Privacy policy chunkx

Chunkx B.V., JF//digital GmbH and all its affiliated companies (Chunkx, we, us or our) take careful handling of your (User or you) personal data very seriously. As the responsible party for the processing of your personal data, we ensure that your personal data is handled and protected with the utmost care. Chunkx adheres at all times to the applicable laws and regulations.

Please read this privacy policy (Privacy Policy) before you use the services of Chunkx (Services) of which are part: the websites and all its subdomains (Websites) and the mobile applications of Chunkx (being: chunkx and chunkx creator) (the Apps) (the Websites and Apps together referred to as the Platform). By using the Services (which includes the downloading and installation of the App) whether or not through your employer or another legal entity (Contractor) you agree to the contents of this Privacy Policy.

Through this Privacy Policy, you are provided an insight into the data we collect, why we collect this data and what we do with this data.

1. Scope of the Platform and Third Party Creators

On the Platform, Chunkx also entitles third parties (such as academies, enterprises and employees) (Third Party Creators) to ask for, process and store data.

This Privacy Policy aims to provide a complete overview of the personal data that (may) be processed on the Platform. However, in some cases a specific channel may be managed by a Third Party Creator, such Third Party Creator is at all times responsible for the scope and type of data that (may) be processed on the respective channel, in accordance with its own privacy policy, therefore, in such cases, Chunkx will always link to the applicable privacy policy. For specific questions about the processing of data that you are required to store in a specific channel owned by a Third Party Creator, we advise you to contact the Third Party Creators.

In cases where a Third Party Creator is the responsible party for the data collected on the Platform, Chunkx is to be considered as the data processor, as defined in the GDPR. We will always inform you if this is the case.

2. The data Chunkx processes, on which ground(s) and for which purpose(s)

In relation to the execution of the Services, Chunkx processes personal data on the grounds and for the purposes as set out below.

A. Grounds

We process personal data based on the following grounds which are included in the European privacy laws.

  1. permission;
  2. performance of an agreement with User;
  3. legal duty; and
  4. legitimate interest of Chunkx or a third party.

Legitimate interests include: advertising, marketing, security, auditing, fraud detection, (crime) prevention, (market) research and analysis and improvement of our services, internal management, legal affairs and business management. We indicated below the specific ground(s) that apply to a specific processing of personal data.

B. The personal data we process and the purpose for which we process the data:

Creating an user account: in order to create an user account, you must provide us with the following information: (i) contact information (first name, last name, e-mail address,); (ii) password; and optional (iii) nickname; (iv) job title; (v) personal educational interests; and (vi) profile picture. Depending on the processing, ground 2. or 4. applies.

Change your user account into a creator-account (chunkx academy): In order to change your user account into a creator account (academy level), you must also provide us with (i) your academy details; and (ii) the payment details being the payment method and financial data, such as credit card and/or bank account information. Depending on the processing, ground 2. or 4. applies.

Change your user account into a creator-account (chunkx for business): In order to change your user account into a creator account (enterprise level), you must also provide us with (i) your company details; and (ii) the payment method and financial data, such as credit card and/or bank account information of your company. Depending on the processing, ground 2. or 4. applies.

Creating certificates: to provide you with certificates, we (or the Third-Party Creator if applicable) process(es) your first name, last name, email address and if applicable your nickname, ground 2. applies.

Information messages: Chunkx may use your contact information to send information messages (not marketing communications) necessary to provide the Services. Ground 2. applies.

Testing and analysis: we use personal data to analyze how registered Users use the Platform. This also includes the use of the data to detect and correct errors and malfunctions. Ground 4. applies.

Data aggregation: to minimize the processing of your personal data, Chunkx can merge or encrypt your personal data to create anonymous data that cannot be traced back to a natural person. Ground 4. applies.

Content Development: Chunkx creates learning content on behalf of its clients. We process this learning content with language models to create content semi-automatically and to keyword the content. In rare cases, the content to be processed may contain personal data. In this case, ground 2 applies.

