Code of Ethics and Business Conduct
mYngle B.V.
Chamber of Commerce Number: 34278896
Willem de Zwijgerlaan 352 (3D), 1055RD Amsterdam, The Netherlands
Chamber of Commerce Number: 34278896
Willem de Zwijgerlaan 352 (3D), 1055RD Amsterdam, The Netherlands
This Code of Ethics and Business Conduct explains the standards expected from people who work for, represent or provide services to mYngle B.V. It supports the trust placed in us by learners, corporate clients, teachers, employees, contractors and business partners.
Scope
This Code applies to mYngle directors, employees, teachers, coaches, contractors, freelancers, consultants, agents and other persons acting on behalf of mYngle. We also expect suppliers and business partners to follow equivalent standards when working with us.
The Code supplements applicable laws, contracts, platform terms, client requirements, privacy notices, data processing agreements, information-security requirements and role-specific procedures. Where another applicable rule is stricter, the stricter rule must be followed.
This Code does not change the legal status of any employee, teacher, contractor or other service provider.
Our principles
- Integrity: We act honestly, lawfully and fairly.
- Respect: We treat people with dignity and support an inclusive learning and working environment.
- Professional quality: We acceptwork we are qualified to perform and deliver it with care.
- Confidentiality: We protectpersonal data, business information and the private nature of learningconversations.
- Accountability: We take responsibility for our decisions, correct mistakes and raise concerns.
Lawful and honest business conduct
- Comply with the laws, regulations and contractual requirements that apply to your work.
- Do not engage in fraud, deception, theft, falsification of records, money laundering or other unlawful conduct.
- Describe mYngle services,qualifications, prices, capabilities and expected outcomes accurately.
- Do not make commitments, offerdiscounts, sign agreements or represent that you can bind mYngle unless youhave written authority.
- Keep learner, attendance,progress, sales, expense, invoice and other business records accurate andcomplete.
- Cooperate honestly with clientreviews, audits, investigations and lawful requests from authorities.
- Follow applicable sanctions,export-control and anti-money-laundering requirements.
Anti-bribery, gifts and conflicts of interest
- Do not offer, promise, request or accept bribes, kickbacks, facilitation payments or any improper advantage.
- Do not use another person or organisation to do something that would be prohibited if done directly.
- Gifts and hospitality must belawful, modest, infrequent and must never be intended to influence a decision.
- Cash and cash equivalents mustnot be offered or accepted.
- Disclose any actual, potentialor perceived conflict of interest promptly.
- Business decisions must bebased on legitimate factors such as quality, capability, service, need andprice.
Respect, inclusion and professional boundaries
- Treat learners, clientcontacts, colleagues, teachers, contractors and partners with dignity andrespect.
- Do not discriminate on anyground protected by applicable law.
- Harassment, bullying, sexualharassment, hate speech, threats, intimidation, exploitation and retaliationare prohibited.
- Respect differences in culture,nationality, religion, belief, opinion and communication style.
- Do not exploit a position oftrust or pursue inappropriate personal, romantic, sexual, financial orcommercial relationships with learners or client contacts.
- Do not work while impaired in away that makes safe and professional performance impossible.
- Where a learner is under 18 orotherwise vulnerable, follow all applicable safeguarding requirements and useauthorised communication channels.
- Raise concerns promptly whenconduct may place a learner or another person at risk.
Professional standards for learning services
- Accept only assignments forwhich you have the appropriate qualifications, language competence, experienceand capacity.
- Present your identity,qualifications and experience truthfully.
- Prepare appropriately, bepunctual and make reasonable efforts to deliver confirmed lessons and servicesas agreed.
- Notify the learner and mYnglepromptly when illness, emergency or technical failure prevents delivery, andsupport rescheduling or handover.
- Use professional judgementwhile respecting agreed course objectives, learner needs, quality standards andauthorised client requirements.
- Use inclusive, accurate andappropriate learning materials.
- Assess learners fairly andconsistently against communicated criteria.
