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Privacy Policy

Last Updated: November 01, 2024

This Privacy Policy (Policy) together with the terms of use on our website (Site) and any other documents referred therein sets out the basis on which we process any personal data we collect from you, or that you provide to us, will be processed by us or our authorised third parties in accordance with applicable data protection laws such as the UK’s Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/ 679 (GDPR). 

We are committed to protecting and respecting your privacy. We run educational programs covering the conceptual underpinnings and the hands-on application of blockchain technology, using Polkadot and Substrate as the foundations (Programs). The Programs include the PBA-X course (PBA-X), our online foundational course covering the conceptual underpinnings of blockchain technology, which can be used as a standalone program or as a primer for participation in our PBA-Campus course (PBA-Campus). PBA Campus is a classroom based course delivering a deep dive into the application of blockchain technology. 

In this Policy, when we refer to we, us, our or PBA, we mean Polkadot Blockchain Academy, an Exempted Limited Guarantee Foundation Company incorporated in the Cayman Islands, with its registered office at ℅ Chartered Financial Partners Limited, Governors Square Suite #5-204, 23 Lime Tree Bay Avenue, Grand Cayman, Cayman Islands, KY1-1108. 

When we refer to you, your or yours we mean the individual accessing our Site, participating in our Programs and/or using our services.

Please take time to read this Policy carefully to understand how we deal with your personal data. More information about your rights and how you can exercise them is set out in the ‘Your Rights’ section below. If you have questions or do not understand any aspect of this Policy, please contact us on [email protected].    

What data do we collect from you?

We may collect and process the following personal data about you:

  • Identity and Contact Data: including your name, contact information (such as email address, social media handles (e.g. GitHub, LinkedIn, Discord handle) and date of birth and other personal data concerning your preferences necessary or relevant for our Programs or services. For participants in PBA-Campus, we will also ask for your passport number, photo(s), gender and visa information. 
  • Application-related information (PBA-Campus only): employment and education history, referrals or references, any other information you provide (such as information on your resume or cover letter) and any information that applicable local laws require us to collect in connection with our selection process for the course.
  • Selection Information (PBA-Campus only): interview details, outcomes of any recruiting exercises you complete, and the details of any offer letter and contract we provide.
  • Performance and Conduct Information: information concerning your attendance of the Programs, responses to and outcomes of any assessments or further interviews you take whilst participating in the Programs, any grievances and complaints and information about any violation of laws or breach of our policies. For participants in PBA-Campus we also process information collected during the selection process. 
  • Communication Information: records of communication (where permissible) and communication metadata.
  • Photographs and Video recordings: photographs and video recordings of events taking place as part of the Programs (unless you have opted out of this).
  • Financial and Payment Data: including your bank account and other data necessary for processing payments and fraud prevention, including other related billing information.
  • Business Information: including information provided in the course of the contractual or client relationship between you and us, or as otherwise voluntarily provided by you.
  • Employment Status and Employment related information: including information about your employment status as part of our monitoring and improvement efforts for the Programs and as part of your employment history validation by us. This data helps us analyse the effectiveness of coursework and identify areas for improvement. The purpose is to ensure the continuous quality and relevance of our Programs.
  • Sensitive Information (PBA-Campus only): information of applicants, registered participants, students, faculty, guests and visitors, if disclosed by you and when relevant, any special needs, health condition, or information relating to accommodations that you may request during the selection process or while at PBA-Campus, equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief. Any data obtained is treated with strict confidentiality. We will delete or anonymise (where possible and following data protection laws standards) all such data as soon as it is no longer needed.
  • Information you provide to us: this is information about you that you provide to us by completing our forms or those on the sites of third party vendors providing us with services, by speaking with us in person, or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address, registration information (such as username and password when you create an account on one of our Site or those of the third party vendors we work with), phone number, job title, organisation, dietary and/or accessibility requirements or your public blockchain address. We will tell you whether the information we are requesting is essential or whether the supply of the information is optional.
  • Information about you that we receive from other sources:
    • This is information we receive about you if you use any of the other websites we operate or the other services we provide or, to the extent permitted by law, publicly accessible information about you on e.g. business social media;
    • We may conduct references and background checks as part of our commitment to maintaining a high standard of academic excellence, ensure security on our Programs and to comply with applicable law. Any data obtained is treated with strict confidence. We will always inform you if and when background checks will be performed and whether they are essential or optional;
    • We may receive referrals from academic partners, vendors, and event partners to enrich our understanding of individuals applying to, registering for or participating in our Programs. This information is valuable for fostering collaborative relationships and ensuring the effectiveness of our educational initiatives. We handle this data responsibly in line with this Policy;
    • We may receive information about you from the Web 3.0 Technologies Foundation and from Parity Technologies Limited as part of our cooperation. The Web 3.0 Technologies Foundation and Parity Technologies Limited may share information about you with us for the purposes of: organising joint events, meetups, conferences, workshops or hackathons; assisting and/or following-up with you and coordinating that assistance; addressing and/or following-up with you where you have shown interest in Polkadot and/or Substrate; and/or building and maintaining the Polkadot network and its community of users. To the extent that you would like further information on the data we receive about you from the Web 3.0 Technologies  Foundation and/or Parity Technologies Limited and the protections we have put in place to ensure the date processed and transferred securely, please contact us at [email protected]; and  
    • We are working closely with third parties (including, for example, event organisation service providers, event partners, and appointment scheduling services) from whom we will receive information about you. The purposes for which we use this information are listed below. To the extent that you would like further information on any of the third parties from whom we receive data about you, and the protections we have put in place to ensure it is processed securely, please contact us at [email protected]. 

