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.