Join the program

Privacy Policy

Last Updated: March 17, 2025

Welcome to the ITSkills4U platform (the “Platform”). This Privacy Policy explains how your personal data is collected, used, and protected when you use the ITSkills4U Platform, operated by CloudTeam Sp. z o.o.(“CloudTeam”, “we”, “us”, or “our”). We are committed to safeguarding your privacy and ensuring that your personal information is handled in compliance with applicable laws, including the General Data Protection Regulation (GDPR).

By using the Platform or providing your personal information, you agree to the terms of this Privacy Policy. If you do not agree with any part of this Policy, please do not use the Platform. We may update this Privacy Policy from time to time, and we will post any changes on this page with an updated revision date.

1. Data Controller and Data Processor

CloudTeam Sp. z o.o. is the primary data controller for personal data collected through the ITSkills4U Platform. This means CloudTeam determines the purposes and means of processing your personal data. Our company details are:

  • CloudTeam Sp. z o.o.
    Address: Plac Konesera 9, 03-736 Warszawa, Poland.
    (CloudTeam is registered in Poland and operates the ITSkills4U program.)

We work in collaboration with the Union of Entrepreneurs and Employers (Polish: Związek Przedsiębiorców i Pracodawców) to deliver the ITSkills4U program. The Union of Entrepreneurs and Employers acts as a data processor on our behalf, specifically helping to manage student enrollments and related administrative tasks. Their details are:

  • Union of Entrepreneurs and Employers (ZPP)
    Address: ul. Nowy Świat 33, 00-029 Warszawa, Poland.

As a data processor, the Union of Entrepreneurs and Employers processes your data only under CloudTeam’s instructions and for the purposes outlined in this Policy (e.g. handling your course registration). CloudTeam remains responsible for overseeing and protecting your personal data in these cases.

If you have any questions about who controls or processes your data, or if you need clarity on these roles, feel free to contact us using the contact information in the Contact Us section below.

2. Personal Data We Collect

We only collect personal information that is necessary for the purposes of the ITSkills4U program. The categories of personal data we may collect from you include:

  • Name (first and last name) – to identify you and personalize communications.
  • Email Address – to contact you with program information, course details, and updates.
  • Phone Number – to reach you for urgent notifications or support related to your enrollment.
  • Citizenship – to verify eligibility for the program (the ITSkills4U initiative is dedicated to certain nationals, e.g., Ukrainians in selected countries).

In addition to the above, you may voluntarily provide us with other information when communicating with us or filling out forms (for example, your current country of residence, professional background, or any specific needs regarding the training). We will also handle such information according to this Privacy Policy.

Automatic Data (Cookies and Usage Data): When you visit our website, we also collect certain data automatically through cookies and analytics tools. This may include your IP address, browser type, device information, and browsing behavior on our site. Please see the Cookies and Tracking Technologies section for more details on what is collected and how to control it.

We do not collect any sensitive personal data (such as racial or ethnic origin, political opinions, health data, etc.) unless you explicitly provide it to us. We ask that you only provide personal data that is relevant to your participation in the ITSkills4U program.

3. Purpose of Processing Personal Data

We process your personal data only for specific and legitimate purposes related to the ITSkills4U program. The main purposes for which we use your data are:

  • Course Enrollment and Administration: We use your name and contact details to register you for the ITSkills4U courses you apply for. This includes processing your application, confirming your eligibility (for example, verifying your citizenship if required for program eligibility), and communicating about course schedules, access to training materials, and other necessary enrollment information.
  • Course Attendance Tracking: During the program, we track your attendance and participation in the courses and workshops. This is done to ensure you meet any requirements for course completion, to issue certificates of completion if applicable, and to report on attendance as needed for program management or funding accountability. For example, we may keep records of which sessions you attended or whether you completed certain lab exercises.
  • Program Communications and Updates: We will use your email and/or phone number to provide you with important updates related to the program. This includes sending reminders for upcoming classes, changes in schedule, technical notices (such as how to access online labs or materials), or follow-ups after sessions for feedback.
  • Marketing of Related Program Activities: With your consent, we may also inform you about other activities and opportunities within the ITSkills4U program or closely related initiatives. This can include additional free workshops (e.g. webinars on CV writing or interview preparation), networking events, job placement opportunities, or new courses that are part of the ITSkills4U or CloudTeam offerings. These communications are intended to help you get the most out of the program and advance your IT career. You can opt-out of these communications at any time (see Your Rights below).