How do we use this information, and what is our legal basis for doing so? 

We have to have a legal basis to process your data. We explain each of these bases below. We also set out the various purposes for which we process your data. 

We use the information we collect from and about you:

  • As necessary to conduct our business and pursue our legitimate interests. In particular:
    • to notify you about changes to our Programs or services;
    • for internal operations, including troubleshooting and statistical purposes;
    • to ensure that content from our Site, blogs and social media is relevant, accurate and presented in the most effective manner;
    • to allow you to participate in interactive features of our Programs and services, when you choose to do so;
    • to use information you provide to investigate any complaints received from you or from others, about our Site or our Programs and services;
    • to address any interest you show in PBA, our Programs and services or any collaboration with us;
    • to administer and manage our relationship with you, including accounting, and taking other steps linked to the performance of our business relationship;
    • to address any requests, issues or questions you inform us about when you contact us;
    • to follow-up with you where you have shown interest in Polkadot, Substrate, our Programs or any other of our services;
    • to analyse and improve our Programs and communications;
    • to protect the security of our communications and our systems and to prevent and detect security threats, fraud and other criminal or malicious activities;
    • for insurance purposes;
    • to collect information about your preferences to personalise and improve the quality of our communications with you;
    • to prepare, coordinate, manage and deliver the Programs, including scheduling events, lectures, talks as well as PBA-Campus specific events, travel and other arrangements; 
    • to schedule, arrange and administer events, meetups and hackathons in which you have expressed an interest (including creating an attendance record for the event and sending anonymised data to the venue including attendees, dietary requirements and accessibility requirements);
    • to allow our services to check for updates and resources necessary for their continued operation;
    • to comply with our legal obligations in areas such as tax, health and safety and equality and anti-discrimination law;
    • to exercise or defend our legal rights or to comply with court orders and to use your data in connection with legal claims, compliance, regulatory, auditing and investigative or disciplinary purposes as necessary (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements; and
    • to combine information which you give to us and information we collect about you with information we receive from other sources. We will then proceed to use the combined information for the purposes set out above (depending on the types of information we receive).
  • As necessary for our (or others’) legitimate interests in the course of preparing and delivering our Programs, including our interests in the teaching and assessment in the course of our Programs; 
  • Where you are registered and/or accepted onto our Programs, as necessary for our (or others’) legitimate interests in the provision of the Programs, including our interests in:
    • managing and improving our provision of the Programs and performing management reporting and analysis related to outcomes and grade metrics;
    • creating marketing and publicity materials for the Programs;
    • taking measures to ensure the integrity of the Programs’ assessments, including checking for plagiarism and the use of artificial intelligence; 
    • inviting, where we choose to do so, high achieving participants of our Programs to interviews for potential recruitment into PBA’s team; and
    • enrolling you into the Programs’ Alumni Community.
  • As necessary for our (or others’) legitimate interests in the course of the PBA-Campus application process, including our interests in:
    • assessing your suitability for the opportunities offered by PBA-Campus;
    • facilitating the application and selection process;
    • verifying the information you or others provide as part of your application; 
    • managing and improving our application and selection process;
    • performing management reporting and analysis related to selection metrics and success factors; and
    • arranging the provision of other services for PBA-Campus, such as accommodation.
  • In accordance with specific consents you may provide. Where you give us such consent this includes storing your data and keeping it up to date and using it to contact you, including:
    • to contact you about future career opportunities at PBA;
    • to send you our newsletters;
    • to send you or have our carefully selected partners send you direct marketing in relation to services provided by us, our affiliates or our partners. Where so prescribed by applicable law, we will only provide you with marketing related information after you have opted in to receive those communications. We will provide you the opportunity to opt out at any point in time; and 
    • on other occasions where we ask you for consent (we will use the data for the specific purpose(s) which we explain at the time of collection).

