Privacy policy


As used in this “Privacy Policy”, “Eduscale” refers to all websites (including, properties, and services owned or operated by Cobrand bv, aka Eduscale.

This Privacy Policy is part of Eduscale’s Terms of Use and describes the privacy practices of Eduscale. It explains when and how Eduscale collects end user and client information, including Personally Identifiable Information (defined below), how we use such information, and the circumstances under which we may disclose such information to others. This Privacy Policy includes the policies that Eduscale observes for compliance with laws in the European Union as well as other applicable laws, including those followed regarding the transfer of Personally Identifiable Information from the European Economic Area (“EEA”) and/or Switzerland to the United States under the U.S. – EU Privacy Shield and U.S. – Swiss Safe Harbor, respectively (collectively, the “Safe Harbor and Privacy Shield”).

By visiting the Eduscale website, visiting an Eduscale client website that provides notice of its use of Eduscale and/or this policy, or registering for our service, you acknowledge that you accept and consent to the practices outlined in this Privacy Policy.

What Types of User Information Does Eduscale Obtain?

Visitors to the Eduscale Website. If you are a visitor to the Eduscale website or an Eduscale client (“Client”) who registers or signs into the Eduscale website (including for purposes of obtaining our ChurnList service), we may obtain the following types of information from you or concerning your computer or device (“Eduscale Client Information”), which may include information that can itself be used to identify and/or contact you (“Personally Identifiable Information”):

  • Name

  • Email address

  • Phone number

  • Logo

  • Website name and URL

  • Credit card number

  • Billing address

  • Visitor site preferences

  • Eduscale may also receive certain information that may be provided by your browser or mobile device, including:

  • Browser information

  • Operating system information

  • Mobile device information (e.g., device identifier, mobile operating system, etc.)

  • IP address

  • Pages accessed

  • Time of visit

  • Time of last visit

Referring site, application, or service, including the relevant search queries that led you to Eduscale’s website

Visitors to Eduscale’s Clients’ Websites. Our Clients may use customized and proprietary Eduscale code, software and/or services (“Service(s)”) to obtain information regarding the activities that users engage in while visiting their web pages (“Client User Data”). When a user visits a website that uses Eduscale’s Service, Eduscale code contained on the website contacts Eduscale’s servers and enables Eduscale to collect Client User Data. Some Clients may also use their own code to obtain Client User Data and then send such information to Eduscale’s servers. Client User Data may include Personally Identifiable Information, including, but not limited to, the types of information listed for Eduscale Client Information above.

Client User Data is stored on Eduscale’s web servers and databases (including those hosted on third party servers on behalf of Eduscale) for use in performing analysis and producing reports for the applicable Eduscale Client. In addition, Eduscale itself uses the Eduscale Service in order to obtain insights into visitors’ activities on its own websites, which include, as of the Effective Date,

Eduscale’s collection and analysis of Client User Data helps our Clients to evaluate and understand how their users are interacting with their websites, and potentially, to modify their websites in order to make them more valuable or useful for their users. Eduscale’s Clients determine the types of Client User Data that are sent to Eduscale’s servers for analysis. This data may include or be linked to Personally Identifiable Information depending on how the Client uses Eduscale’s Services on its website(s). Eduscale’s Clients are contractually prohibited from sending personally sensitive Client User Data (e.g. personal health information, political opinions, religious or philosophical beliefs) to Eduscale and Eduscale does not knowingly receive such data.

In addition, Eduscale may collect certain information about a Client’s visitor’s computer that may be provided by the visitor’s browser. This includes browser information, operating system information, mobile device information, IP address, time of visit, and the referring site, application, or service, time on page, click history. Such information may be collected and shared with the Eduscale Client even though not specifically requested by the Client.

How Do We Use This Information?

Visitors to the Eduscale Website. We use the Eduscale Client Information, including Personally Identifiable Information, to register your account, fulfill your requests, understand how you are engaging with Eduscale, communicate with you, determine if you are satisfied with the Service, process billing for Eduscale Services, and personalize your experience on the Eduscale website and with the Eduscale Service.

Next to that, we may use this information for marketing purposes. F.ex. list your name logo on our website.

We may also use Eduscale User Information to facilitate the delivery of content or advertisements that we believe may be of interest to you, or to communicate with you about new or existing products and services or special offers. For more information on opting out of these communications, please see the section on “User Privacy Controls” below.

For Clients that authorizes their Google account in order to access Eduscale’s product and functionality, agrees to give Eduscale the ability to send email on behalf of that Client. At the same time, Client will agree to allow Eduscale to display the content of specific, relevant emails in Client’s Eduscale instance only.

Visitors to Eduscale’s Clients’ Websites. Except as described in the “Disclosure of Information to Third Parties” section below, Eduscale never sells or shares any Client User Data with individuals or companies other than the specific Client whose website transmitted the Client User Data to Eduscale.

