Privacy Policy

PRIVACY POLICY OR THE USE OF THE WEBSITE AND PRODUCTS OF JRK CONSULT LTD (THE “COMPANY”)

This Privacy Policy (“Policy”) is an integral part of the General Terms and Conditions for the use of the website www.destinationagile.com, owned and operated by “JRK Consult” Ltd. (“JRK CONSULT”), with UIC: 201349042.

The Policy was adopted and approved by the Company’s manager on 01.06.2024. The Company’s website www.destinationagile.com (referred to below as the “Company’s website”) is administered by the Company.

The Policy was created and adopted by the Company in accordance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regarding the protection of natural persons concerning the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (“General Regulation” or “GDPR”). It includes the purposes, processing methods, applied protection, categories of user data collected and processed by the Company, data protection information and their storage, the way of exercising the rights of data subjects, and types of protection.

1. What Information is Collected When Using the Company’s Website?

When using our website, your personal data is processed, which can directly or indirectly identify you.

In cases where you use our website and wish to receive a specific service through it, you will need to provide the following categories of your personal data. This information is necessary for us to provide the requested service and meet your expectations as our customer.

Categories of Data:

1. Your full name
2. Valid email address
3. Phone number
4. Potential preferences for the types of courses and training we offer
5. Additional data (user content and/or invoice information)
6. Your address, data for created username, and password
7. Information about your employer, in case a payment document is to be issued to them

If you decide to exercise your rights as described in this Policy, we may need you to provide some of the above-mentioned data again.

For the execution of certain functionalities on our site, which you access through it, our information system collects information from your computer during standard web operations such as GET/POST HTTP requests, execution of HTML, CSS, and JavaScript, cookies, and site codes. This may result in the collection of the following additional categories of personal data:

1. IP address

2. Under what conditions can we collect and process your personal data?

Through the Company’s website, we provide services that include training modules divided into four main categories as follows:

1. Training with certification from service providers (third-party providers to the Company)
   • Example: Leading SAFe
2. Training with certification from JRK CONSULT
   • Example: Agile Fundamentals and Scrum Basics
3. Programs for building useful work habits
   • Example: September: Physical activity in our daily lives. Agile Gamification.
4. Open study groups (workshops)
   • Example: Story mapping workshop

All training modules and product categories within each module are collectively referred to below as “product” or “products.” 

Our products may be updated from time to time, with new ones added or existing ones discontinued. Regardless, this privacy policy remains current, and the categories of personal data we collect about you, as well as the conditions/methods for their processing, remain unchanged.

2.1. When You Decide to Become Our Client

The data we collect and process is intended to enable us to provide you with the selected training module/products. When you decide to become our client, you will need to:

• To register as a user on the Company’s website, you will need to provide a username and password. We will then link these credentials to your name and the other data you have provided.
• The creation of a user name and password for use of the Company’s website is at your express request, and in view of this, you have used the functionalities of the Company’s website and created the user profile with a username and password.
• You may use our website to purchase training materials. In this case, the website will use your user data (username and password, bank account/credit/debit card details, invoice information). These data will be used only as necessary to make a payment to us. Payments by debit/credit card are made through financial service platforms, so we will not receive any direct card data but will be able to reflect the payment received from your account.
• If you decide to use our online training, where you will interact with our instructor through an electronic platform, we will be able to see your face and hear your voice. However, these interactions will not be recorded.

2.2. When you make a purchase payment with a bank card, we use the services of a third party (Stripe, Inc) – a financial service provider. In these cases, the payment service provider is an independent data controller, and our website acts solely as a platform through which end-users can make remote payments (online payments) in accordance with the third party’s privacy policy. The systems through which the third party provides services and processes your data are entirely controlled by them and cannot be influenced by us.

2.3. Filling Out the Contact Form

If you decide to fill out the contact form, we will collect the following data: first name, last name, and email address. This information will be used to contact you regarding the services provided or for our newsletter.

2.4. Newsletter Registration

If you decide to subscribe to our newsletter, we will collect your email address. 

Subscription to our newsletter is requested by you, and you can unsubscribe at any time by following the instructions provided in the newsletter itself.

If you have requested to receive information about our products and/or services, we will collect the necessary personal data to send you the requested information and/or to include you in our subscription program for receiving periodic updates, if such a program is active during that period.