We will not use your personal data for any purposes that are incompatible with the ones listed above. If we need to process your data for a new purpose that is not covered by this Privacy Policy, we will inform you and, if necessary, request your consent before doing so.

4. Legal Basis for Processing

Under the GDPR, we must have a valid legal basis to process your personal data. For the ITSkills4U Platform, the primary legal basis is your consent (GDPR Article 6(1)(a)).

  • Consent: By registering for the ITSkills4U program or otherwise submitting your personal information to us, you are giving us your consent to process that information for the purposes described in this Privacy Policy. This includes consent to receive communications about the courses and related program activities. We will ask for your explicit consent (for example, by having you check an “I agree” box or similar) at the point of data collection on our website or forms.

We rely on your consent for all the processing activities described (enrollment, tracking, communications, marketing). In some cases, processing your data may also be necessary to take steps at your request prior to entering into a training service agreement – for example, when you sign up for a course, we must use your data to provide that course to you. However, since the program is offered free and is not a commercial contract with you, we still primarily treat your participation as voluntary and based on consent.

Right to Withdraw Consent: You have the right to withdraw your consent at any time. If you choose to withdraw consent, we will stop processing your personal data for the purposes you originally agreed to, unless we have another legal basis to continue (such as a legal obligation). For example, if you withdraw consent during the program, we will remove you from our mailing lists and will not further use your data, though we may need to retain certain information until the project’s conclusion for accountability (see Data Retentionbelow). Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal.

Please note that if you do not provide consent for us to process the necessary personal data, or if you withdraw your consent, we may not be able to enroll you or continue to include you in the ITSkills4U program, since such data is essential for providing the courses and related services.

5. How We Share Personal Data (Data Recipients)

We treat your personal data with care and confidentiality. We do not sell your personal information to third parties. However, in order to run the ITSkills4U program efficiently, we need to share your data with certain trusted third parties (data recipients) who assist us in providing our services. These include:

  • Union of Entrepreneurs and Employers (ZPP) – Enrollment Management: As mentioned, the Union of Entrepreneurs and Employers acts as a data processor to help manage student enrollments. This means personnel from ZPP who are involved in the ITSkills4U project will have access to your registration details (name, contact, etc.) to confirm your eligibility, communicate with you about course start dates, and handle administrative duties related to your participation. They process your data only for these program purposes and under instructions from CloudTeam.
  • Amazon Web Services (AWS) – Hosting and Infrastructure: We use Amazon Web Services to host the ITSkills4U website and related IT infrastructure. All data you provide through our website (including registration forms and any online training materials or lab environments) is stored on secure AWS servers. AWS acts as a data sub-processor, meaning they process data on our behalf by providing cloud storage and computing services. AWS does not access your data for any purpose other than to maintain the hosting and storage as needed. We have ensured that AWS, as a leading cloud provider, implements strong security measures and complies with data protection requirements. (For more on security, see Security Measures below.)
  • Email and Communication Services: To send out program emails (such as enrollment confirmations or newsletters about upcoming events), we may use an email service provider. For example, if we use a service like Gmail/Google Workspace or a mailing platform, your email address and name might be stored in that system for sending communications. Any such provider will only use the data to send emails on our behalf and not for their own purposes.
  • Google Analytics – Website Analytics: We use Google Analytics (a web analytics service provided by Google) to collect anonymized information about how visitors use our website. Google Analytics uses cookies (see Cookies and Tracking Technologies section) to gather data such as your IP address, browser type, pages visited, and time spent on the site. This information is transmitted to and stored by Google on their servers for the purpose of analyzing website traffic and improving the Platform. We have configured Google Analytics to anonymize IP addresses where possible, and we do not send any personally identifiable information (like your name or email) to Google Analytics. Google acts as a data processor for analytics data, and they are not allowed to use the data we collect for any purpose other than providing us with analytics reports.
  • Program Partners and Instructors: In some cases, we may share necessary details with program partners or instructors. For example, if a training instructor (from CloudTeam or a partner organization like GoIT) needs a list of registered students to conduct a virtual class or provide lab access, we will provide them with your name and email to facilitate that course. These partners are bound by confidentiality and data protection obligations. They will only use your information for delivering the training or related support services.
  • Legal and Compliance Recipients: We may disclose personal data if required to do so by law or in response to valid requests by public authorities (e.g., law enforcement or regulatory agency). For instance, if the European Bank for Reconstruction and Development (EBRD), as the funder of the project, requires certain data for audit or verification purposes, we may need to share relevant information. In such cases, we will ensure the data shared is limited to what is necessary and that appropriate safeguards are in place.