Eduscale does not collect or aggregate information about end user behavior across multiple, different websites that are operated by different Clients, nor does it use any Client User Data for purposes of behavioral advertising. However, Eduscale may analyze Client User Data in the aggregate for purposes of internal research and/or to determine overall trends or metrics concerning how users are engaging with websites, and may report such general trends publicly, without disclosing any Client User Data.

Our Client’s Use of Eduscale. Eduscale contractually requires its Clients to abide by all applicable laws, rules and regulations, including the Safe Harbor and Privacy Shield where it applies, as well as other applicable laws relating to privacy and data collection (“Applicable Laws”). Eduscale also contractually requires its Clients to obtain any necessary consents from visitors to its website(s) for the Client’s use of Eduscale’s services, comply with all Applicable Laws (including, as an example, the Safe Harbor and Privacy Shield where it applies) with respect to the transfer of Personally Identifiable Information of EU or Swiss subjects through the Service, and to post an online privacy policy that provides each visitor with clear notice of its practices regarding data collection, use, and disclosure (including the Client’s use of Eduscale), along with a link to the Eduscale Privacy Policy.

Eduscale cannot be held responsible for any Client’s failure to make these disclosures on its website or for any Client’s use or collection of Client User Data that is not permitted under this Privacy Policy or otherwise. For more details on the terms that apply to our Clients’ use of the Eduscale Service, please see Section 4 (“Privacy”) in the Eduscale terms.

Eduscale’s Use of Cookies and Web Beacons

Cookies. Eduscale uses cookies (small text files that Eduscale stores locally on your computer) on our Client’s websites for one or more of the following purposes: to help identify unique visitors and/or devices; assess usage patterns and perform traffic analysis; identify visitor preferences; conduct A/B testing; diagnose problems with our servers, and otherwise administer the Eduscale Service. Eduscale does not use methods such as browser cache, Flash cookies, or eTags, for acquiring or storing information about end users web browsing activity on Client websites or otherwise.

Depending on how our Clients use Eduscale’s Services, information contained in Eduscale cookies placed on the computers of end users may be linked to Personally Identifiable Information in Eduscale’s database. This allows our Clients to use the Eduscale Service to better analyze and measure their users’ interactions with their website and to organize activities by the same user on their website across time.

If you do not wish to have Eduscale place and use cookies on your computer, you should set your browser preferences to refuse all cookies before accessing Eduscale or other websites that may use Eduscale. Eduscale is not responsible for any failure by you or your browser to accurately implement or communicate your browser preferences or settings. In addition, please be aware that even if you configure your browser settings to reject all cookies, your activity on Eduscale client websites will still be recorded by our Service, unless you opt out of our Service as set forth below. However, your rejection of all cookies will prevent Eduscale from determining whether or not someone using your computer has previously visited the website, i.e., whether or not the visitor is a “unique” visitor, and from retrieving any information about your prior activities on a Client’s website through information contained in a cookie.

Please note that if you set your browser to reject cookies, some features of the websites you visit may be unavailable. For more information on how to reject cookies, see your browser’s instructions on changing your cookie settings. Additionally, please note that rejecting cookies may also prevent you from opting out of our Service because that involves placing an opt-out cookie in your browser.

If you do not elect to set your browser preferences to refuse cookies, you consent to have cookies, including cookies used by Eduscale, placed on your computer when you visit our Client’s websites.

Web Beacons. Eduscale may also collect certain information using Web Beacons. “Web Beacons” are electronic images that may be used on Eduscale’s Website, in Eduscale’s Service, or in our email communications. They are used, for example, to count website visits or to tell if an email has been opened and acted upon.

Disclosure and Transfer of Information to Third Parties

Service Providers. Information, including Eduscale Client Information, Client User Data, and any Personally Identifiable Information contained therein, may be shared with certain third-party companies and individuals that help facilitate technical and administrative aspects of the Eduscale Service (e.g., credit card processing), or perform functions related to the administration of Eduscale (e.g. hosting services). These third parties perform tasks on our behalf and are contractually obligated not to disclose or use Eduscale User Information or Client User Data for any other purpose, and to employ adequate security measures to prevent unauthorized access to such data. However, Eduscale is not responsible in the event that Personally Identifiable Information is disclosed as a result of a breach or security lapse by any such third party.

Eduscale Clients.

Eduscale Clients may share Client User Data with service providers (e.g. customer relationship management platforms) that perform tasks on behalf of Eduscale Clients. Eduscale contractually requires the Clients to disclose such practices to its users.