2.5. Accounting Purposes

Your personal data may be sent to our accounting department for the issuance of invoices for your orders.

2.6. Hosting Services

Our website is hosted by a service provider, SuperHosting.BG Ltd.

2.7. Advertising

For advertising purposes, we use Google Ads conversion tracking and Meta ads conversion tracking. The data collected by these services is not stored by us but by the respective advertising product providers for analytical purposes. The systems through which the third party provides services and processes your data are entirely controlled by them and cannot be influenced by us.

2.8. Managing Contacts and Sending Messages

We may use the collected personal data to contact you regarding the provided service or to supply additional materials.

3. How Do We Collect and Process Children’s Personal Data?

Our services are not directed towards individuals under 18 years of age. The Company does not aim to collect or wish to collect personal data from children in connection with the services and products it provides.

If the Company receives information about a minor in connection with a request for a service or product from the Company’s website, we will not process it and will delete it, unless a legal act obligates us to process this data in a specifically established manner.

4. How is Information Collected?

The personal data we collect through or in connection with the use of the Company’s website may be collected in the following ways: 

1. a) The information is voluntarily provided by the user/visitor to the website;
2. b) The information is collected automatically through the functionalities of the Company’s website; 
3. c) Through the use of cookies and other similar solutions for performance optimization, analysis, and sending commercial messages.

If you would like to learn more about these technologies, how they work, and how we use them, please visit our Cookie Policy outlined below in section 5.

5. Cookie Policy

JRK CONSULT uses cookies in various ways to improve your experience on our website, including:

• Recognition and Enhancement: To recognize our website users and enhance user experience when interacting with our website.
• Analysis: To help us analyze the use and performance of our website and services.
• Improvement: To improve the delivery and value of various services and products offered by us.

A. What Types of Cookies Do We Use?

Our website uses several types of cookies:

1. Persistent Cookies:

• Purpose: Improve your experience of using the sites.
• Function: Record your acceptance of our Cookie Policy to remove the cookie message that first appears when you use the sites.

1. Session Cookies:

• Purpose: Track internet usage during your visit.
• Function: These are temporary cookies that are deleted from your machine when your web browser closes.

III. Analytical/Performance Cookies:

• Purpose: Recognize and count the number of visitors and see how visitors move around our website.
• Function: Helps us improve the way our website works, ensuring users find what they are looking for.

1. Functionality Cookies:

• Purpose: Recognize you when you return to the website.
• Function: Enable us to create more relevant content for you and remember your preferences.

1. Targeting Cookies:

• Purpose: Record your visit to our website, the pages you navigate to, and the links you click.
• Function: Helps us formulate information relevant to your areas of interest.

B. How to Manage Cookies?

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. Disabling some cookies on the website may have a negative impact and result in the non-availability of some features.

If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the sites from placing further cookies on your device unless and until you adjust your internet browser setting as described above.

You can obtain up-to-date information about blocking and deleting cookies via these links:

• Chrome
• Firefox
• Opera
• Internet Explorer
• Safari

These opt-out mechanisms rely on cookies to remember your choices. If you delete your cookies, use another computer or device, or change browsers, you will need to repeat this process. Additionally, opting out of interest-based ads will not opt you out of all ads, but rather only those ads that are personalized to your interests.

6. Legal Basis for Processing Personal Data and Processing Period

The Company uses the information described above for various purposes based on the corresponding legal grounds, namely:

Category of Data	Purpose of Processing	Legal Basis under GDPR	Method of Collection	Retention Period
Full Name Valid Email Address Phone Number Physical Address Personal Preferences Accounting Data Employer Data for Invoicing Purposes	To fulfill our obligations in providing the selected training/products. For sending training materials and feedback, for sending our newsletter. For issuing an accounting document for the payment made. For feedback on requested information.	The processing is necessary for the provision of our products and to ensure the ability to use the functionalities of our website.	When a user places an order. At your explicit request, after registering on our website or if you have requested specific information/assistance from us.	We retain your data until you decide to stop using the functionalities of our website or products and terminate your user account.
1.IP address	To provide full functionality of the website and for advertising.	The processing is necessary for the performance of the agreement between us to provide certain products.	When using the Company’s website.	Up to 60 months after the termination of the user account through an option in the control panel.
Analytical data and marketing data, cookies:	Please see clause 2.7 and section 5 of this policy.

