative, and technical safeguards,
to protect our Service and your personal information.

Begum Academy implements reasonable security measures to protect our Service and your personal
information, but no security measure is perfect. We cannot guarantee the absolute security of all
information you transmit to Begum Academy. For example, no internet service or email
communication is ever completely secure or error-free. In particular, emails sent to or from the
Service may not be secure. Please be cautious about the information you share via email or when
requesting support.

Once we receive your information, Begum Academy makes reasonable efforts to ensure the security
of our systems. When you enter sensitive information, we encrypt the transmission of this data
using the HTTPS protocol, which secures data with SSL/TLS certificates. However, please note that
this does not guarantee that such information cannot be accessed, disclosed, altered, or destroyed in the event of a breach of our physical, technical, or administrative security measures.

If any information under our control is compromised due to a security breach, we will take
reasonable steps to investigate the situation and notify you of the security incident in accordance
with applicable laws and regulations.

Article 8. Partnerships and advertising

As a non-profit organization, Begum Academy relies on the support of its partners, donors, and
other contributors to provide the Service for free to its users.

Occasionally, we may create content in partnership with other organizations/institutions. For
example, for-profit organizations may participate in creating content related to vocational training,
such as nutrition or coding. Content created in partnership will always be visible via logos in the
videos.

Begum Academy does not disclose any of your personal information to these sponsors without your
explicit consent. We do not allow them to track or collect information about visitors or users of our
site.

Begum Academy does not display third-party ads on its Service. From time to time, we may
integrate content or links to content provided by third parties that may interest you and be relevant
in the educational context of our Service. Some of these contents or websites may include branding
elements or ads authorized by their third-party owner or operator.

Third-party links

The Service may contain links to websites operated by other entities or individuals and may also be
linked from such websites. If we include links to third parties and you click on them, you will leave
the Begum Academy platform, and the privacy policy of the respective third party will apply.
Similarly, if you see a link to Begum Academy on a third-party website, the privacy policy of that
third party applies.

For example:

If you click on a link to an educational program managed by another company, you will be redirected to that company’s website, and its privacy policy will apply.
You may choose to share information about your use of Begum Academy on social media. If you do so, the social media platform may use your information in accordance with its own privacy policies.
If you visit Begum Academy’s page on a social media platform such as Facebook or Instagram, the privacy policy of the respective social media platform will apply to that page.

Begum Academy’s privacy policy does not apply to (and we cannot control the activities of) these third-party websites.

You should review the privacy policies of these third-party websites.

Article 9. Use by children

Begum Academy is committed to complying with international laws and regulations regarding the collection and processing of personal data for minors. In accordance with the European Union’s General Data Protection Regulation (GDPR) and the relevant French laws, we do not collect personal data from children under the age of 15 without the prior consent of their parents or legal guardians.

If a child is under 15 years old, we will explicitly request parental consent before collecting any personal data. Parents or guardians must confirm their explicit agreement for the collection of their child’s personal information.

For more information on how we handle children’s personal data, please refer to our Children’s privacy notice.

We offer several types of accounts for different users of our platform: one for parents, one for students, and one for teachers.

If you have any questions or concerns about privacy, please feel free to contact us at [email protected].

Article 10. Children’s privacy notice

This privacy notice supplements our general privacy policy and provides additional information on how we collect, use, and disclose the personal information of children under the age of 15 (a “child” or “children”).

Our school is committed to respecting children’s privacy.

Protecting children’s privacy is particularly important to us. That is why we have implemented features designed to safeguard the personal information of children. When a child creates an account, we collect their information in compliance with applicable laws, including by requesting parental or legal guardian (“Parent”) consent for account creation.

I. How children can use and register for our service:

Our school does not allow children to create an account without the consent of a parent or guardian. If we learn that a child’s personal information has been collected without proper consent, we will take the necessary steps to delete this data. If you are a parent and discover that your child under the age of 15 has created an account without consent, please contact us at [email protected] to request the removal of their personal information from our systems.

II. How children can create an account in our service:

-Account creation with parental consent

When a child wishes to register, they are explicitly asked to request that their parent fill out the displayed form, which states: “If you are under 15, please ask a parent to fill out the form. As a parent, you agree that Begum Academy may use the provided data to create, manage, and personalize the account.”

