Polkadot Blockchain Academy ("PBA") is committed to protecting and respecting your privacy. PBA runs a classroom-based educational program covering the conceptual underpinnings and the hands-on application of blockchain technology, using Polkadot and Substrate as the foundations (the “Academy”).

This policy (together with our terms of use on the website https://polkadot.network/development/blockchain-academy, and any subdomains such as  (the “Site”) (and any other documents referred herein) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in accordance with the General Data Protection Regulation (EU) 2016/ 679 (“GDPR”) and other applicable data protection laws. 

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. More information about your rights and how you can exercise them is set out in the “Your Rights” section below.

This Privacy Notice applies to PBA mailing list subscribers; Academy applicants; Academy faculty, guests and visitors; PBA vendors and consultants. For current students and members of the Academy’s Alumni Community, this policy applies in addition to the Privacy Appendix in your relevant cohort Student Terms and Conditions. 

For website visitors, the following privacy policy applies to you:https://polkadot.network/privacy/

What data do we collect from you?

We may collect and process the following personal data about you:

  • Identity and Contact Data, including your name, contact information (such as email address, social media handles (such as Github, LinkedIn, Discord handle), date of birth, passport number, photos, gender, visa information and other personal data concerning your preferences relevant to our services;
  • Application-related information: Employment and education history, referrals or references, any other information you provide (such as information on your resume or cover letter) and any information that applicable local laws require us to collect in connection with the selection process.
  • Selection Information: Interview details, outcomes of any recruiting exercises you complete, and the details of any offer letter and contract we provide.
  • Performance and Conduct Information: Information concerning your attendance at the Academy, responses to and outcomes of any assessments or further interviews you take while at the Academy or during the selection process, any grievances and complaints, and information about any violation of laws or breach of Academy policies while at the Academy or during the selection process.
  • Communication Information: Records of communication (where permissible) and communication metadata.
  • Photographs and Video recordings: Photographs and video recordings of events taking place in the course of the Academy (unless you have opted out of this)
  • Financial and Payment Data, including your bank account and other data necessary for processing payments and fraud prevention, including other related billing information;
  • Business Information, including information provided in the course of the contractual or client relationship between you or your organisation and PBA, or otherwise voluntarily provided by you or your organisation;
  • Employment Status and Employment related information, we collect information about your employment status as part of our monitoring,  and improvement efforts for the Academy and employment history validation. This data helps us analyse the effectiveness of the coursework and identify areas for improvement. The purpose is to ensure the continuous quality and relevance of our educational program.
  • Sensitive Information: For Academy applicants, students, faculty, guests and visitors, if disclosed by you and when relevant, any special needs, health condition, or information relating to accommodations that you may request during the selection process or while at the Academy, equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.The data obtained is treated with strict confidentiality and following rigorous processes. It will be immediately deleted or completely anonymised (where possible and following data protection laws standards) after it is no longer needed.
  • Information you provide to us, this is information about you that you give us by filling our forms, filling in forms on the sites of third party vendors providing us with a service, or by speaking with us in person, corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address, registration information (such as username and password when you create an account on one of our sites or those of the third parties vendors we work with), phone number, job title, organisation, dietary and / or accessibility requirements or your public blockchain address. We will tell you whether the information we are requesting is essential or whether the supply of this information is optional.
  • Our Site is currently hosted under polkadot.network domain. To understand what further information is collected from you as website visitor, please refer to polkadot.network’s privacy policy: https://polkadot.network/privacy/ 
  • Information we receive from other sources.
    • This is information we receive about you if you use any of the other websites we operate or the other services we provide or, to the extent permitted by law, publicly accessible information about you on e.g. business social media.
    • As part of our commitment to maintaining a high standard of academic excellence, ensure security and when necessary to comply with applicable law, we may conduct references and background checks. The data obtained is treated with strict confidentiality and following rigorous processes. We will always inform you if and when background checks will be performed and whether they are optional.
    • We may receive referrals from academic partners, vendors, and event partners to enrich our understanding of individuals participating and applying to the Academy. This information is valuable for fostering collaborative relationships and ensuring the effectiveness of our educational initiatives. We handle this data responsibly, adhering to our privacy policy.
    • We may also receive information about you from the Web 3.0 Technologies Foundation and Parity Technologies Limited as part of our cooperation. The Web 3.0 Foundation and Parity Technologies Limited may share information about you with us for the purposes of organising joint events, meetups, conferences, workshops or hackathons; assisting and/or following-up with you and coordinating that assistance; addressing and/or following-up with you where you have shown interest in Polkadot and/or Substrate; and building and maintaining the Polkadot network and its community of users. To the extent that you would like further information on the data we receive about you from the Web 3 Foundation and/or Parity Technologies Limited and the protections we have put in place to ensure it is processed and transferred securely, please contact us at legal@polkadot.academy
    • In addition, we are working closely with third parties (including, for example, event organisation service providers, event partners, and appointment scheduling services) from whom we will receive information about you. The purposes for which we use this information are listed below. To the extent that you would like further information on any of the parties from whom we receive data about you, and the protections we have put in place to ensure it is processed securely please contact us at legal@polkadot.academy

