We are committed to protecting your personal information and to being transparent about the information we hold about you. Using personal information allows us to develop a better understanding of our customers.
What personal information we collect from you
We operate a platform which provides users with access to e-learning, informational and/or instructional audio-visual content delivered well-known experts (the “Platform”). This privacy notice applies to all users of the Platform (whether they access it through our website via any app we might release from time to time, or through any other means) and the term ‘Platform’ as used in this notice applies to any and all such channels.
We respect our users’ privacy and are committed to treating any information that we obtain about you with as much care as possible and in a manner that is compliant with all applicable data protection laws. For users in the EU, that includes the EU General Data Protection Regulation 2016/679 (“GDPR”). It will also include any applicable national law, such as (in the UK) the Data Protection Act 2018 and the GDPR as transposed into national law (collectively, we’ll refer to these as “Data Protection Laws”).
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes or if you become aware that any data that we hold is not accurate during your relationship with us.
How and when we collect personal data
We collect personal data about you when you:
- register for an account on the Platform
- purchase a course (or a subscription to one or more courses) on the Platform
- access and use the Platform (including automatically by way of cookies)
- subscribe for or participate in competitions, contests, special events, or our mailing list
- make any enquiries about a course, or otherwise contact us about the Platform (whether in writing, by email, by telephone, through social media or via any contact form available on the Platform)
- request technical support or other customer care support
- participate in polls, surveys and questionnaires related to the Platform; or
- post content on our social media pages or on any area of the Platform which allows for user-generated content.
All of the personal data will be provided by you directly. Where lawful, we may also obtain limited personal data from third parties or public sources (for example, the open electoral register or credit reference agencies) and we may process that information where it is an essential component of the products and services we offer you.
What personal data we collect
The type of personal data we process may include (if and as applicable):
- Identity and contact information, such as your name, user name, email address, postal address, location of account registration, date of birth, telephone number and other information provided by you when you register for an account on the Platform, purchase a course, or subscribe for other services, contests, special events or our mailing list (“Identity and Contact Data”)
- Information which you provide in any correspondence with us, including details of any enquiries or requests for technical support you might send us (“Correspondence Data”);
- in relation to any order, purchase or subscription made by you, details of the course(s) ordered, purchased or subscribed for by you (including the type of course, purchase price and any relevant information added by our admin), your payment information, your preferences and other transaction information provided or obtained in connection with any such order, purchase or subscription (“Product and Service Data”)
- in your responses to any polls, surveys and questionnaires we may run from time to time (“Response Data”)
- Marketing and communications data, which includes your preferences in receiving marketing from us and our third party partners and your communication preferences (“Marketing and Communications Data”)
- Any personal data contained in content you post (as reviews on the Platform, on our social media pages or through any other posting any user-generated content) (“UGC Data”)
- Information ascertained by your interaction with us through the Platform, including your interests and purchase history (“Transaction Data”).
The purposes for which we process your personal data
We use your personal data for a number of purposes but only where the law allows us to.
We may process your personal data in any circumstances where such processing is necessary:
- In order to perform any agreement between us (including pursuant to our Platform terms and conditions and your purchase of any course or subscription)
- To comply with any applicable law or regulation
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data:
- To register you as a new customer or user
- In the performance of a contract with you
- In our legitimate interests (to acquire new users of our Platform)
- With consent (in some circumstances, as referred to below)
- To process and deliver orders, purchases and subscriptions, including to:
- Manage payments, fees and charges
- Collect and recover money owed to us
- Issue refunds where required
- To allow users to access the Platform and access their purchased content
- To manage our relationship with you which will include:
- notifying you about operational changes to our Platform, and any changes to our T&Cs and/or privacy notice
- responding to enquiries, messages and requests for technical support
- To enable you to partake in a prize draw or competition, to leave a review or to complete a survey
- To administer and protect our business and our platform, website or app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- To deliver relevant and personalised platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
- To improve our Platform, products/services, marketing, customer relationships and experiences
- To make suggestions and recommendations to you about goods or services that may be of interest to you
- To keep accountancy records
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you (which may be by way of update to this notice) and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Generally, we don’t rely on consent as a lawful basis for processing your personal data. Occasionally, though, to avoid sending you unwanted emails, we will get your consent before sending certain marketing communications to you. You are not required to opt-in to marketing communications in order to access the Platform.
