Effective as of August 22, 2025.
This Privacy Policy describes how MyDojo Inc d/b/a RevisionDojo and its affiliates ("RevisionDojo",
"we", “us” or "our") processes personal information that we collect through our digital or online
properties or services that link to this Privacy Policy (including as applicable, our website and the
application functionality on our website, marketing activities, and other activities described in this
Privacy Policy (collectively, the “Service”)).
RevisionDojo is an online learning platform designed to support individual learners (“Students”) with
tools for personalized revision, progress tracking, and study insights. We also provide our services to
educational institutions (“Schools”) that use RevisionDojo to support and monitor their students’
learning. This Privacy Policy applies to RevisionDojo’s processing of personal information when we
provide our Service directly to Students. This Privacy Policy does not apply to information that we
process on behalf of Schools (for example, in the context of an institutional subscription) while
providing services to them. Our use of information that we process on behalf of Schools is governed
by our agreements with such Schools. If you have concerns regarding your personal information that
we process on behalf of a School, please direct your concerns to that School.
European Users: Please see the ‘Notice to European Users’ section below for additional
information for individuals located in the European Economic Area or United Kingdom (which we
refer to as “Europe,” and “European” should be understood accordingly).
Contents:
•
Personal information we collect
•
How we use your personal information
•
How we share your personal information
•
Your choices
•
Other sites and services
•
Security
•
International data transfer
•
Children
•
Changes to this Privacy Policy
•
How to contact us
•
Notice to European Users
Personal information we collect
We may collect different types of personal information depending on whether you are a:
•
Student using the Service directly for learning purposes, such as creating an account,
uploading academic content, or using our AI tutor;
•
School representative or prospect interacting with us on behalf of a School or in a
business or marketing context (e.g., via our website) (a “Representative”); or
•
A visitor to our website.
A. Information we collect about Students.
When you use the Service as a Student, the personal information you may provide to us through
the Service or otherwise includes:
•
Contact data, such as your first and last name, email address, address, and phone number.
•
Profile data, such as the username and password that you may set to establish an online
account with us, school affiliation, interests, preferences, and any other information that you
add to your account profile.
•
Communications data based on our exchanges with you, including when you contact us
through the Service, social media, or otherwise.
•
Academic content data, such as answers or other content which you upload to our Service
for AI grading and review. When you submit coursework, all uploaded files are automatically
and permanently deleted after 48 hours. The text extracted from your submission through
Optical Character Recognition (“OCR data”) may be retained only to provide ongoing context
for interactions with our AI tutor, JojoAI, such as enabling continued suggestions, feedback,
and related insights after your files are removed. At any time, you may also choose to
permanently delete all of your data, including the retained OCR text, by using the permanent
delete button.
•
User-generated content data, such as comments, questions, messages, and other content
or information that you generate, transmit, or otherwise make available on the Service
(including via interactions with our AI tutor, JojoAI), as well as associated metadata.
Metadata includes information on how, when, where and by whom a piece of content was
collected and how that content has been formatted or edited. Metadata also includes
information that users can add or can have added to their content, such as keywords,
geographical or location information, and other similar data.
•
Other data not specifically listed here, which we will use as described in this Privacy Policy
or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from Students with
personal information we obtain from other sources, such as:
•
Public sources, such as government agencies, public records, social media platforms, and
other publicly available sources.
•
Data providers, such as information services and data licensors
•
Schools you may attend that provide us with information about you.
•
Third-party services that you use to log into, or otherwise link to, your Service account. This
data may include your username, profile picture and other information associated with your
account on that third-party service that is made available to us based on your account
settings on that service, such as Google, that you use to log into, or otherwise link to, your
Service account. Our use and disclosure of information received from Google’s APIs will
adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Data about others. We may offer features that help users invite their friends or classmates to use
the Service, and we may collect contact details about these invitees so we can deliver their
invitations. Please do not refer someone to us or share their contact details with us unless you have
their permission to do so.
B. Information we collect about Representatives.
When you use the Service as a Representative, the personal information you may provide to us
through the Service or otherwise includes:
•
Contact data, such as your first and last name, email address, address, and phone number.
•
Professional data, such as your title, school or company affiliation, and location.
•
Communications data based on our exchanges with you, including when you contact us
through the Service, social media, or otherwise.
•
Marketing data, such as your preferences for receiving our marketing communications and
details about your engagement with them.
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•
Other data not specifically listed here, which we will use as described in this Privacy Policy
or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal
information we obtain from other sources, such as:
•
Public sources, such as government agencies, public records, social media platforms, and
other publicly available sources.