We ensure that any third party that receives or handles personal data on our behalf (as listed above) has agreed to protect your data in line with this Privacy Policy and applicable privacy laws. We sign data processing agreements with our service providers and partners to ensure they only use your data for the specific services they provide to us and not for other purposes.

If we ever need to share your data with any other third parties not covered above, we will inform you and obtain your consent if required.

6. International Data Transfers

CloudTeam is based in Poland, and the ITSkills4U program is offered to individuals in various European countries. We strive to store and process personal data within the European Economic Area (EEA) whenever possible. However, some of our service providers might be located outside of your country or the EEA:

  • Amazon Web Services (AWS): We primarily use AWS data centers located in the EEA (for example, in Europe) to host your data. In the event that any data is stored or backed up in servers outside the EEA, AWS is a company that participates in strong contractual privacy protections. We have a data processing agreement with AWS that includes Standard Contractual Clauses (SCCs) approved by the European Commission to safeguard any transfers of personal data outside the EEA.
  • Google (Analytics): Google may process analytics data on servers outside the EEA (for example, in the United States or other locations). Google is certified under frameworks and uses SCCs for EU data transfers as well. We have taken steps to enable data anonymization features in Google Analytics to minimize personal data. Nonetheless, if data is transferred outside Europe, it is protected by appropriate safeguards under GDPR.

Whenever we transfer your personal data internationally (outside the EU/EEA or your country of residence), we will ensure at least one of the following safeguards is implemented:

  • The country has been deemed to provide an adequate level of protection for personal data by the European Commission (an “adequacy decision”).
  • We have in place Standard Contractual Clauses or other approved transfer mechanisms with the recipient, which legally require them to provide a similar level of protection to your data as it has in Europe.
  • For US-based providers, if applicable, they adhere to frameworks that are recognized for protecting personal data (though currently the main method is SCCs after the invalidation of Privacy Shield).

You can contact us if you would like more information about international data transfer safeguards or to obtain a copy of the relevant contractual protections in place.

7. Cookies and Tracking Technologies

The ITSkills4U website uses cookies and similar tracking technologies to provide a smooth user experience and to understand how our site is used. A cookie is a small text file that is stored on your device when you visit a website. We use the following types of cookies on our Platform:

  • WordPress Cookies (Functional Cookies): Our website is built on WordPress. WordPress uses cookies to enable essential site functionality. For instance, if the Platform has a login area or multi-page forms, cookies might remember your session so you don’t have to re-enter information as you navigate the site. These cookies are typically necessary for the website to function properly, such as keeping you logged in (if accounts are used) or remembering your language preferences. They do not collect personal data for marketing, but they might capture some identifiers (like a session ID or your IP address) needed for the site to work.
  • Analytics Cookies (Google Analytics): As noted earlier, we use Google Analytics to collect information about how visitors use our site. Google Analytics cookies gather data on pages visited, time spent on pages, how you arrived at our site (e.g., via search engine or referral link), and interactions with our site content. This helps us compile statistical reports on website activity and improve the Platform’s content and layout. The information collected by these cookies (including IP addresses) is anonymized or pseudonymized; we do not attempt to identify individual visitors through analytics. Google Analytics may set cookies such as _ga, _gid, and others on your browser.