How do we use this information, and what is our legal basis? 

We have to have a legal basis to process your data. We explain each of these legal bases below. We also set out the purposes for which we process your data. 

We use the information we collect from and about you:

  • As necessary to conduct our business and pursue our legitimate interests, in particular:
    • to notify you about changes to our services or the Academy;
    • for internal operations, including troubleshooting and statistical purposes;
    • to ensure that content from our Site, blogs and social media is relevant, accurate and presented in the most effective manner;
    • to allow you to participate in interactive features of our services, when you choose to do so;
    • to use information you provide to investigate any complaints received from you or from others, about our Site, or services or the Academy;
    • to address any interest you or your team show in the Academy, PBA any collaboration with us;
    • to administer and manage our relationship with you, including accounting, and taking other steps linked to the performance of our business relationship including suppliers or service providers;
    • to address any requests, issues or questions you inform us about when you contact us via email, phone or otherwise;
    • to follow-up with you where you have shown interest in Polkadot, Substrate, the Academy or any other of our services;
    • to analyse and improve the Academy and communications;
    • to protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities;
    • for insurance purposes;
    • to collect information about your preferences to personalise and improve the quality of our communications with you;
    • to prepare, coordinate, manage and deliver Academy cohorts, including scheduling, travelling, lectures, talks and other Academy related events; 
    • to schedule, arrange and administer events, meetups and hackathons in which you have expressed an interest (including creating an attendance record for the event and sending anonymised data to the venue including attendees, dietary requirements and accessibility requirements);
    • to allow our services to check for updates and resources necessary for their continued operation;
    • to exercise or defend our legal rights or to comply with court orders and to use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
    • Information we receive from other sources: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
  • As necessary for our (or others’) legitimate interests in the course of the application process including our interests in:
    • assessing your suitability for the Academy opportunity
    • facilitating the selection process
    • verifying the information you or others provide about your application and
    • managing and improving our application and interview process and performing management reporting and analysis related to selection metrics and success factors; 
    • As necessary to comply with our legal obligations, in areas such as tax, health and safety, and equality and anti-discrimination law.
    • If accepted into the Academy, as necessary for our (or others’) legitimate interests in the provision of the Academy, including our interests in:
    • Managing and improving our provision of the Academy and performing management reporting and analysis related to outcomes and grade metrics.
    • Creating marketing and publicity materials for the Academy.
    • Taking measures to ensure the integrity of the Academy assessments, including checking for plagiarism.
    • Inviting, at our discretion, high achieving participants to further interviews for potential recruitment into PBA’s team.
    • Protecting our business interests and legal rights, including in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements.
    • Enrolling you in the Academy’s Alumni Community
  • To prepare for and deliver the Academy, including the teaching and assessment in the course of the Academy and the provision of any other services such as accommodation which may be specified in your admission letter.
  •  
  • Consistent with specific consents you may provide (if applicable), and which you may revoke at any time. For example, with your consent, we use your data to contact you about future career opportunities at PBA or when you subscribe to our newsletters. This includes storing your data and keeping it up to date and using it to contact you.