7. Measures to Ensure Lawful Processing and Security

In accordance with GDPR, the Company maintains appropriate, necessary, and proportionate technical and organizational measures to protect user data, including preventing unauthorized access and/or misuse.

Only authorized personnel have access to personal data in our information systems.

The personal data we collect from you is stored on servers that are part of the SuperHosting.BG infrastructure and maintained by their technical team. 

8. With Whom Do We Share Your Personal Data?

The Company may share user personal data with industry-recognized solutions such as Google Analytics, Meta, financial service providers, accounting service providers, hosting service providers, and external service providers such as Scaled Agile, Inc., third-party training product providers, and providers of exam and certification platforms that you have chosen to use or wish to access.

• Sharing your data with entities providing accounting services is in connection with fulfilling obligations under the Accounting Act or established international accounting standards (basis – Article 6, paragraph 1, letter “c” of GDPR).
• We may need to transfer your personal data to various administrative, judicial, arbitration bodies or committees, law enforcement agencies, financial institutions, our lawyers, consultants, and/or executive authorities when necessary for the disclosure of trade secrets, during legal disputes, when required by specific law, or related to the prevention and prosecution of crimes, fraud, corruption reports, and more.
• Information about you may also be transferred to our business partners for the performance of contractual services to ensure quality services or to implement marketing strategies.
• Our trainers also receive information about you. They are informed in advance of the security level they must ensure and will use your personal data to fulfill their contractual obligations to the Company for conducting the respective training.
• In connection with data transfer to Scaled Agile, Inc. For students that attend certified courses part of the SAFe framework, i.e. Leading SAFe® or SAFe® Product Owner/Product Manager, your name and email address will be provided to the Scrum Alliance to process your certification.
  https://scaledagile.com/privacy-policy/

9. Your Rights Regarding Personal Data Related to the Use of the Company’s Website

In connection with the use of the Company’s website and the processing of your personal data, you have the right to information about who processes your personal data, for what purpose, in what manner, whether this data is shared with other parties, how it is stored and for what period, and whether profiling is performed.

In this regard, you can also exercise your right to access the information being processed about you and request the administrator to correct your personal data if it is inaccurate.

During the restriction period, the data may continue to be stored by the Company.

Below is a summary of the rights you have regarding your personal data, administered and processed by the Company:

1. The right to access your personal data processed by the Company.

To exercise this right, you can request us to provide the data we have received about you, which is stored and processed, and further explain what we have used it for and where it is stored. For this purpose, you can write to the Company at the email address provided below.

1. The right to correct inaccurate or incomplete personal data.

iii. The right to delete (“right to be forgotten”) personal data that is processed unlawfully or without valid legal grounds (expired retention period, withdrawn consent, fulfilled original purpose for which they were collected, etc.).

1. The right to restrict processing when there is a legal dispute between the controller and the individual until it is resolved and/or for the establishment, exercise, or defense of legal claims.
2. The right to data portability. In cases defined by law, you can object and request your data to be provided in a structured, commonly used, machine-readable format.
3. The right to object to the processing of your personal data.

vii. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.

viii. The right to withdraw consent. When the processing of your personal data is based on consent, you can exercise this right. Such withdrawal will not affect the lawfulness of processing based on your consent before its withdrawal.

1. right of appeal to the Commission for the protection of personal data or the court.
2. How to Contact Us Regarding Any Questions About Personal Data or to Exercise Your Rights?

Please write to us at the email address provided below and state your request. We will contact you and make every effort to fulfill your request. We may ask you to provide additional personal data to respond to your request.

E-mail: contactus@destinationagilе.com

In connection with the protection of your personal data, if you believe there is a problem with its processing, you can file a complaint with the relevant data protection authorities.

In Bulgaria, where our Company’s headquarters is located, the competent data protection authority is:

Commission for Personal Data Protection 

Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria 

Email: kzld@cpdp.bg 

Contact Phone: +359 2 9153518

If you have any questions or comments regarding this privacy policy, you can contact us at contactus@destinationagilе.com.

All personal data is processed by the Company and our products/services are provided under the Company’s General Terms and Conditions, which can be found on our website www.destinationagile.com.