•
Data providers, such as information services and data licensors that provide demographic
and other information.
•
Service providers that provide services on our behalf or help us operate the Service or our
business.
•
Partners, such as marketing partners and event co-sponsors.
C. Information we collect about Students, Representatives, and general website visitors.
Automatic data collection. We, our service providers, and our business partners may automatically
log information about you, your computer or mobile device, and your interaction over time with the
Service, our communications and other online services, such as:
•
Device data, such as your computer or mobile device’s operating system type and version,
manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage,
device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile
device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location
information such as city, state or geographic area.
•
Online activity data, such as pages or screens you viewed, how long you spent on a page
or screen, the website you visited before browsing to the Service, navigation paths between
pages or screens, information about your activity on a page or screen, access times and
duration of access, and whether you have opened our emails or clicked links within them.
•
Communication interaction data such as your interactions with our email, text or other
communications (e.g., whether you open and/or forward emails) – we may do this through
use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in
our emails.
Cookies and similar technologies. Some of the automatic collection described above is facilitated
by cookies and similar technologies – for example, we may store a record of your preferences in
respect of the use of these technologies in connection with the Service. For more information, see
our Cookie Policy.
How we use your personal information
We may use your personal information for different purposes depending on how you interact with us.
Some uses apply only to Students who create a platform account. Others apply only to
Representatives who interact with us via our website or other business channels to the extent that
we are a controller of such data.
A. Students
Service personalization. We may use your personal information to:
•
personalize the service, including remembering the devices from which you have previously
logged in and remembering your selections and preferences as you navigate the Service;
and
•
understand your needs and interests, and personalize your experience with the Service and
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our communications.
B. Representatives
Marketing and advertising. We, our service providers and our third-party advertising partners may
collect and use Representatives’ personal information for marketing and advertising purposes:
•
Direct marketing. We may send you direct marketing communications and may personalize
these messages based on your needs and interests. You may opt-out of our marketing
communications as described in the Opt-out of marketing section below.
•
Interest-based advertising. Our third-party advertising partners may use cookies and
similar technologies to collect information about your interaction (including the data
described in the ‘Cookies and similar technologies’ section above) with the Service, our
communications and other online services over time, and use that information to serve online
ads that they think will interest you. This is called interest-based advertising. We may also
share information about our users with these companies to facilitate interest-based
advertising to those or similar users on other online platforms. You can learn more about
your choices for limiting interest-based advertising in the Your choices section of our Cookie
Notice.
C. Students, Representatives, and general website visitors
Service delivery and operations. We may use your personal information to:
•
provide, operate and improve the Service and our business;
•
establish and maintain your user profile on the Service;
•
facilitate your invitations to friends who you want to invite to join the Service;
•
enable security features of the Service, such as by sending you security codes via email or
SMS, and remembering devices from which you have previously logged in;
•
communicate with you about the Service, including by sending Service-related
announcements, updates, security alerts, and support and administrative messages;
•
communicate with you about events or contests in which you participate; and
•
provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development
purposes, including to analyze and improve the Service and our business and to develop new
products and services. As part of these activities, we may create aggregated, de-identified and/or
anonymized data from personal information we collect. We make personal information into de-
identified or anonymized data by removing information that makes the data personally identifiable to
you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third
parties for our lawful business purposes, including to analyze and improve the Service and promote
our business.
Service improvement and analytics. We may use your account information to analyze your usage
of the Service, improve the Service, improve the rest of our business, help us understand user
activity on the Service, including which pages are most and least visited and how visitors move
around the Service, as well as user interactions with our emails, and to develop new products and
services.
Compliance and protection. We may use your personal information to:
•
comply with applicable laws, lawful requests, and legal process, such as to respond to
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subpoenas, investigations or requests from government authorities;
•
protect our, your or others’ rights, privacy, safety or property (including by making and
defending legal claims);
•
audit our internal processes for compliance with legal and contractual requirements or our
internal policies;
•
enforce the terms and conditions that govern the Service; and
•
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal
activity, including cyberattacks and identity theft.
Data sharing in the context of corporate events. We may share certain personal information in
the context of actual or prospective corporate events – for more information, see the reference to
sharing with ‘Business transferees’ in the section ‘How we share your personal information’,
below.
Cookies and similar technologies. In addition to the other uses included in this section, we may
use Cookies and similar technologies. For more information, see our Cookie Policy.
Further uses. In some cases, we may use your personal information for further uses, in which case
we will ask for your consent to use of your personal information for those further purposes if they are
not compatible with the initial purpose for which information was collected.
