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PositionX

Building Tomorrow's Game Developers

Privacy Policy

Last Updated: January 15, 2025

At Positionx, we take your privacy seriously. This policy explains how we collect, use, and protect your personal information when you interact with our mobile game development educational programs and website services.

We're based in Georgia and operate under Georgian data protection regulations, including the Law of Georgia on Personal Data Protection. But more importantly, we believe in being transparent about what happens with your information.

Information We Collect

When you sign up for our courses or contact us, we collect information that helps us provide better educational services. Here's what we typically gather:

  • Contact Details: Your name, email address, phone number, and location. We need these to communicate about course schedules, updates, and materials.
  • Educational Background: Information about your experience level, programming knowledge, and educational goals helps us match you with appropriate learning programs.
  • Technical Information: When you browse our website, we collect standard data like IP address, browser type, device information, and how you navigate through our pages.
  • Payment Information: If you enroll in paid courses, we process payment details through secure third-party processors. We don't store complete credit card numbers on our servers.
  • Course Performance Data: Your project submissions, quiz results, attendance records, and participation in learning activities help us track progress and provide feedback.

How We Use Your Information

We're not in the business of selling your data. Everything we collect serves specific purposes related to providing quality education:

  • Course Administration: Managing enrollments, sending schedules, sharing learning materials, and coordinating with instructors.
  • Educational Support: Tracking your progress, identifying areas where you might need extra help, and personalizing learning recommendations.
  • Communication: Sending important updates about your courses, upcoming programs, and relevant opportunities in mobile game development.
  • Service Improvement: Analyzing how students interact with our materials to make courses more effective and our website more user-friendly.
  • Legal Compliance: Meeting our obligations under Georgian law and maintaining necessary records for educational institutions.

We don't use automated decision-making that would significantly affect your enrollment or access to educational opportunities without human review.

Data Sharing and Third Parties

We work with a limited number of trusted partners to deliver our services. Here's who might see your information and why:

Service Provider Purpose Data Shared
Payment Processors Handling course payments securely Name, payment details, transaction amounts
Email Service Providers Sending course materials and updates Email address, name, enrollment status
Learning Platform Hosts Hosting course content and tracking progress Account details, course activity, submissions
Analytics Tools Understanding website usage patterns Anonymized browsing data, demographics

All these partners are contractually required to protect your data and can only use it for the specific services they provide to us. We don't sell or rent your personal information to marketing companies or data brokers.

International Transfers: Some of our service providers operate servers outside Georgia. When we transfer data internationally, we ensure appropriate safeguards are in place through standard contractual clauses and security measures that meet Georgian legal requirements.

Your Rights and Control

Georgian data protection law gives you several rights over your personal information. Here's what you can do:

  • Access Your Data: Request a copy of all personal information we hold about you. We'll provide this in a readable format within 30 days.
  • Correct Inaccuracies: If any of your information is wrong or outdated, let us know and we'll update it promptly.
  • Request Deletion: Ask us to delete your personal data, though we may need to retain some information for legal or legitimate business reasons.
    • Active enrollment records must be kept during your course participation
    • Financial records are retained for tax compliance purposes (up to 6 years)
    • Academic transcripts may be kept to verify completion of programs
  • Object to Processing: You can object to how we use your information for marketing or certain analytical purposes.
  • Data Portability: Request your data in a machine-readable format to transfer to another service provider.
  • Withdraw Consent: If we're processing your data based on consent, you can withdraw that consent at any time.

To exercise any of these rights, send an email to contact@positionx.com with "Privacy Request" in the subject line. Include your full name and the specific action you're requesting. We'll verify your identity before processing requests that involve accessing or changing personal data.