Law Enforcement and Legal Process. Eduscale also reserves the right to disclose any Eduscale Client Information or Client User Information (including Personally Identifiable Information) to: (i) comply with any law, regulation, or legal request; (ii) enforce, apply, or investigate breaches of the Terms of Use or other agreements; (iii) respond to client requests; or (iv) protect the rights, property, or safety of Eduscale, our employees, our users, or others.

Change of Control. If Eduscale, or substantially all of its assets, is acquired by another company or successor entity, Eduscale Client Information and/or Client User Data will be one of the assets transferred or acquired by the purchaser or successor. You acknowledge that such transfers may occur, and that any purchaser of or successor to Eduscale or its assets may continue to collect, use and disclose your information acquired prior to such transfer or acquisition as set forth in this policy.

User Privacy Controls and Do Not Track Signals

Clients and Visitors to the Eduscale Website. Eduscale offers several ways for you to review and update account information that is obtained and stored by Eduscale, or to change your Eduscale communication preferences:

If you have an Eduscale account, you can review or update your account information by contacting us at [email protected]

You may unsubscribe to any of our e-mail or direct message communications regarding updates or products by following the unsubscribe instructions in the body of any message.

Opt-in/Opt-out of Eduscale Tracking

If you would like to opt out of Eduscale tracking, you can email [email protected]

This opt-out mechanism applies to all Eduscale Client websites, meaning that no user data will be collected about you on any such websites. Please note that if you use a different device or Internet browser than you used when opting out of Eduscale’s Service, or if you clear your cookies, Eduscale will not be able to view the opt-out and will collect Client User Data when you visit Eduscale Client websites. In these circumstances, you will need to revisit the link above from the new browser or device in order to reiterate your opt-out decision for that device or browser.

Email Communications

We may contact you by e-mail or other equivalent electronic communications if you access Eduscale products or services. By registering or using Eduscale Services, you specifically consent to the receipt of these e-mail or text message communications. If you do not want to receive emails or other communications from us, please follow the unsubscribe instructions in the body of such communications or notify us by email at [email protected]

How We Protect Your Personal Information

Eduscale has implemented reasonable security mechanisms to protect Eduscale Client Information and Client User Data that is maintained on Eduscale’s servers from loss, misuse and unauthorized access, disclosure, alteration and destruction. Examples of these security mechanisms include high security public/private keys, encryption on processed data, and SSL encryption to protect transmission of data.

However, please keep in mind that no security system is impenetrable. It may be possible for third parties to intercept or access Eduscale Client Information and Client User Data in spite of these measures. Eduscale cannot guarantee the security of your information and cannot be held responsible for unauthorized access to Eduscale client accounts.

Our Policy Toward Children

Our Site and Service is not directed to children under 13. We do not knowingly collect personally identifiable information from children under 13 or from websites that are targeted to children under 13. If you are under 13, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us as provided below. If we become aware that a child under 13 has provided us with personally identifiable information, we will delete such information from our servers.

Changes to this Privacy Policy

Eduscale retains the discretion to amend or modify this Privacy Policy from time to time. If we make material changes to the way we collect, use or disclose Personally Identifiable Information, we will notify you by posting a clear and prominent announcement on Eduscale or through a direct communication to your Eduscale account. For new users, the change or update will become effective upon posting. For existing users, the change or update will become effective 14 days after posting.

Use and disclosure of information we obtain is subject to the later of: (1) the Privacy Policy in effect at the time such information is collected or (2) any subsequent Privacy Policy of which you have constructive notice.

How to Contact Us

Eduscale welcomes any questions or comments about this Privacy Policy or our privacy practices. Any such comments or questions should be submitted via e-mail to: [email protected], or by first class mail, air mail, or overnight courier to:

Cobrand bv

Fazantenstraat 48

9940 Evergem, Belgium

We will use reasonable efforts to respond promptly, within 10-20 business days, to requests, questions or concerns you may have regarding access to Personally Identifiable Information about you that we have collected. We may contact you for follow up information.

Marketing analtyics & GDPR

Eduscale makes use of the website analytics tool Google Analytics and our own Eduscale Service. We use this to improve content on our website and to measure effectiveness of marketing efforts. The received data is stored, along with your IP address, transferred to set parties and stored in their servers. Read the privacy policy of Google for more information.

Google uses this information to see how our website is used, to generate reports to Eduscale and to show their advertisers information about the effectiveness of their campaigns.

Google can share this data with third parties when they are legally obliged to, or subcontractors who process the data in name of Google. Eduscale has no influence on this.

Eduscale has given Google no permission to use data gained from Eduscale for other Google services. Google and has to comply to GDPR regulations.


You have the right to look into your own data, correct or delete it. You can send a request for either of these to [email protected] Eduscale will answer your request as fast as possible, but within 3 weeks minimum.

Effective Date of this Privacy Policy

This Privacy Policy is effective as of June 30, 2020.