- Do not manipulate results orallow personal bias to affect an assessment.
- Do not guarantee learning,assessment or business outcomes that cannot reasonably be guaranteed.
- Complete agreed feedback,progress records, course plans and achievement reports accurately and on time.
- Do not contact corporate clientrepresentatives about programme arrangements unless authorised by mYngle.
- Do not solicit learners orprovide competing services outside authorised mYngle channels in breach ofcontractual or platform rules.
mYngle does not use lesson content, temporary transcripts, Pedagogical Notes or lesson summaries to train or fine-tune AI or machine-learning models operated by mYngle. Where provider settings allow mYngle to choose whether these data may be shared for model-training purposes, mYngle does not enable optional sharing for that purpose. mYngle uses available provider settings and contractual safeguards intended to prevent these data from being used to train, fine-tune or improve general-purpose AI models. This does not prevent limited processing necessary to provide, secure, monitor or troubleshoot the relevant service in accordance with this Privacy Policy.
Who do we share your data with ?
We may share your personal data withtrusted third parties where necessary to provide our services, operate ourbusiness, comply with legal obligations, or protect our legitimate interests. These recipients may include:
- Service providers who help us operate our website, platform, customer support, hosting and IT systems
- Payment providers and fraud prevention providers
- Email delivery and communication providers
- Video conferencing providers, such as Zoom, Webex or Microsoft Teams, where applicable
- Transcription and AI-supported note-generation providers used for lesson delivery, transcription, hosting, AI-supported processing and delivery of Pedagogical Notes, where applicable
- Learners and teachers, where notes, lesson summaries or lesson-support materials are intended to be shared with them
- Providers that support the creation and delivery of class notes or pedagogical lesson summaries, where applicable
- Professional advisers, regulators, public authorities, or law enforcement bodies wherer equired by law or where necessary to protect our legal rights
- We do not sell or rent your personal data to third parties for their own marketing purposes. Where service providers process personal data on our behalf, we require them to process the data only in accordance with our instructions and applicable data protection law.
International transfers
Where personal data is transferred outside the European Economic Area, mYngle will ensure that appropriate safeguards are in place in accordance with applicable data protection law. These safeguards may include an adequacy decision, the EU-US Data Privacy Framework where applicable, Standard Contractual Clauses approved by the European Commission, transfer impact assessments and supplementary technical, contractual or organisational measures where required.International transfers may occur where we use service providers located outside the EEA, or providers that may process or access personal data from outside the EEA, including providers of hosting, IT support, communications, video conferencing, transcription, AI-supported processing, analytics or customer-support services.You may contact us for more information about the safeguards used for relevant transfers, subject to confidentiality, security and commercial restrictions.
Marketing
mYngle may send you information about our products and services if you have explicitly agreed to receive marketing communications.
You have the right to withdraw your consentand opt out of marketing at any time.
To do so, please:
- Use the unsubscribe or manage preferencesoption in any marketing email, or
- Contact us at privacy@mYngle.com
We do not sell or rent your data to third parties for marketing purposes.
What are your data protection rights?
mYngle would like to ensure you are fully aware of your rights under the GDPR. Every user is entitled to the following:
- Right to access – Request copies of your personal data
- Right to rectification – Request correction of inaccurate or incomplete data
- Right to erasure – You have the right to request that mYngle erase your personal data, under certain conditions.
- Right to restrict processing – Request limitation of how we process your data under specific conditions
- Right to object – Object to our processing where we rely on legitimate interests or for direct marketing
- Right to data portability – Request transfer of your data to another organization or to yourself
- Right to withdraw consent – Where we rely on your consent, you may withdraw it at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal
If you make a request, we have one month to respond. To exercise any of these rights, please contact us using the details at the end of this Privacy Policy.