By using our site, you may have cookies placed on your device. On your first visit, you should see a notification or banner about cookies, allowing you to consent or manage your preferences if required by law. If you continue to use the site without disabling cookies, we will assume you consent to our use of cookies as described.

Managing and Disabling Cookies: You have the right to accept or reject cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You can also delete cookies that have already been set. However, please be aware that if you disable cookies, some features of our website may not function correctly. For example, you might not be able to stay logged in or some pages might not remember your preferences.

  • To manage cookies, check your browser’s help section for instructions on how to block or delete cookies.
  • To opt-out of Google Analytics specifically, Google provides a browser add-on here: Google Analytics Opt-out Browser Add-on which you can install to prevent Google Analytics from collecting your data on any website.

We do not use cookies to serve third-party advertisements, and we do not engage in any behavioral advertising tracking. Cookies on our site are used solely to support the operation of the site and to help us understand and improve the ITSkills4U program’s web presence.

For more details, you can refer to our Cookie Policy (if provided separately) or contact us with any questions about our use of cookies and tracking technologies.

8. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or to comply with legal or contractual requirements. Specifically for the ITSkills4U program, we retain personal data until the project is completed and settled with the funder (the European Bank for Reconstruction and Development – EBRD).

What this means in practice:

  • We will keep your personal information throughout the duration of your participation in the ITSkills4U courses and related activities. This allows us to manage your enrollment, track your progress, and communicate with you effectively for the entire program period.
  • After the ITSkills4U program has concluded, and once all required reporting and administrative tasks with EBRD (the funder) or other stakeholders are completed, we will no longer need your personal data for the initial purposes. At that point, we will either securely delete your personal data from our systems or anonymize it (so that it no longer can be linked back to you).
  • The typical retention period will cover the active project timeframe. For example, if the program runs during 2025 and final reports to EBRD are submitted in early 2026, we would aim to remove or anonymize personal data shortly after that finalization, unless there is a reason to keep it longer.

In some cases, we may retain certain information for a bit longer if necessary for legitimate business purposes or legal obligations, such as:

  • Legal Requirements: If laws or regulations (or auditors related to the project funding) require us to keep records of participation or finances for a certain period, we will retain the necessary data for that period as mandated (e.g., retention for audit or tax purposes).
  • Dispute Resolution: If a participant or any party raises a complaint or legal claim regarding the program, we may retain relevant data until the issue is resolved, strictly for use in addressing that claim.
  • Backups: Personal data may remain in routine backups for a short duration even after deletion from our main systems. We protect any data in backups with the same security measures until those backups are overwritten or destroyed.

After the applicable retention period ends, we will either delete your data or anonymize it. Anonymization means converting it into a form that does not identify you (for example, keeping aggregated statistics like “number of participants from each country” without names or contact details).

If you have specific questions about how long your particular data will be kept, you can contact us for more information.