Compliance with (local) legislation: Chunkx may be required to comply with the applicable local legislation to process your personal data for purposes other than those set out in this Privacy Policy, for example for law enforcement and in case of a court order. Ground 3. applies.

Fraud detection: Chunkx processes personal data for fraud detection and to prevent fraud and abuse. If we detect or have a reasonable suspicion of any fraud, scam or criminal activity imputable to you, your personal data will be processed to prevent you from being able to use our Services in the future. Depending on the processing, ground 3. or 4. applies.

Support: Chunkx may collect and share your personal information to provide support. For example, Chunkx may collect requests received by its support department (e.g. through the issuance of contact forms) and the replies in relation thereto, along with other contact information and other data of Users/persons which fill in contact forms. Through this way Chunkx can respond better to user questions. Depending on the processing, ground 1. or 4. applies.

Information included in Curriculum Vitae’s: in case you are interested in applying for a job at Chunkx, you are able to submit your Curriculum Vitae to us. Moreover, additional information can be sent, such as reference letters. In other words, by applying for a job your personal data such as name, address, age or date of birth, gender, e-mail address, telephone number will be utilized for the registration, consideration and processing of your application. If Chunkx does not hire you, your information will be deleted within 4 (four) weeks after your application unless otherwise agreed between you and Chunkx in writing. Depending on the processing, ground 1. or 4. applies.

IP-address and your use of the Websites: Upon each visit to the Websites your (fixed our temporary) IP address, the referrer website, browser type, browser version, operating system, time of access and device type are detected. We process these data for technical and functional management in order to ensure our Websites are easy to use. Ground 4. applies.

Marketing: insofar as you subscribed to our marketing communications and give us consent to send you such communications, Chunkx may use your contact information (as described above) for marketing communications, such as newsletters. You can unsubscribe at any time. The newsletter may also contain information and offers from third parties. Each newsletter contains a link that allows you to unsubscribe from our newsletter. The subscriber file of the newsletter will not be provided to third parties, unless you have given explicit permission to do so. Depending on the processing, ground 1. or 4. applies.

3. Retention period of personal data

We retain personal data no longer than is permitted under applicable law or when we believe that it is necessary and permissible to keep your personal data longer. In any case, the information required to create a user account (as described above) will be retained for as long as you use the Services or if you continue to show interest in the Services. After the cancellation or removal of your user account, your personal data will be deleted within six months. If you have any questions about the retention period of your personal data, please contact us by using the contact details listed below.

Please note that Chunkx can keep collected data at any time in an aggregated and anonymous form for (market) research, analysis and / or fraud protection. In this case ground 4. applies.

4. Providing personal data to Contractor or other third parties

In the situations listed below, Chunkx is allowed to share your personal information with third parties.

Employer: If you take of the Services through your employer, Chunkx may, under the agreement between Chunkx and your employer, share certain relevant information about your use of the Services (for example, about your progress). Depending on the processing, ground 1. or 4. applies.

Third Party Creators: If you use a third party creator’s offerings in Chunkx (a Channel or Academy), Chunkx may share certain relevant information about your use of the services (e.g., your progress) as part of the agreement between Chunkx and the third party creator. Depending on the processing, ground 1. or 4. applies.

Competent authorities: Chunkx discloses personal data to authorities in charge of law enforcement and other government agencies, to the extent required by law or strictly necessary for the prevention, detection or prosecution of criminal offenses and fraud. Ground 4. applies.

Assignment: Chunkx may transfer your personal data to third parties in the event of a merger, acquisition, reorganization, sale of business units or bankruptcy of Chunkx. Chunkx will request your permission in advance if this is required under applicable law. Ground 4. applies.

Service providers: Chunkx may share your personal information for the purposes set out in this Privacy Policy with service providers if this is necessary to provide the Services on our behalf, such as hosting, data analysis and storage, payment processing, information technology and related infrastructure, customer service, product design, product diagnostics, Vehicle maintenance or related services, e-mail services, credit card processing, auditing, and marketing. We only share your personal information with service providers who provide sufficient safeguards for the protection of your personal data. Depending on the processing, grounds 2. or 4. applies.