Wherever we rely on your consent as the legal basis for us processing your data, you are able to withdraw that consent at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented, unless there is another legal basis for the processing.

You have the right to withdraw your consent for direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in our communications where this is an electronic message, or by contacting us at [email protected].

  • For purposes which are required by applicable law, including: 
    • in response to requests by government or law enforcement authorities conducting an investigation; and 
    • maintaining records, compliance checks or screening and recording (e.g. anti-money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions, etc.).

Where we need to collect personal data under applicable law, in order to process your instructions or to perform a contract we have with you and you fail to provide the data when requested, we may not be able to carry out your instructions or perform the contract we have or are looking to enter into with you. In this case, we may have to terminate your relationship with us. We will notify you promptly in such instances.

Who will we share your data with, where and when?

We may share your personal data with selected third parties, including but not limited to:

  • Within PBA, with our subcontractors and with faculty and partner universities;
  • We may share your data among the different PBA stakeholders involved in the selection process for participation in our Programs, and those involved in their teaching, assessment and organisation;
  • With our ecosystem partners, as part of our overall collaboration and joint efforts within the space. For example, with your consent we will share your information to form part of the job board for possible career opportunities;
  • With service providers which help us manage and improve the Programs and who perform services on our behalf, such as interview and assessment providers, travel booking and expense providers, relocation entities, immigration advisors or reporting and analytics and security services. We may also share your data with event organisers and partner universities so that they can provide services such as accommodation, meals, and access to teaching facilities to those attending PBA-Campus. All partner entities are required to protect the information we share with them with appropriate organisational and technical safeguards and to use such information as necessary to provide services to us;
  • Other business partners and subcontractors, for the performance of any contract we enter into with them or you, such as legal, financial, tax and accounting services providers and IT service providers (e.g. hosting and/or maintenance providers);
  • Our newsletter service provider for the purposes of providing you with our newsletter; and
  • With Parity Technologies Limited and Web 3.0 Technologies Foundation as part of our cooperation and for the purposes of organising joint events, meetups, conferences, workshops or hackathons; assisting and/or following-up with you and coordinating that assistance; addressing and/or following-up with you where you have shown interest in Polkadot and/or Substrate; and building and maintaining the Polkadot network and its community of users. 

If you would like further information of any of the parties with whom we share your data, and the protections we have put in place to ensure it is processed securely please contact us at [email protected]. 

We may also disclose your personal data to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your data to the prospective seller or buyer of such business or assets in compliance with applicable law;
  • If we (or substantially all of our assets) are acquired by a third party, in which case the data held by us about you and our other customers will be one of the assets being transferred to the buyer; or
  • If we are under a duty to disclose or share your data in order to comply with our legal obligation, or in order to enforce or apply our policies, such as our terms of use, or other agreements; or to protect the rights, property, or safety of PBA, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

A note on jboards.io

PBA hosts a job board on jboard.io (Job Board) for the purposes of connecting those who have completed our Programs and other PBA alumni with career opportunities within the Polkadot ecosystem.

Where we wish to offer this opportunity to you, you will receive an invitation from us to set up a profile on the Job Board. This may require you to create a profile and to disclose personal data, including but not limited to: identity data (name, profile picture, location), contact details (email, phone number), employment related data (title, resume, skills), social media handles (like LinkedIn), as well as any other data you may choose to disclose. 

If you choose to apply for an open role on our Job Board with one of our partners, your data will be shared with the partner. If you select the ‘available for work’ option, partners will be able to see your profile and may contact you. 

Please note that our ecosystem partners have their own privacy policies. We do not accept any responsibility or liability for them or their policies. Please therefore check their policies carefully before you submit any personal data or decide to make your profile available to them. Your data may also be shared with our processor, jboards.io, for the purposes of providing the Job Board service to you. Please be sure to also familiarise yourself with their privacy policy.

PBA reserves the rights to screen, admit and remove anyone (including ecosystem partners) from its Job Board at its discretion. Please contact us at [email protected]  if you have any questions. 

A note regarding Blockchain use

The Polkadot, Kusama and Substrate based blockchain clients written in the programming language Rust do not collect information from you. However, please note that any information you publish onto a (public) blockchain like Ethereum, Kusama or Polkadot is public by design. Your use of a client and other interactions with a blockchain like Ethereum, Polkadot or Kusama will lead you to interact with other network participants on those blockchains. Please be aware that when you do so, those with whom you interact and other participants on those networks may be able to determine certain things about you through your use of those networks.