9. Your Data Protection Rights

As a user of the ITSkills4U Platform and as a data subject under GDPR (if you are in the EU or in a jurisdiction with similar data protection laws), you have certain rights regarding your personal data. We are committed to upholding these rights. Below is a summary of your key data protection rights and how you can exercise them:

  • Right to Access: You have the right to request a copy of the personal data we hold about you, as well as information on how we process it. We will provide you with a copy of your data in a common electronic format (unless you request otherwise), typically within one month of your request.
  • Right to Rectification: If any of your personal information is inaccurate or incomplete, you have the right to have it corrected or updated. You can update some of your information directly through your user dashboard on our Platform (for example, if we provide an account area where you can edit your profile, you can change your phone number or email). For other corrections, you can contact us and we will rectify the errors promptly.
  • Right to Erasure (“Right to be Forgotten”): You can request that we delete your personal data. You may exercise this right, for example, if you decide to withdraw from the program or after the project is completed. Upon your request, we will erase your data without undue delay, provided that the data is no longer necessary for the purpose it was collected. Please note, we might need to retain certain minimal information if required for legal reasons or for completing project obligations (see Data Retentionabove), but we will inform you if that is the case.
  • Right to Restrict Processing: You have the right to ask us to restrict (pause) the processing of your data in certain circumstances. For instance, if you contest the accuracy of your data, you can request we restrict processing until the accuracy is verified. Or if you object to processing (see below) and we are considering that objection.
  • Right to Object: You have the right to object to our processing of your personal data when we are processing it under a legal basis of legitimate interest or for direct marketing. In the context of ITSkills4U, we primarily rely on consent, but if for any reason we were processing data under a different legal basis, you could object. For example, if you receive marketing emails from us about program activities and you no longer wish to, you can object (or simply withdraw consent) and we will stop sending them.
  • Right to Withdraw Consent: As noted in the Legal Basis section, if we are processing your data based on your consent, you can withdraw that consent at any time. This is done by contacting us or using any provided unsubscribe links in communications. Withdrawing consent will stop the processing for the purposes you had originally agreed to (for example, marketing or even participation in the program if you withdraw all consent).
  • Right to Data Portability: You have the right to request that the data you provided to us be given to you or transmitted to another organization in a structured, commonly used, machine-readable format. This typically applies to data processed by automated means under consent or contract. If you need an export of your data (for instance, the personal details you gave us) to reuse elsewhere, let us know and we will accommodate if possible.
  • Right Not to Be Subject to Automated Decision-Making: We do not use your personal data for automated decision-making or profiling that would have legal or significant effects on you (such as algorithmically deciding your eligibility without human involvement). All enrollment decisions and communications involve human oversight. If that ever changes, you have rights regarding such automated decisions, including the right to request human intervention.
  • Right to Lodge a Complaint: If you believe your data protection rights have been violated, you have the right to file a complaint with a supervisory authority. CloudTeam Sp. z o.o. is based in Poland, so our lead supervisory authority is the Polish Personal Data Protection Office (UODO) – (Urząd Ochrony Danych Osobowych). You can contact UODO or your country’s data protection authority. We encourage you, however, to reach out to us first at privacy@cloudteam.pl so we can address your concerns directly.

How to Exercise Your Rights:
We provide multiple ways for you to exercise your data rights:

  • User Dashboard: If the Platform offers a user account or dashboard, you can log in to review the personal information you provided and make corrections to basic details. For example, you might update your phone number or email if it changes.
  • Email Request: For any rights that you cannot exercise directly through the Platform (such as obtaining a full copy of your data, withdrawing consent, or requesting deletion), you can send us a request via email at privacy@cloudteam.pl. Please indicate clearly what right you wish to exercise and provide relevant details to help us fulfill your request (for example, the email address you used to register, which data you want corrected, etc.). We may need to verify your identity before acting on certain requests, to ensure we do not disclose or alter someone’s data improperly.
  • Timing: We will respond to your request as soon as possible, generally within one month as required by GDPR. If your request is complex or if we have received many requests, we may extend this period by an additional two months, but we will inform you if an extension is needed.
  • Cost: Exercising your rights is free of charge. However, if you make repetitive, unfounded, or excessive requests, we are permitted by law to either charge a reasonable fee or refuse to act on the request. We will of course inform you of any such decision.

We want you to have control over your personal data. Don’t hesitate to contact us with any questions or requests regarding your information and rights.

