General Data Protection Regulation (GDPR)
November 23, 2025 2025-11-23 17:25General Data Protection Regulation (GDPR)
Last Updated: 17th November 2025
PORTDEMY (“we”, “our”, “us”) is committed to protecting the privacy and personal data of all learners, parents, educators, partners, affiliates, and visitors across all regions—including the European Union (EU), United Kingdom (UK), United States (US), Asia-Pacific countries, and the rest of the world.
This Global Data Protection & Privacy Policy explains how we collect, use, store, protect, and process personal data through the PORTDEMY platform, mobile browser versions, LMS integrations, AI Tutor system, interactive learning modules, and all related services.
This policy aligns with:
- GDPR (EU & UK)
- CCPA/CPRA & U.S. state privacy laws
- PDPA (Malaysia, Singapore, Thailand)
- Philippines Data Privacy Act (DPA)
- Indonesia Personal Data Protection Law (PDP Law)
- India Digital Personal Data Protection Act (DPDP Act)
- Global edtech and cybersecurity standards
By creating an account, using our platform, or accessing our content, you agree to this policy.
1. Data Controller
PORTDEMY
PORTMAN AI Sdn Bhd
E18, Mines 2 Retail Tower, PORTMAN College,
2nd Floor, Jalan Mines 2, Mines Wellness City,
43300 Seri Kembangan, Selangor
Email: data@portdemy.com
We act as the Data Controller for personal data processed on our platform.
2. Personal Data We Collect
We collect various types of data to deliver high-quality interactive learning experiences.
2.1 Identity & Contact Information
- Full name
- Email address
- Phone number
- Age, date of birth (if required for age-appropriate content)
- Parent/guardian contact (for minors)
2.2 Learning & Academic Data
- Course enrollments
- Lesson progress & activity
- Quiz scores
- AI Tutor feedback
- Homework submissions
- Gamification progress
- Learning behavior analytics
2.3 Payment & Subscription Data
- Billing details (processed by secure third-party providers)
- Transaction records
- Subscription status
2.4 Technical & Device Data
- IP address
- Browser type
- Device information
- Location (approximate)
- Cookies, usage analytics
- Platform performance data
2.5 Communication & Interaction Data
- Support chats
- Chatbot/AI Tutor interactions
- Email and WhatsApp messages
- Feedback, surveys, form submissions
3. Legal Basis for Processing
For EU/UK (GDPR) Users
We process data based on:
- Consent
- Performance of a contract
- Compliance with legal obligations
- Legitimate interest
For US Users (CCPA/CPRA & Others)
We provide:
- Notice at data collection
- Right to opt out
- Consumer access & deletion rights
- No sale of personal information
PORTDEMY does not sell personal data.
For Asia Users (PDPA, DPA, PDP Law, DPDP Act)
We follow:
- Clear consent requirements
- Purpose-specific processing
- Data minimization
- Secure retention and disposal
4. How We Use Your Data
We process data to:
- Provide access to courses and learning content
- Track progress, scores, badges, and achievements
- Deliver AI Tutor guidance and personalized learning recommendations
- Improve lesson quality and curriculum
- Offer customer support
- Authenticate user accounts
- Manage payments and subscriptions
- Enhance system performance and user experience
- Ensure platform safety, compliance, and child protection
- Conduct marketing outreach (only with consent)
5. Data Sharing with Third Parties
We may share data with:
- LMS & interactive content providers (TutorLMS, H5P, etc.)
- AI systems used for tutoring and recommendations
- Cloud hosting providers
- Customer support systems
- Payment processors (Stripe, PayPal, etc.)
- Analytics platforms (for performance optimization)
- Government authorities when legally required
All partners must comply with global data protection standards.
6. International Data Transfers
Data may be stored or processed outside your country.
We ensure protection using:
- GDPR Standard Contractual Clauses (SCCs)
- Encrypted transfer methods
- PDPA/DPDP/PDP compliance safeguards
- Secure access controls
7. Data Retention
We retain personal data only as long as needed:
- Learning records: while the user remains active
- Inactive learner accounts: typically 12–36 months
- Payment data: as required by financial regulations
- Communication logs: 12–24 months
- Deleted account data: permanently removed after processing
8. Your Rights
GDPR Rights (EU/UK)
You may request:
- Access
- Correction
- Deletion
- Restriction
- Data portability
- Objection to processing
- Withdrawal of consent
US Rights (CCPA/CPRA)
You may request:
- Categories of data collected
- Deletion of your data
- Correction
- Opt-out of sharing
- Limitation of sensitive data use
Asia Rights (PDPA, DPA, PDP Law, DPDP Act)
You may request:
- Access
- Correction
- Data deletion
- Consent withdrawal
- Purpose limitation
PORTDEMY supports all valid regional requests.
9. AI, Personalization & Automated Processing
PORTDEMY uses AI for:
- Personalized learning paths
- Lesson recommendations
- Interactive question generation
- Real-time feedback
- Smart difficulty adjustment
- Chatbot & support automation
All AI-generated decisions are reviewed and supervised by human educators.
Users or parents may request manual override and human review at any time.
10. Data Security
We secure personal data with:
- SSL/TLS encryption
- Secure cloud infrastructure
- Access control based on staff roles
- Encrypted backups
- Regular vulnerability testing
- AI system monitoring
Child protection safety mechanisms
11. Cookies & Tracking Technologies
We use cookies for:
- Platform functionality
- Analytics & performance
- Personalization
- Marketing (opt-in only for regions requiring consent)
Users may manage or disable cookies in browser settings.
12. Contact: Data Protection Officer (DPO)
For privacy matters:
Data Protection Officer
PORTDEMY
Email: data@portdemy.com
Users may also file complaints with their regional data protection authority.
13. Policy Revisions
We may update this policy due to:
- Legal changes
- Platform upgrades
- AI model updates
- Curriculum enhancements
- System improvements
All updates will be posted on the official PORTDEMY platform.