Data Security Measures

Protecting your information isn't just a legal requirement for us. It's fundamental to maintaining the trust you place in our educational programs. Here's how we keep your data secure:

  • Encryption: All data transmitted between your browser and our servers uses TLS encryption. Sensitive information stored in our databases is encrypted at rest.
  • Access Controls: Only authorized staff members who need access to perform their jobs can view personal information. We use role-based permissions and regular access reviews.
  • Secure Infrastructure: Our systems are hosted with reputable providers who maintain industry-standard security certifications and regular security audits.
  • Regular Updates: We keep our software and security systems up to date with the latest patches and security improvements.
  • Staff Training: Our team receives regular training on data protection practices and security awareness.
  • Incident Response: We have procedures in place to detect, respond to, and notify you about any data breaches that might affect your information.

While we implement strong security measures, no system is completely invulnerable. We encourage you to use strong passwords and keep your login credentials confidential.

Data Retention Periods

We don't keep your information longer than necessary. Here's our retention approach for different types of data:

  • Active Student Records: Maintained throughout your enrollment and for 2 years after course completion to support alumni services and references.
  • Financial Records: Kept for 6 years to comply with Georgian tax and accounting regulations.
  • Marketing Contacts: If you've subscribed to updates but never enrolled, we'll keep your contact information until you unsubscribe or for 3 years of inactivity.
  • Website Analytics: Aggregated and anonymized usage data may be retained indefinitely for historical analysis and service improvement.
  • Correspondence: Emails and support messages are typically kept for 2 years to maintain context for ongoing relationships.

Deletion Process: When retention periods expire, we systematically delete or anonymize personal data. You can request earlier deletion by contacting us, subject to any legal obligations we have to retain certain records.

Cookies and Tracking

Our website uses cookies and similar technologies to function properly and improve your experience. Here's what we deploy:

  • Essential Cookies: These keep you logged in, remember your preferences, and enable basic website functionality. They're necessary for the site to work.
  • Analytics Cookies: Help us understand which pages are popular, how long people spend on different sections, and where our visitors come from.
  • Functional Cookies: Remember choices you make (like language preferences) to provide enhanced features.

You can control cookies through your browser settings. Keep in mind that blocking essential cookies might affect how the website functions. Most browsers let you:

  • See what cookies are stored and delete them individually
  • Block third-party cookies while allowing first-party ones
  • Block all cookies from specific websites
  • Delete all cookies when you close your browser

Children's Privacy

Our courses are designed for individuals aged 16 and older. We don't knowingly collect personal information from children under 16 without parental consent.

If you're under 18 and want to enroll in our programs, we'll need consent from a parent or legal guardian before processing your enrollment. They'll receive information about how we handle your data and must approve your participation.

If we discover we've inadvertently collected information from someone under 16 without proper consent, we'll delete that data promptly.

Changes to This Policy

We review and update this privacy policy periodically to reflect changes in our practices, technology, or legal requirements. When we make significant changes that affect how we handle your personal information, we'll notify you through:

  • Email to your registered address if you're an active student
  • A prominent notice on our website for at least 30 days
  • Direct communication during enrollment or course registration processes

The "Last Updated" date at the top of this page shows when the most recent changes were made. We encourage you to review this policy occasionally, especially before sharing new information with us.

Legal Basis for Processing

Under Georgian data protection law, we need a legal basis to process your personal information. Here's what applies to different types of processing:

  • Contractual Necessity: When you enroll in courses, we process your data to fulfill our educational services contract with you.
  • Legitimate Interests: We process certain data to improve our programs, prevent fraud, and maintain security where this doesn't override your privacy rights.
  • Legal Obligations: Some processing is required to comply with Georgian tax, education, and business regulations.
  • Consent: For marketing communications and optional features, we rely on your explicit consent, which you can withdraw anytime.

Questions About Your Privacy?

If you have concerns about how we handle your personal information, want to exercise your rights, or just have questions about this policy, we're here to help.

Email: contact@positionx.com
Phone: +995 422 27 40 59
Address: ძმები ზუბალაშვილების #16, Tbilisi 1001, Georgia

We'll respond to privacy inquiries within 10 business days. For complex requests, we might need up to 30 days and will keep you informed about our progress.