International data transfers

The data that we collect from you may be transferred and stored by us or our service provider(s) outside the UK and the European Economic Area (EEA). It may also be processed by staff operating outside the UK and the EEA who work for us or for one of our suppliers. Where information is transferred outside the UK and the EEA, and where this transfer takes place to a country for which the European Commission has not issued a decision that the country’s data protection laws provide adequate protection for your data, your data will be separately protected by suitable data protection agreements, the European Commission’s approved standard contractual clauses or by the local vendor's Processor Binding Corporate Rules. 

Our Sites may, from time to time, contain links to the websites of our partners and affiliates. Please note that if you follow a link to any of these websites, the websites will have their own privacy policies. We do not accept any responsibility or liability for those websites and/or their privacy policies. Please check these privacy policies carefully before you submit any personal data to these websites.

Data retention

We'll retain information we collect from you for as long as required to comply with our legal obligations, to resolve disputes and to enforce our contractual agreements. Applicable law may require us to hold certain information of yours for specific retention periods. In other cases, we may retain data for an appropriate period after our relationship with you ends to protect ourselves from legal claims, or to administer our business.

Notwithstanding the foregoing:

  • for newsletter subscribers or where we are processing your data on the basis of your consent: 

We will retain your personal data until you ask us to stop. Where consent is provided, you have the right to withdraw your consent at any time. We may indefinitely keep a record of the fact that you have asked us not to process your data so that we can respect your request for the future. Further, if you wish to unsubscribe from our mailing lists you can manage your subscription preferences and unsubscribe by following the instructions provided in our emails or by contacting us at [email protected]. 

  • for PBA-Campus:

If you have successfully applied to PBA-Campus, we will retain the information you provided during the application process as part of your records, alongside information collected during your participation in the Program. After your completion of PBA-Campus, we will retain your personal data for archival, record-keeping and legal purposes.

As a participant of PBA-Campus your personal data will generally be kept for six years after the Program has ended, unless there are relevant legal proceedings for which your data is reasonably required. After this period, we will take steps to delete your personal data or hold it in a form that no longer identifies you.

Where we request and you choose to provide sensitive personal data such as dietary or medical requirements, emergency contact details and other information in order to ensure smooth operation of a Program and to safeguard staff, students and faculty, such data will be deleted 240 days after submission (approximately 6 months) after the end of the cohort. 

If you were unsuccessful in your application to PBA-Campus, we will retain your personal data subject to you consent for one year so we can keep you in mind for future opportunities or for six months in the absence of your consent;

  • PBA-X Learners

How will you protect my data?

We strive to maintain the highest standards of security and we have put in place robust technical and organisational measures for the protection of your data in accordance with current general state of the art technologies, especially to protect the data against loss, falsification or access by unauthorised third persons. However, the transmission of information via the internet is never completely secure. So, whilst we do our best to protect your personal data, we cannot guarantee the security of your data when it is transmitted. Any transmission to us is at your own risk. Once we have received your personal data we will use strict procedures and security features to prevent unauthorised access.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site or content, you are responsible for keeping the password confidential. We ask you not to share your password with anyone and to let us know immediately if your password is lost or compromised.

Your rights

You have the right, subject to applicable exceptions and our verification of your identity, to ask us to access, rectify, port (where technically feasible) and delete your data. You also have the right to object to and restrict us from certain processing of your data. If you would like to exercise such a right, please contact us at the details below. If you have unresolved concerns about how we handle your data, you have the right to complain to a data protection authority. 

Where we request and collect personal data from you to administer your contract with us or to comply with our legal obligations, the provision of your data by you is essential and we will not be able to fulfil our contractual obligations to you without said data. In all other cases, provision of the requested data is optional, but failure to provide the data may affect your ability to participate in our Programs or to receive goods and services from us, where we need the data for those purposes.

Withdrawing your consent

Where we have asked for your consent to process your data, you may withdraw the consent at any time by giving us notice. If you ask to withdraw your consent to processing your data, this will not affect any processing which has already taken place at that time.

Cookies

Please make reference to our Cookie Policy to understand how we use cookies. 

How to contact us

Please contact us at [email protected] if you have any questions about this Policy or the information we hold about you.

Changes to our Privacy Policy

This Policy may be updated from time to time. The most recent version will always be available on our Site. Please check back frequently so you are aware of the most recent version of the Policy and how we collect, process and store your personal data.