If the organizations as described above are classified as a processor under the European privacy laws, we will conclude a data processor agreement with them. The processing of your personal data will only take place on our instruction and under our responsibility.

5. Transfer of your personal data

Our services are mainly managed and operated from Germany and the Netherlands. If, however, personal data is provided to a third party, this will only be done to a third party in a country which, according to the European Commission, provides a level of protection that is appropriate for personal data. If this level of protection is not adequate, Chunkx shall ensure that the legally required safeguards are made, such as the conclusion of an EU model contract.

Your personal data will be transferred in the context of the services provided by:

(i) Amazon Web Services EMEA SARL (AWS) in the field of hosting software. AWS is located in Luxembourg, at 38 Avenue John F. Kennedy, L-1855. AWS adheres to the Standard Contractual Clauses as set by the European Commission. We have signed a data processing agreement with AWS. The data is stored exclusively in data centers in the eu-central-1 region (Frankfurt/Main), which are certified according to ISO 27001, 27017 and 2018 as well as PCI DSS Level 1.

(ii) Stripe Payments Europe LTD (Stripe), being our payment service provider. Stripe only receives data about you from us if you are a paying customer and use one of our payment plans. Stripe is located at Dublin, Ireland at Block 4, Harcourt Center, Harcourt Road. Stripe adheres to the Standard Contractual Clauses as set by the European Commission. e have signed a data processing agreement with Stripe;

(iii) Mailjet SAS (Mailjet), being our e-mail services provider. Mailjet is based in Paris, France, at 4 rue Jules Lefebvre, 75009. The data of European customers like us is stored in Germany and Belgium on the Google Cloud Platform (70 Sir John Rogerson’s Quay, Dublin 2, Ireland). We have signed a data processing agreement with Mailjet;

(iv) Google Firebase services (Google Firebase) provided by Google LLC. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA.) We have signed a data processing agreement with Google LLC. We use the service Firebase Cloud Messaging for sending push notifications to mobile devices and only to users of Chunkx who have enabled push notifications. Also, we are using the service Firebase Crashlytics. In the event of a technical error or crash of the installed Chunkx app, we collect data of the device to further analyze the crash and fix it (e.g., which function of the app was used, the version of the operating system, the type of device the user was using at the time the error occurred). The data collected in this context helps us to improve the app and minimize future failures and malfunctions of Chunkx.

(v) Microsoft Corporation (One Microsoft Way, Redmond, WA 98052, USA). We use Microsoft’s Azure OpenAI Services to process content provided to us by customers to develop micro-learning units. This content may also contain personal data in rare cases. In addition, content created in the authoring tool chunkx creator by Chunkx or by customers is processed using Azure OpenAI Services to automatically generate keywords. Here, we use the West Europe (Netherlands) and France regions. Our customers’ content is not used to train language models (more on how Microsoft does and does not use data can be found here).
Additionally, we use Microsoft’s Office365 services for our email communications and appointment management.

If you would like to receive further information about the transfer of your personal data, please contact our privacy officer by using the contact details below. By using our Services, or otherwise providing information to us, you agree to the transfer of your personal data to countries outside Germany and the Netherlands.

6. Use of cookies

Chunkx uses cookies on the Websites. By confirming the selection on the cookie notification of our Website or continuing to use the Websites, you consent to the placing of cookies. A cookie is a simple small file that a website stores on your hard disk via the browser. Information is stored in a cookie. Different types of cookies can be used per visit. Below, you find more information about the cookies used by and via the Website and for what purposes.
Please find our Cookie Policy here:

7. What type of cookies are used on the Website and for what purpose

The Website makes use of the different types of cookies listed below and for the purposes listed below:

Analytical cookies: these cookies are anonymous and allow Chunkx to improve the Website. These cookies collect information about the way visitors use the Website, such as information about the most frequently visited pages or the number of displayed error messages. The information collected by these cookies may not be used for marketing purposes and will not be passed on to third parties.

Session cookies: session cookies are used during your visit and are automatically deleted when you close the browser. Through these cookies we can remember which parts of our Website you viewed during a visit and we coordinate our Services accordingly.