Where you give us consent:

  • we or our carefully selected partners will send you direct marketing in relation to our relevant services or other services provided by us, our affiliates and carefully selected partners. However, we will only provide you with marketing related information after you have, where legally required to do so, opted in to receive those communications and having provided the opportunity for you to opt out at any time.
  • on other occasions where we ask you for consent (we will use the data for the purpose(s) which we explain at the time of collection).

Wherever we rely on your consent, you will be able to withdraw that consent at any time, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is no other legal ground for the processing.

You have the right to withdraw your consent for direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in our communications where this is an electronic message, or by contacting us at legal@polkadot.academy.

  • For purposes which are required by law 
    • In response to requests by government or law enforcement authorities conducting an investigation.
    • Processing for purposes required by law, including maintaining records, compliance checks or screening and recording (e.g. anti-money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions etc.).

Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

Who will we share your data with, where and when?

We will share your personal information with selected third parties including but not limited to:

  • Within PBA, including staff members, subcontractors and faculty and partner universities – we may share your information among the different PBA stakeholders involved in the selection process, and in the teaching, assessment and organisation of the Academy.
  • With our Ecosystem partners - as part of our overall collaboration and joint efforts within the space. For example, with your consent we will share your information to form part of the job board for possible career opportunities. We may also share aggregated and anonymised metadata with our ecosystem for example for reporting our success metrics[purpose]
  • With service providers – these are entities that help us manage and improve the Academy and who perform services on our behalf, such as interview and assessment providers, travel booking and expense providers, relocation entities, immigration advisors, reporting and analytics services, security services. We also share participant information with event organisers and partner universities so that they can provide services such as accommodation, meals, and access to teaching facilities to those attending the Academy. These entities are required to protect the information we share with them with appropriate organisational and technical safeguards and to use such information as necessary to provide services to us.
  • Other business partners and sub-contractors - for the performance of any contract we enter into with them or you, such as legal, financial, tax and accounting services providers and IT service providers, including but not limited to hosting and/or maintenance providers;
  • our newsletter service provider - for the purposes of providing you with our newsletter;
  • In particular with Parity Technologies Limited and Web 3 Technologies Foundation - as part of our cooperation and for the purposes of organising joint events, meetups, conferences, workshops or hackathons; assisting and/or following-up with you and coordinating that assistance; addressing and/or following-up with you where you have shown interest in Polkadot and/or Substrate; and building and maintaining the Polkadot network and its community of users. 

To the extent that you would like further information of any of the parties with whom we share your data, and the protections we have put in place to ensure it is processed securely please contact us at legal@polkadot.academy

We will also disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets in compliance with applicable law.
  • If PBA or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of PBA, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Note on jboards.io

PBA hosts a Job Board on jboard.io for the purposes of connecting PBA Alumni with career opportunities within the Polkadot ecosystem (the “Job Board”).

PBA alumni will be invited to set up a profile on the Job Board. This may require you to create a profile and disclose personal data including but not limited to: identity data (name, profile picture, location), contact details (email, phone number), employment related data (title, resume, skills), social media handles (like LinkedIn), as well as any other data you may choose to disclose. If you choose to apply for an open role at one of our ecosystem partners on our Job Board, your data will be shared with them. If you choose the “available for work” option, ecosystem partners in PBA’s Job Board may be able to see your profile and contact you. Further, please note that our ecosystem partners have their own privacy policies and that we do not accept any responsibility or liability for them. Please check these policies before you submit any personal data or decide to make your profile available to them.

Your data may also be shared with our processor, jboards.io, for the purposes of providing the Job Board service to you. Please be sure to check their privacy policy.