You may withdraw your consent at any time by contacting firstname.lastname@example.org
You can also unsubscribe from different types of emails by following the unsubscribe link displayed at the bottom of each email. The withdrawal of your consent doesn’t affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds set out below.
What if you refuse to provide us with any personal data?
Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested (or fail to consent to the processing of that data, if necessary), we may not be able to perform the contract or arrangement we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will endeavour to notify you if this is the case at the time.
Whilst we may be able to provide you with certain products and services notwithstanding your refusal to submit personal data, this may limit your ability to participate in some activities, or use certain features, services or functionality.
Sharing information with affiliates and third parties
We will not share any of your personal data with third parties except as set out in the 2 paragraphs below or otherwise notified to you or agreed between you and us from time to time.
In the event that our business or any part of it is sold or integrated with another business, your details may be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
Your rights as a data subject
Subject to any conditions and requirements set out in the relevant Data Protection Laws, you may have some or all of the following rights in relation to the personal data we hold about you:
- The right to request a copy of your personal data held by us
- The right to correct any inaccurate or incomplete personal data held by us. You can amend any personal data which cannot be modified on the Platform by emailing us at email@example.com
- The right to request that we erase personal data we hold about you. You can deactivate your account on the Platform or by emailing us at firstname.lastname@example.org
- The right to request that we restrict the processing of your data
- The right to have your personal data transferred to another organisation
- The right to object to certain types of processing of your personal data by us
- The right to complain .
NOTE that these rights are not absolute in all situations and may be subject to conditions and provisos set out in the Data Protection Laws. We cannot therefore guarantee that we’ll be able to honour any request from you in connection with the rights set out above. (For example, even if you request that we delete your personal data, we may be required by law to retain some personal data for accounting and record keeping purposes.)
Storage and retention of your personal data
As a minimum, we need to store your data for as long as is necessary to enable us to provide you with the content and services that you have requested from us (or to support your other uses of our Platform, such as maintaining your account(s)). So we’ll usually store your personal data for as long as you have an account with us, and will usually delete it when you delete your account.
However, we will retain certain of your personal data for longer if we think it is reasonably necessary to do so in the circumstances, taking into consideration factors such as:
- Our need to perform any agreements between you and us (including order fulfilment)
- Our need to answer any queries or resolve any problems you may have
- Your continued consent to receive marketing and other emails and communications from us
- Our continued provision of any content or services to you
- Our need to comply with legal requirements (e.g. relating to record keeping).
If you tell us that you would like to delete your account, we will take steps to delete all the personal data we hold about you once it is no longer necessary for us to hold it (e.g. to fulfil any outstanding orders, resolve disputes, or as is permitted by applicable law or regulation).
For as long as we do store your data, the Company follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information you have provided. The Company has security measures in place designed to protect against the loss, misuse, and alteration of the information under our control. Personal data collected by the Company in connection with this notice is stored in secure operating environments that are not available to the public. The Company maintains information behind a firewall-protected server and uses SSL encryption for purchases made through our online store.
You are responsible for maintaining the strength and confidentiality of any login credentials.
We will notify you as soon as reasonably practicable if we have reason to believe that there has been a personal data breach by us which could adversely affect your rights and freedoms.
A cookie is a small file of letters and numbers stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive.
Your browser may give you the ability to block all or some cookies by activating a setting in your browser’s options. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Platform, or may not be able to experience all the features and functionality of our Platform.
Except for essential cookies, all cookies will remain for 30 days unless the cookie cache is cleared (unless otherwise indicated in the table above).
Questions and complaints
For all questions or complaints about this notice, we would appreciate the chance to deal with your concerns before you approach the relevant data protection authority. Please contact us in the first instance at email@example.com.
You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues, which in the UK is the Information Commissioner’s Office (ICO) (www.ico.org.uk).
By subscribing I consent to my personal data being processed in accordance with the privacy notice.