Social media cookies: these are cookies to share the content of our Website via social media. For the functioning of these buttons social media cookies are used from the social media parties, so that they recognize you when you want to share a page of the Website. For the cookies that the social media parties place and the possible data they collect, we refer to the statements that these parties provide on their own websites.

Tracking cookies: with your consent, Chunkx or a third party uses tracking cookies to track your visit to the Website and possibly other websites in order to build a profile of you. These cookies may be used to show ads tailored to your preferences.

Other/unforeseen cookies: due to the way internet and websites work, Chunkx may not always have insight into the cookies that third parties place via our Website. This is especially the case when our web pages contain so-called ’embedded elements’ (these are texts, documents, images or films that are stored with another party, but which are displayed on, in or via our Website).

8. Specific overview of the cookies used

Via the link below you will find an overview of the cookies used on the Website.

9. Customize cookie settings or delete cookies

If you don´t want Chunkx to place cookies on your (mobile) device, you can refuse the use of cookies through the settings or options of your browser. For each browser and each (mobile) device, you have to adjust your settings separately.
Note: it is possible that after modification of the cookie settings, some parts of the Website can no longer be (correctly) used. When Chunkx has placed cookies, you can also delete them. How to do this, differs per browser. If necessary, consult the help function of your browser. More information about cookies can be found on the following website

We ask you kindly to notify us in case you find a cookie used on the Website that is not mentioned above.

10. Security

We try to do everything we can to protect your personal data. Chunkx uses technical and organizational security measures to protect the personal data managed by Chunkx against manipulation, loss, destruction and unauthorized access. These safety measures are constantly being improved in line with technological developments. For example, all entry fields on the Platform are SSL and/or TLS protected, the access to the databases of Chunkx is limited and passwords are stored encrypted. Furthermore, the Platform is continuously updated with the latest security updates.

The Platform may contain links to external websites that are managed by other companies. It is possible that they collect personal information from people who visit their website. Chunkx cannot offer any guarantees regarding the privacy policy of external websites and is not responsible for those websites.

11. Your rights

You have the right of inspection, correction or deletion of your personal data at any time. For any of these actions please contact us via the contact details as described below. In addition, Users can itself view, delete or correct certain personal data via the Platform. However, in case, despite our efforts to ensure the correctness of personal data, incorrect information is stored, we will correct such data on your request. Finally, we would like to point out that, on the basis of the European privacy laws, you have the following rights:

  • to get an explanation of what personal data of you we have and what we do with it;
  • access to the exact personal data of you that we have;
  • correcting erroneous data;
  • the removal of obsolete personal data;
  • withdrawal of consent; and
  • object to a particular use of your personal data.

However, in case, despite our efforts to ensure the correctness of personal data, incorrect information is stored, we will correct such data on your request.

12. Complaints

Please feel free to contact us in case of complaints about our processing of your personal data. In case of a complaint, we ask you to contact us via the contact details as described below. Notwithstanding the foregoing, under the European privacy legislation you also have the right to file a complaint directly with the authorities about the way we process personal data. You can find a list of supervisory authorities and their contact details here (Germany and EU, BfDI) and here (Netherlands, Autoritieit Persoonsgegevens).

13. Revision Clause

Chunkx reserves the right to change this Privacy Policy. However, we do not limit your rights under this Privacy Policy without your express consent. You can find the most up-to-date version of this Privacy Policy at any time on the Platform. We recommend that before making a revision you check whether an updated version is available.

14. Translation

This Privacy Policy is drawn up in German and English. In case of any contradictions between these versions, the English version prevails.

15. Contact details

In case of any questions about this Privacy Policy or our processing of your personal data, you can contact us by regular mail via the contact details as described below.

JF//digital GmbH
Flinger Broich 18
40235 Düsseldorf
Chamber of Commerce: HRB 83246
Email address:

Chunkx B.V.
High Tech Campus 6 Unit A
The Netherlands
Chamber of Commerce number: 84701358
Email address:

16. Version

This privacy policy was last edited on August 22, 2023.