LAST UPDATED: APRIL 28TH 2020
personal data which we receive through the educational services (the,
“Services”), provided by XBlended (part of The Queen Rania Foundation) and
how students enrolled on a course provided by XBlended can exercise their
rights over it.
Who we are and how to contact us
We are XBlended for Training and Community Development, LLC of 5 Mohammad
Saad AlBatayneh Street, Amman, Jordan (“XBlended”). References to “we”,
“our” or “us” means XBlended. We offer an open online learning platform to
students looking to advance their education via a platform known as,
“XBlended”. We are the controller of your data. This means that we are
responsible for deciding how we collect, store and use personal
information about you. We may from time to time engage third parties to
process your information and we may also process your information
ourselves (as described further below).
If you have any questions or concerns about the information in this
or if you would like more detailed information, you should email us at
[firstname.lastname@example.org] or write to us at [5
Mohamed Saad AlBatayneh Street, Amman, Jordan] for the attention of
The information we collect about you and why we collect it
By registering an account on XBlended and in turn using our Services, we
will collect from you the following information (“Personal Data”):
- Your name
- Your email address
- Your year of birth
- Highest education level achieved
- Country of residence/origin
- Phone numbers (Teachers)
- Social media accounts (If you login/register using social media,
namely Facebook or Google)
- Records of your visits to XBlended and engagement with educational
content such as pages, videos, assessments, and posts, comments, and
any other interactions you perform on course discussion forums
- Details of grades scored on assessments you take on XBlended
- Online footage of interactions you performed in online lecture
videos, called “pause and seek events”
- Records of creation of virtual classrooms by teachers on XBlended
- Information you add to child accounts you create for your children
on XBlended through the parents’ section on the dashboard page
If you are a parent or a guardian creating an account for your child,
the following child (“Personal Data”) will be collected:
- The child’s name
- The child’s gender (optional)
- The child’s academic grade
- The country whose curricula you want the child’s programs to follow
XBlended will never share externally a child’s Personal Data, or any
linkage between child and parent data.
Our legal basis for using your Personal Data
Where we use your Personal Data, we process it on the following bases:
- Performance of a contract to which you as a data subject are a party
(including in connection with the retention of records detailing
your learning progress and performance for the purpose of saving
your course progress and certificates); and
- For the legitimate interest of XBlended carrying out the following
- Internal research purposes, for example the improvement of
course design and operation;
- The following research and marketing purposes (unless you decide
to opt-out when registering or subsequently):
- Internal research in connection with how the XBlended platform
is used; and
- For the purpose of sending you updates in respect of online
courses offered by XBlended;
- Improving the platform user experience of XBlended; and
- The publication of scientific papers in journals or conferences.
No data that identifies you are ever shared in a scientific
publication. We only publish aggregated or anonymized data.
We will never collect any unnecessary Personal Data from you and do not
process your information in any way, other than as specified in this
We make every effort to maintain the accuracy and completeness of your
Personal Data, which we store, and to ensure all of your Personal Data
is up to date. However, you can assist us with this by promptly
contacting us if there are any changes to your Personal Data. We shall
not be responsible for any losses you suffer arising from any
inaccurate, inauthentic, deficient or incomplete Personal Information
that you provide to us.
How long we will keep your Personal Data
For EU users and users in other countries with data protection
legislations that require personal user data to be deleted after some
time, your account data will be deleted automatically after 7 years of
inactivity. Inactivity is defined as the absence of interaction with
course content. Following 7 years of inactivity, we will contact you
with a 1 month prior notice, informing you that your Personal Data will
be deleted from the computers on which it is stored, and giving you the
option to request your Personal Data is retained for another 7 years.
For users in all other countries, your account data will be saved by
XBlended until you submit a request for us to delete your data through the
Website, after which your data will be deleted according to the timeline
provided by the Website when you request the deletion.
XBlended may shorten the retention period for your Personal Data depending
on the amount, nature, and sensitivity of your Personal Data, the
potential risk of harm from unauthorised use or disclosure of your
Personal Data, the purposes for which we process your Personal Data and
whether we can achieve those purposes through other means, and the
applicable legal requirements.
Who we share your Personal Data with
We may from time to time share your Personal Data with the following
parties for the purpose of improving course content, and improving
- The internal course management team;
- The internal marketing team; and
- The internal leadership team.
- Third parties we partner with for the purposes of course creation,
operation, or evaluation (including instructors, teaching
assistants, and personnel from organizations that partner with
XBlended for the purpose of a course you are enrolled in) and
marketing agencies we partner with for XBlended’s specific marketing
needs. All third parties who receive personal data from XBlended sign
a data processing agreement with XBlended that mandates they use your
Personal Data only for the purposes for which XBlended contracted them
and in accordance with GDPR or any other applicable data
regulations, and that the third party deletes your personal data
within 10 days of the termination or completion of the contract.
We may also from time to time share your Personal Data (in an anonymised
form) with external educational researchers for the purpose of
conducting educational research.
Transfer of your Personal Data to other countries
We only transfer your Personal Data outside the EEA where we have a
legal basis for doing so and where we require that your personal
information is protected to the same standard as it would be protected
in the EEA. We do this by entering into data sharing agreements with the
recipients of your Personal Data based outside the EEA which comply with
the EU Commission’s standard clauses for the transfer of personal
If you would like further details about our transfer of your personal
information outside the EEA or details of the safeguards put in place in
relation to your personal information please contact the “Privacy
Officer” at XBlended.
Use of your Personal Data for automated decision-making
We do not make any automated decisions using this information.
Changes to this policy
Except to the extent limited by applicable law, we reserve the right to
update this policy to reflect changes to our information practices by
prominently posting notice of the update on our Services, and as
required, obtaining your consent. Any updates will become effective
immediately after posting the updates to this policy and apply to all
information collected about you, or where required, upon your consent.
You agree that you will review this policy periodically. If we make any
changes to this policy, we will change the "Last Updated" date above.
Your rights and how to exercise them
European and UK privacy laws give you certain rights in respect of the
data that we hold about you. Below is a short overview of those rights.
- With some exceptions, you have the right to have a copy of the
Personal Data that we hold about you. We may make a reasonable
charge for additional copies of that data beyond the first copy,
based on our administrative costs. Where the data is data that you
have given to us, you have the right to receive your copy of it in a
common electronic format, and to provide copies of it to other
people if you wish.
- You have the right to have the Personal Data we hold about you
corrected if it is factually inaccurate.
- In some circumstances, you have the right to have Personal Data that
we hold about you erased (the “right to be forgotten”). This right
is not generally available where we still have a valid legal reason
to keep the data (for example, if we are obliged to do so by law).
- You have the right to require us to stop using your Personal Data
for marketing purposes.
- You also have the right in some circumstances to request that
temporary restrictions are placed on how we process your Personal
Data, For example if we are processing it on the basis of our
legitimate interest, and you contest to our assessment that our
interest is not overridden by your fundamental rights and freedoms.
- If we are processing your Personal Data on the basis of your
consent, you have the right to withdraw that consent at any time, in
which case we will stop that processing unless we have another legal
basis on which to continue. In some cases, the only way for XBlended
to stop that processing would be through terminating your accounts.
XBlended will request your confirmation before terminating your
account, through the email address through which you request to
withdraw your consent. If you do not provide written confirmation
within 21 days for XBlended to terminate your account, your request to
withdraw your consent will be considered canceled.
In order to protect you and others, we may require you to prove your
identity before you exercise these rights.
If you are unhappy with how we have handled your Personal Data, you have
the right to complain to your local data protection authority.