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this
Privacy Policy, in other applicable notices, or at the time of collection. We do not knowingly share
personal information of users under the age of 18 with business or advertising partners for marketing
purposes.
Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Service
or our business (such as payment processing, hosting, information technology, customer support,
email delivery, marketing, consumer research and website analytics). Our enterprise AI agreements
with Anthropic and OpenAI include strict provisions that prohibit these providers from training their
models on user data. As such, a zero-day data retention policy is in place, meaning user data is not
stored by these providers beyond what is required for processing.
Business and marketing partners. Third parties with whom we co-sponsor events or promotions,
with whom we jointly offer products or services, or whose products or services may be of interest to
you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers,
where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we
believe in good faith to be necessary or appropriate for the Compliance and protection purposes
described above.
Business transferees. We may disclose personal information in the context of actual or prospective
business transactions (e.g., investments in RevisionDojo, financing of RevisionDojo, public stock
offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example,
we may need to share certain personal information with prospective counterparties and their
advisers. We may also disclose your personal information to an acquirer, successor, or assignee of
RevisionDojo as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the
event of an insolvency, bankruptcy, or receivership in which personal information is transferred to
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one or more third parties as one of our business assets.
Other users and the public. Your profile and other user-generated content data may be visible to
other users of the Service and the public. For example, other users of the Service or the public may
have access to your information if you chose to make your forum account profile or other personal
information available to them through the Service, such as when you provide comments, reviews,
survey responses, or share other content. This information can be seen, collected and used by
others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search
engines), and we are not responsible for any such use of this information.
Your choices
Access or update your information. If you have registered for an account with us through the
Service, you may review and update certain account information by logging into the account.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out
or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you
choose to opt-out of marketing-related emails, you may continue to receive service-related and other
non-marketing emails.
Cookies. For more information about cookies and similar technologies employed by the Service and
how to manage your preferences, see our Cookie Policy.
Blocking images/clear gifs: Most browsers and devices allow you to configure your device to
prevent images from loading. To do this, follow the instructions in your particular browser or device
settings.
Privacy settings. We make available certain privacy settings on the Service. To modify these
settings, visit your Account Settings.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the
online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more
about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain
services. If you do not provide the information we identify as required or mandatory, we may not be
able to provide those services.
Remove or anonymize your content. You may request that the content that you posted to the
Service be removed or anonymized such that your personal information will not be publicly
identifiable on the Service by contacting us. We may decline to process your request as consistent
with law. Please note that even if we process your request, it does not ensure complete or
comprehensive removal of the content or information posted on the Service.
Delete your content or close your account. You can choose to delete certain content through your
account. If you wish to request to close your account, please contact us or visit your account settings
to do so.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated
by third parties. In addition, our content may be integrated into web pages or other online services
that are not associated with us. These links and integrations are not an endorsement of, or
representation that we are affiliated with, any third party. We do not control websites, mobile
applications or online services operated by third parties, and we are not responsible for their actions.
We encourage you to read the privacy policies of the other websites, mobile applications and online
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services you use.
Security
We employ a number of technical and organizational safeguards designed to protect the personal
information we collect. However, security risk is inherent in all internet and information technologies
and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other
countries. Your personal information may be transferred to the United States or other locations
where privacy laws may not be as protective as those in your state, province, or country.
Users in Europe should also read the information provided about transfers of personal information to
recipients outside Europe contained in the ‘Notice to European Users’ below.
Children
If you are a parent or guardian of a child from whom you believe we have collected personal
information in a manner prohibited by law, please contact us. We encourage parents and guardians
to monitor their children’s use of our Service and to contact us of they have any concerns.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this
Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the
Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon
our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your
use of the Service after the effective date of any modified Privacy Policy indicates your
acknowledging that the modified Privacy Policy applies to your interactions with the Service and our
business.
How to contact us
•
Email: privacy@revisiondojo.com
•
Phone:+1 415 715 1206
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Notice to European users
General
Where this Notice to European users applies. The information provided in this ‘Notice to
European users’ section applies only to individuals located in the European Economic Area (EEA) or
United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).
Personal information. References to “personal information” in this Privacy Policy should be
understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General
Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of
the United Kingdom (“UK GDPR”). Under the GDPR, “personal data” means information about
individuals from which they are either directly identified or can be identified. The personal information
that we collect from and about you is described in greater detail in the section “Personal information
we collect” that is set out above.
Controller. MyDojo Inc d/b/a RevisionDojo is the “controller” in respect of the processing of your
personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to
contact us’ section above for our contact details.
Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires
us to ensure that we have a “legal basis” for that use.