Data retention
We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, including legal, contractual, and reporting requirements. For example:
- Account-related data: retained while your account is active, unless a longer retention period is required by law or necessary for legitimate business purposes
- Financial data: retained for at least 7 years for tax compliance
- Temporary transcripts used for AI-supported Pedagogical Notes: temporary lesson transcripts are processed only for the purpose of generating AI-supported Pedagogical Notes and related learner-support materials. mYngle deletes temporary transcripts from its own systems as soon as reasonably possible after the Pedagogical Notes have been generated
- Platform-specific technical transcript retention: depending on the lesson platform, short technical retention periods may apply before deletion by the relevant platform or provider. The current expected technical retention periods are: Microsoft Teams: approximately 2 hours; Zoom: approximately 1 day; Webex: approximately 1 hour
- AI-supported Pedagogical Notes: retained in mYngle systems for 10 days and then deleted or anonymised, unless a longer retention period is required by law or necessary for the establishment, exercise or defence of legal claims.
- Consent, preference and audit records: where consent, preference or availability records are used for AI-supported Pedagogical Notes, mYngle retains these records for as long as necessary to demonstrate compliance, manage lesson preferences, handle related questions or disputes, and meet legal or contractual requirements.
- Copies of emailed communications and related operational records: retained only as long as necessary for customerservice, legal, contractual, and reporting purposes
What are cookies?
Cookies are text files placed on your device to collect standard internet log and visitor behavior information. When you visit our website, we may automatically collect data using cookies or similar technologies.
For more information, visit: www.allaboutcookies.org.
How do we use cookies?
mYngle uses cookies to:
- Improve website functionality
- Recognize your preferences (such as language or region)
- Analyze website traffic and user behavior
- Personalize advertisements based on your online activity, where applicable
- Non-essential cookies, including advertising, analytics or tracking cookies, are used only where required consent has been obtained. You can withdraw or change your cookie preferences at any time through our cookie settings.
What types of cookies do we use?
There are a number of different types of cookies, however, our website uses:
- Strictly necessary cookies: These cookies are required for the website or platform to function, for example to support login, security, session management and core service functionality. These cookies do not require consent.
- Functionality cookies: Allow us to recognize you and remember your preferences.
- Advertising cookies: Collect data about your visit, content viewed, links clicked, and technical details such as IP address and browser type. We may share this data with our advertising partners to serve relevant ads.
These may include both first-party and third-party cookies.
Our cookie banner or cookie settings provide more information about the cookies we use, including the provider, purpose and retention period. You can withdraw or change your cookie preferences at any time through our cookie settings.
Our cookie banner or cookie settings provide more information about the cookies we use, including the provider, purpose and retention period. You can withdraw or change your cookie preferences at any time through our cookie settings.
How to manage cookies
You can set your browser to refuse or remove cookies. Instructions are available atwww.allaboutcookies.org. However, certain website features may not function properly without cookies.
Privacy policies of other websites
The mYngle website may contain links to third-party websites. This Privacy Policy applies only to our website, platform and services. When you click a link to another website, we encourage you to review that website’s privacy policy.
Changes to our Privacy Policy
mYngle may update this Privacy Policy from time to time to reflect changes in our services, technology providers, legal requirements or operational processes. The latest version will be available on our website. Where changes materially affect how we process personal data, we will provide appropriate notice and, where required, request consent or acceptance. This Privacy Policy may be made available in multiple languages. In the event of any inconsistency or difference in interpretation between the English version and a translated version, the English version will prevail, unless applicable law requires otherwise.
How to contact us
mYngle has not appointed a Data Protection Officer. Privacy questions may be directed to:
Email: privacy@mYngle.com
Phone: +31 (0)20 8004943
Post: Willem De Zwijgerlaan 352 (3D), 1055RD Amsterdam, The Netherlands
Phone: +31 (0)20 8004943
Post: Willem De Zwijgerlaan 352 (3D), 1055RD Amsterdam, The Netherlands
How to contact the appropriate authorities
If you wish to report a complaint or believe that mYngle has not addressed your concern in a satisfactory manner, you may contact the Dutch supervisory authority:
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