10. Security Measures

We take the security of your personal data seriously. CloudTeam implements a variety of technical and organizational measures to protect your information from unauthorized access, disclosure, alteration, or destruction. Here are some of the key security practices in place:

  • Encryption in Transit: When you enter personal data on our website (for example, filling out the registration form), that data is transmitted securely over the internet using encryption protocols such as HTTPS/SSL. This means that information like your name or email is encrypted before it travels across the internet, preventing eavesdropping by third parties.
  • Encryption at Rest: The databases and storage systems where we hold your personal data (for example, on AWS servers) are encrypted at rest. This provides an additional layer of protection in case of any unauthorized access to the storage. Even if physical disks or backups were accessed without permission, the data would be unreadable without the proper decryption keys.
  • Access Controls (Principle of Least Privilege): We restrict access to personal data strictly to those staff and partners who need it to perform their duties for the ITSkills4U program. For example, the program coordinator and enrollment managers will have access to participant lists, but an instructor might only receive the list of names/emails needed for their class, and not the full database. Every person or entity handling your data does so under confidentiality agreements and with unique authenticated access. We regularly review user permissions to ensure no one has access beyond what is necessary.
  • Secure Development Practices: Our Platform and website are developed and maintained following industry best practices for security. This includes keeping software (like the WordPress CMS and any plugins) up-to-date to patch vulnerabilities, performing security testing, and monitoring for intrusions or anomalies.
  • Network and System Security: AWS provides robust cloud security, including firewalls, intrusion detection systems, and monitoring. We leverage these tools to protect the servers and databases that host your data. We also use anti-malware protection and secure network configurations on our systems that interact with the cloud environment.
  • Employee Training and Policies: CloudTeam ensures that employees and team members involved in the ITSkills4U project are trained on data protection best practices. We have internal policies regarding data confidentiality, and we conduct background checks as appropriate. All staff are required to follow our security and privacy policies when handling user data.
  • Data Breach Response: Despite our best efforts, no method of transmission or storage is 100% secure. In the unlikely event of a data breach (for example, if we discover unauthorized access to personal data), we have a response plan in place. We will promptly contain and investigate the breach, and we will notify affected users and relevant authorities as required by law. We aim to be transparent and to take all necessary steps to prevent any further damage in such situations.

Our goal is to give you peace of mind that your data is in safe hands. We continually assess and improve our security measures to adapt to new threats and technologies. If you have specific questions about the security of the Platform, feel free to reach out to us.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please do not hesitate to contact us. We are here to help and address any issues related to privacy and data protection.

  • Email: You can reach our data protection team at privacy@cloudteam.pl. This is our dedicated inbox for privacy inquiries, including questions about data use, requests to exercise your rights, or complaints. We strive to respond to all inquiries in a timely manner.
  • Postal Mail: If you prefer to contact us via mail, you can write to:
    CloudTeam Sp. z o.o. (Attn: Data Protection Officer/Privacy)
    Plac Konesera 9, 03-736 Warszawa, Poland.

When contacting us about your personal data, please include your name and contact information and a clear description of your request or question. If you are making a request related to your data (e.g., access or deletion), we may need to verify your identity for security reasons before fulfilling the request.

We value your privacy and will do our best to assist you with any concerns.

12. Changes to This Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we make changes, we will:

  • Post the updated Privacy Policy on this page with a new “Last Updated” date at the top so you can see when the last changes were made.
  • If the changes are significant, we may also provide a more prominent notice, such as a banner on our website or an email notification, to inform you of the update.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the ITSkills4U Platform after any changes to this Privacy Policy constitutes your acceptance of those changes.

Thank you for taking the time to read our Privacy Policy. We hope it has clarified how your personal data is handled in the ITSkills4U program. We are committed to protecting your privacy and ensuring your personal information is used in a transparent and secure manner. If you have any further questions or need clarifications, please contact us at privacy@cloudteam.pl.