Our legal bases for processing your personal information described in this Privacy Policy are listed
below.
●
Where we need to process your personal information in order to deliver the Service to you,
or where you have asked us to take specific action which requires us to process your
personal information (“Contractual Necessity”).
●
Where it is necessary for our legitimate interests and your interests and fundamental rights
do not override those interests (“Legitimate Interests”). More detail about the specific
legitimate interests pursued in respect of each purpose we use your personal information for
is set out in the table below.
●
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
●
Where we have your specific consent to carry out the processing for the purpose in question
(“Consent”).
We have set out below, in a table format, the legal bases we rely on in respect of the relevant
purposes for which we use your personal information – for more information on these Purposes and
the data types involved, see the ‘How we use your personal information’ section above and the
description of associated data sharing relevant to such purposes set out in the ‘How we share your
personal information’ section also above.
Purpose
Categories of personal
information involved
Legal basis
A. Students
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Service
personalization
•
Profile data
•
Data from Third-Party
Sources.
•
Device data
•
Legitimate Interests. We have a
legitimate interest in providing you with a
good service via the Service, which is
personalized to you and that remembers
your selections and preferences.
•
Consent, in respect of any optional
processing relevant to personalization
(including processing directly associated
with any optional cookies used for this
purpose).
B. Representatives
Service delivery
and operations
•
Contact data
•
Communications data
•
Transactional data
•
Data from Third-Party
Sources
•
Device data
•
Contractual Necessity.
•
Legitimate Interests. We have a
legitimate interest in ensuring the ongoing
security and proper operation of our
Service (including, where relevant,
responding to any contact via any
“contact us” feature or similar), our
business and associated IT services,
systems and networks.
Direct marketing
•
Contact data
•
Marketing data
•
Data from Third Party
Sources
•
Communication
interaction data
•
Legitimate Interests. We have a
legitimate interest in promoting our
operations and goals as an organization
and sending marketing communications
for that purpose.
•
Consent, i n c irc ums tances or i n
jurisdictions where consent is required
under applicable data protection laws to
the sending of any given marketing
communications.
Interest-based
advertising
•
Device data
•
Online activity data
•
Consent
C. Students, Representatives, and general website visitors
Purpose
Categories of personal
information involved
Legal basis
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Service delivery
and operations
•
Contact data
•
Profile data
•
Communications data
•
Transactional data
•
A ca d e m ic c o n t en t
data
•
User-generated
content data
•
Data from Third-Party
Sources
•
Device data
•
Contractual Necessity.
•
Legitimate Interests. We have a
legitimate interest in ensuring the ongoing
security and proper operation of our
Service (including, where relevant,
responding to any contact via any
“contact us” feature or similar), our
business and associated IT services,
systems and networks.
Research and
development
To create
aggregated, de-
identified and/or
anonymized data
•
Any and all data types
relevant in the
circumstances
•
Legitimate Interests.
o
We have a legitimate interest in
conducting research and
development, including to analyze
and improve the Service and our
business and to develop new
products and services.
o
We have a legitimate interest in
creating aggregated, de-identified
and/or anonymized data in this
context to preserve the privacy of
our users.
Service
improvement and
analytics
•
Contact data
•
Profile data
•
Communications data
•
Data from Third Party
Sources
•
Device data
•
Online activity data
•
Legitimate Interests. We have a
legitimate interest in providing you with a
good service and analyzing how you use
it so that we can improve it over time, as
well as developing and growing our
business.
•
Consent, in respect of any optional
cookies used for this purpose.
Compliance and
protection
•
Any and all data types
relevant in the
circumstances
•
Compliance with Law.
•
Legitimate Interests. Where Compliance
with Law is not applicable, we have a
legitimate interest in participating in,
supporting, and following legal process
and requests, including through co-
operation with authorities. We may also
have a legitimate interest in ensuring the
protection, maintenance, and
enforcement of our rights, property, and/or
safety.
Purpose
Categories of personal
information involved
Legal basis
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Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected
it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to
establish or defend legal claims, or otherwise for the ‘Compliance and protection’ purposes outlined
above.
To determine the appropriate retention period for personal information, we consider the amount,
nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use
or disclosure of your personal information, the purposes for which we process your personal
information and whether we can achieve those purposes through other means, and the applicable
legal requirements.
When we no longer require the personal information that we have collected about you, we will either
delete or anonymize it or, if this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal information and isolate it
from any further processing until deletion is possible. If we anonymize your personal information (so
that it can no longer be associated with you), we may use this information indefinitely without further
notice to you.