-What information we collect from child users and how we use it

We collect a username, first name, last name, father’s name, country, province, gender, date of birth, email address, and, if the child chooses to submit it, a school document. We also collect information about the use of the service (lessons completed, badges earned), as well as device usage data, as described in our information collection policy. If the student wishes to take exams, we will also collect a document verifying their identity.

The collected information is used to provide the service, personalize the child’s experience with appropriate content, improve our services, develop new features, and ensure user security while complying with legal requirements.

-Disclosed information

For more details, refer to the “Information disclosure” section.

-No third-party tracking and no targeted advertising

Our service does not display targeted advertising. We do not share children’s personal information for direct marketing or targeted advertising purposes.

Article 11. Regional information

This notice supplements our privacy policy based on region-specific practices related to the services provided by Begum Academy, which is based in France.

Begum Academy’s privacy practices are designed to respect users’ privacy rights in accordance with global standards, including specific rights applicable in the European Union and other countries where our services are accessible. This includes:

The right to know what personal information we collect, how it is used, processed, stored,
protected, shared, and whether it is sold.
The right to correct your personal information.
The right to request the deletion or anonymization of your personal information.
The right to object to the use or processing of your personal information, including opting
out of its sale.
The right to withdraw your consent to the processing of your personal information.
The right to file a complaint with the relevant data protection authority, such as the CNIL in
France.
The right not to face discrimination for exercising your privacy rights.

Specific rights and procedures for exercising them may vary by country. In Europe, you may have
additional rights under the General Data Protection Regulation (GDPR). The processes and
timelines may differ depending on local laws, and we may require you or your legal representative
to verify your identity before responding to your request. It is essential to provide the required
information within the given timeframe so that we can process your request correctly in compliance
with applicable laws.

If you wish to exercise your privacy rights, please contact Begum Academy. Our ability to fulfill
certain requests may be limited by applicable laws and the functionalities of our service. For
example, we may be required to retain certain data for legitimate business reasons or because
processing is necessary to provide the service you have requested.

International data transfers

Although we are based in France, our services may be operated and managed on servers located in
Afghanistan or other countries. If you access our service from another country, you agree that
Begum Academy may transfer, store, and process your personal information in France, in
compliance with legal data protection requirements (including GDPR).

Article 12. Minor rights in France

If you are a registered user under the age of 18 residing in France, you have the right to request the
removal of content or information you have publicly posted on our Service. To exercise this right,
please contact us directly at [email protected]. However, please note that your request
does not guarantee complete or exhaustive removal, as some information or content may be retained
under applicable laws.

If you reside in France or another European Union country, you have the following rights under the
General Data Protection Regulation (GDPR):

Right of access and portability: You have the right to access your personal information, as
well as certain related information, and to receive this information in a structured, commonly
used format, and to have it transferred to another data controller.
Right to rectification: You have the right to obtain the rectification of your personal
information when it is inaccurate or incomplete, without undue delay.
Right to erasure: You have the right to obtain the erasure of your personal information in
certain circumstances, such as when the data is no longer necessary for the purposes for
which it was collected or processed.
Right to restriction of processing: You have the right to request the restriction of the
processing of your personal information in certain circumstances, including if you dispute
the accuracy of the information.
Right to object: You have the right to object, for reasons related to your particular situation,
to the processing of your personal data. You can also object to the processing of your data for
direct marketing purposes.
Right to withdraw consent: You have the right to withdraw your consent at any time,
although this does not affect the lawfulness of processing carried out before the withdrawal
of your consent.

You may also have the right to lodge a complaint with the Commission Nationale de l’Informatique
et des Libertés (CNIL), the competent supervisory authority in France. If you need assistance in
exercising your rights, please contact us, and we will review your request in accordance with the
applicable laws.

Article 13. Modification of this privacy policy

Begum Academy may modify or revise this Privacy Policy from time to time. We will inform users
of any changes by publishing the revised policy with an updated revision date on our Service. If we
make significant changes to this policy, we will make reasonable efforts to notify you by posting a
notice on our mobile application before the changes take effect.

We encourage you to review this Privacy Policy regularly whenever you visit the Service to stay
informed about our privacy practices.