PBA reserves the rights to screen, admit and remove both PBA Alumni and ecosystem partners from its Job Board. If you have any questions about this, you can contact us at legal@polkadot.academy

Note regarding Blockchain use

The Polkadot, Kusama and Substrate based blockchain clients written in the programming language Rust do not collect information from you. However, any information you publish onto a (public) blockchain like Ethereum, Kusama or Polkadot is public by design. Your use of a client and other interactions with a blockchain like Ethereum, Polkadot or Kusama will lead you to interact with other network participants on those blockchains. You should note that where you do so those with whom you interact as well as other participants on those networks may be able to determine certain things about you through your use of those networks.

International Transfers

The data that we collect from you may be transferred and stored by us or our service provider(s) outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who works for us or for one of our suppliers.

Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by data protection agreements, EU Commission approved standard contractual clauses or a vendor's Processor Binding Corporate Rules. 

Our Sites may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Data retention

General

We'll retain information we collect from you for as long as required to comply with our legal obligations, to resolve disputes and to enforce our contractual agreements. Laws may require us to hold certain information of yours for specific retention periods. In other cases, we may retain data for an appropriate period after any relationship with you ends to protect itself from legal claims, or to administer its business.

Notwithstanding the foregoing, the following is especially applicable to:

  • Newsletter subscribers or where you provided your consent:

We will retain your personal data until you ask us to stop. Where consent is provided, you have the right to withdraw your consent at any time. We may keep a record of the fact that you have asked us not to process your data indefinitely so that we can respect your request in future. Further, if you wish to unsubscribe from our mailing lists you can manage your subscription preferences and unsubscribe by following the instructions provided in our emails or by contacting us at legal@polkadot.academy

  • Academy applicants and Academy Students:

If you're successful in your application, we retain the information you provide during the application process as part of your records, alongside information collected during your time at the Academy. After completion of the Academy, we will retain personal data for archival, record-keeping and legal purposes.

Academy participant’s personal data will generally be kept for 6 years after the Academy, unless there are relevant legal proceedings for which the data is reasonably required. After this period, we will take steps to delete your personal data or hold it in a form that no longer identifies you.

For unsuccessful Academy applicants we will retain your personal data with your permission for 1 year so we can keep you in mind for future opportunities. Otherwise, it will be deleted after 6 months.

How will you protect my data?

We strive to maintain the highest standards of security and PBA has put in place robust technical and organisational measures for the protection of your data in accordance with the current, general state of the art technologies, especially to protect the data against loss, falsification or access by unauthorised third persons. However the transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted. Any transmission is at your own risk. Once we have received your personal data we will use strict procedures and security features to prevent unauthorised access.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites or content, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Your Rights

How can you exercise your rights? 

You have the right, subject to applicable exceptions and adequate verification of your identity, to access, rectify, port (where technically feasible), and delete your data. You also have the right to object to and restrict certain processing of your data. If you have unresolved concerns, you have the right to complain to a data protection authority. If you would like to exercise such a right, please contact us at the details below. 

Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to PBA processing your data, this will not affect any processing which has already taken place at that time.

Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to fulfil our contractual obligations with you, such as managing the selection process or your participation in the Academy, without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to participate in certain programs or systems, where the information is needed for those purposes. For example, we may not be able to provide suitable meals if you do not inform us of your dietary requirements.

Cookies

PBA’s Site is hosted on a third-party platform, and as a result, certain cookies and technologies may be employed by this third party to enhance your browsing experience, analyse website traffic, and provide additional functionalities. These cookies may collect information about your interactions with our Site. Please be aware that the use of these cookies is subject to the third party's privacy policy. We recommend reviewing their privacy policy to understand how they handle your data and use cookies. By continuing to use our Site, you consent to the use of cookies as described at https://polkadot.network/privacy/. 

Data controller details

Polkadot Blockchain Academy is an Exempted Limited Guarantee Foundation Company incorporated in the Cayman Islands under number 404321 with registered address at ℅ Chartered Financial Partners Limited, Governors Square Suite #5-204, 23 Lime Tree Bay Avenue, Grand Cayman, Cayman Islands, KY1-1108 

How to contact us

Please contact us at legal@polkadot.academy if you have any questions about this policy or the information we hold about you.

Changes to our privacy policy

This privacy policy may be updated periodically. Any changes will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

This privacy policy was last updated 26th June 2024