Other information
No obligation to provide personal information. You do not have to provide personal information to
us. However, where we need to process your personal information either to comply with applicable
law or to deliver our Service to you, and you fail to provide that personal information when
requested, we may not be able to provide some or all of our Service to you. We will notify you if this
is the case at the time.
No sensitive information. We ask that you not provide us with any sensitive personal information
(e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health,
criminal background or trade union membership, or biometric or genetics characteristic other than as
requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide
us with any such sensitive personal information to us when you use the Service, you must consent
Data sharing in the
c o n t e x t o f
corporate events
•
Any and all data types
relevant in the
circumstances
•
Legitimate Interests. We have a
legitimate interest in providing information
to ‘Business transferees’ and parties who
are involved in an actual or prospective
corporate event (including to enable them
to investigate – and, where relevant, to
continue to operate – all or relevant
part(s) of our operations).
Further uses
•
Any and all data types
relevant in the
circumstances
•
The original legal basis relied upon, if the
relevant further use is compatible with the
initial purpose for which the personal
information was collected.
•
Consent, if the relevant further use is not
compatible with the initial purpose for
which the personal information was
collected.
Purpose
Categories of personal
information involved
Legal basis
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to our processing and use of such sensitive personal information in accordance with this Privacy
Policy. If you do not consent to our processing and use of such sensitive personal information, you
must not submit such sensitive personal information through our Service.
No automated decision-making and profiling. As part of the Service, we do not engage in
automated decision-making and/or profiling, which produces legal or similarly significant effects.
Your additional rights
General. European data protection laws may give you certain rights regarding your personal
information in certain circumstances. If you are located in Europe, you may ask us to take the
following actions in relation to your personal information that we hold:
•
Access. Provide you with information about our processing of your personal information and
give you access to your personal information.
•
Correct. Update or correct inaccuracies in your personal information.
•
Delete. Delete your personal information where there is no good reason for us continuing to
process it - you also have the right to ask us to delete or remove your personal information
where you have exercised your right to object to processing (see below).
•
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your
personal information which you have provided to us.
•
Restrict. Restrict the processing of your personal information, for example if you want us to
establish its accuracy or the reason for processing it.
•
Object. Object to our processing of your personal information where we are relying on
Legitimate Interests – you also have the right to object where we are processing your
personal information for direct marketing purposes.
•
Withdraw Consent. When we use your personal information based on your consent, you
have the right to withdraw that consent at any time.
Exercising These Rights. You may submit these requests by contacting us. We may request
specific information from you to help us confirm your identity and process your request. Whether or
not we are required to fulfill any request you make will depend on a number of factors (e.g., why and
how we are processing your personal information), if we reject any request you may make (whether
in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal
restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge
a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all
legitimate requests within a month of receipt. It may take us longer than a month if your request is
particularly complex or if you have made a number of requests; in this case, we will notify you and
keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to
contact us first to find a solution for any concern you may have, in addition to your rights outlined
above, if you are not satisfied with our response to a request you make, or how we process your
personal information, you can make a complaint to the data protection regulator in your habitual
place of residence.
•
For users in the European Economic Area – the contact information for the data protection
regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/
board/members_en
•
For users in the UK – the contact information for the UK data protection regulator can be
found here: https://ico.org.uk/make-a-complaint/
Data Processing outside Europe
RevisionDojo is a U.K.-based company – many of our service providers, advisers, partners or other
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recipients of data are also based in the U.K. This means that, if you use the Service, your personal
information will necessarily be accessed and processed in the U.K. It may also be provided to
recipients in other countries outside Europe.
Where we share your personal information with third parties who are based outside Europe, we try
to ensure a similar degree of protection is afforded to it by making sure one of the following
mechanisms is implemented:
•
Transfers to territories with an adequacy decision. We may transfer your personal
information to countries or territories whose laws have been deemed to provide an adequate
level of protection for personal information by the European Commission or UK Government
(as and where applicable) (from time to time) or under specific adequacy frameworks
approved by the European Commission or UK Government (as and where applicable) (from
time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
•
Transfers to territories without an adequacy decision.
o
We may transfer your personal information to countries or territories whose laws have
not been deemed to provide such an adequate level of protection (e.g., the U.S.).
o
However, in these cases:
▪
we may use specific appropriate safeguards, which are designed to give personal
information effectively the same protection it has in Europe – for example, standard-
form contracts approved by relevant authorities for this purpose; or
▪
in limited circumstances, we may rely on an exception, or ‘derogation’, which
permits us to transfer your personal information to such country despite the
absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example,
reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when
transferring your personal information out of Europe.
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