Effective Date: September 2022
A reference to “LearnersPlatform”, “We” and “Us” means LearnersPlatform and/or any of its other corporate affiliates, listed below in the “Contact us” section.
This Policy does not apply:
- when We process personal data collected about you for our LearnersPlatform customers
In certain circumstances, We process your personal data as a data processor, which means on behalf of our customers (for example, where LearnersPlatform provides Services to an organisation, a company or academic institution). In these cases, it is the LearnersPlatform customer that is responsible for the processing of your personal data.
LearnersPlatform data protection practices will be regulated by the terms of a data protection agreement entered with the customer.
If you have questions or concerns about how your personal data is handled in these circumstances, including how to exercise your rights, you should contact the customer that has control over your account (e.g. your employer or account administrator) and refer to their separate privacy policies.
- to third-party sites or integrations not controlled by LearnersPlatform
From time to time, We may include links on the Sites to third-party websites, or be able to integrate LearnersPlatform services with third-party integrations. Please be aware that we do not control, monitor or are responsible for such websites, their web content while you are visiting their websites, and the processing of your personal data required by the third-party to use this integration. We encourage you to review their privacy policies.
WHAT INFORMATION WE COLLECT ABOUT YOU:
In this Policy any reference to ‘personal data’ or ‘personal information’ is intended as any information that can identify or relate to you as individual person. We collect the following personal information from you as further described below:
(a) Information provided voluntarily by you
- Contact information, such as name, business email address, phone number, your photo, billing information, physical address, Skype information, call recordings, information you input in open text fields in help/contact us forms. By using our Services, you might choose to add a display name, profile photo, job title, and other details to your profile.
- Content information, such the information you may choose to post, send, receive and share in our Services. Examples of Content information include the content viewed in the Services, training interactions, the files and links you upload and the aggregate insights obtained from this information.
- Customer Support information, such a summary of the problem you are experiencing, and any other documentation or information that would be helpful in resolving an issue submitted to Us.
We do not collect your payment information, such as your credit card or your Paypal account, but we ask our payment providers to manage this information on our behalf.
- Information We collect automatically from you
- Analytics information, such as when you visit and interact with any of our Services. This information includes the features you use; the links you click on; the type, size and filenames of attachments you upload to the
Services; frequently used search terms; and your interaction with third-party integrations and others on the Services.
- Information We receive from other sources
From time to time, We may receive information about you from:
- other end users,
- third-party providers,
- our corporate affiliates, professional social networks and publicly accessible websites,
- Third-party integrations set up with your LearnersPlatform account,
- and from our business partners.
We will collect this information only where these third parties are legally permitted or required to share your personal information to Us.
HOW WE USE YOUR PERSONAL INFORMATION AND WHICH LEGAL BASIS WE RELY ON:
We collect and process personal information for a variety of purposes, including:
|Type of personal information||Purposes||Legal basis|
|Contact information||To send you an order confirmation and invoice you accordingly||Performance of a contract with you|
|• • • •||To administer your account, including your single sign-on (SSO) access To provide the Services to you To respond to a demo or other customer service requests To give you access to a LearnersPlatform Community and connect with other users|
|Contact information||•||To establish and manage our relationship with you, including informing you about Services or opportunities which might be of your interest For safety and security to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies||LearnersPlatform business legitimate interests|
|Contact information||•||To send you marketing communications and newsletters To conduct surveys and evaluate customer satisfaction||LearnersPlatform business legitimate interests, or, if required under applicable law, to the extent you have provided your prior consent|
|Contact information||• •||To manage registrations at our events (e.g. conferences, webinars) and customer participation Recording calls for training and quality assurance purposes||Your consent to process your data|
|Contact information||• •||To comply with legal obligations, including the cases where LearnersPlatform needs to respond to requests by government or law enforcement authorities. To protect our legitimate business interests and legal rights||To comply with a legal obligation|
|Content information||•||For data labelling and machine learning to improve our services and your experience (e.g. to predict the most appropriate content to insert in a selected area of the LearnersPlatform domain)||LearnersPlatform business legitimate interests|
|Customer Support information||To resolve technical issues, to respond to requests for assistance||Performance of a contract with you|
|Customer Support information||•||To analyze crash information, and to improve the Services||LearnersPlatform business legitimate interests|
|Device information||• • •||Display content based upon your interests For adverting purposes To develop and improve our websites||LearnersPlatform business legitimate interests, or, if required under applicable law, to the extent you have provided your prior consent|
HOW WE SHARE YOUR PERSONAL INFORMATION:
We do not share or sell your personal information to third parties for their own marketing purposes. We may share your personal information with the third parties listed below in the following circumstances:
- Service Providers
- Affiliates and Subsidiaries
We may share the information We collect within the LearnersPlatform group of companies to provide services to you.
- Your organisation’s LearnersPlatform administrators
If you’re using LearnersPlatform Services in connection with an organization or academic institution, your company’s own account administrator can have access to some information associated with you and connected with the domain they manage.
- LearnersPlatform Community
In our community you are able to upload and share comments or feedback publicly with other LearnersPlatform users. Any information that you disclose in this forum is not confidential, and LearnersPlatform may use it for any purpose. You should be aware that any information you post openly in these ways will be potentially accessible through third party search engines. Also, in the Community, your posts might remain accessible (but with your profile information removed where possible) to ensure the correct functionality of the Community.
- Event sponsors
if you attend an event or webinar organized by us, we may share your personal data with the sponsors of the event with your explicit consent, when required by the applicable law.
- Legal Authorities
We may also disclose your personal data as required by law, such as to comply with a subpoena or similar legal process when We believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. Unless We are prohibited by law, We will notify you of any disclosure requirement.
- Potential parties involved in a business transaction
In case LearnersPlatform decides to merge with, or is acquired (entirely or partially) by another company, or sell some of
the services provided or a business unit, your personal data might be disclosed, under conditions of confidentiality, to our advisers and any prospective purchaser’s advisers. In this case We will inform you, via email and/or a prominent notice on our website, of any change in ownership, use of your personal data, and choices you may have regarding your personal data.
We may also disclose your personal data to any other third party with your prior consent (e.g. when you connect LearnersPlatform Services with third-party integrations).
HOW YOUR INFORMATION IS KEPT SECURE:
The security of your personal information is important to Us.
We follow generally accepted security standards and We have adopted commercially reasonable security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access. We may use third-party products and services to secure or store your information. For more information on where We store and how We secure your information, please see our compliance and security page.
Depending on where you live, you may have a legal right to be notified in case of security breach. Overall, if you have any reason to believe that your interactions with the Services are no longer secure, please notify Us immediately at privacy@LearnersPlatform.com.
We may, subject to applicable law, transfer your information outside the country where you are located and to where information protection standards may differ (e.g. your information may be stored on servers located in other jurisdictions). We will utilise appropriate safeguards governing the transfer and usage of your personal information. See the following Section ‘How we transfer your data’ for further information.
HOW WE TRANSFER YOUR DATA:
Your personal information may be transferred to, and processed in, countries other than the country in which you are based, where LearnersPlatforms ‘affiliates, subsidiaries, partners or our third-party service providers operate.
Some of these countries might not offer an adequate level of protection and security. As a result, We take measures to ensure that your information is safe and protected in compliance with the applicable data protection laws, including:
- reliance of Standard Contractual Clauses to transfer your data outside the European Economic Area, United Kingdom and Switzerland;
- implementation of organisational, contractual and technical security measures with our third-party service providers;
- establishment of an intra-group data transfer agreement for internal transfers of personal data within LearnersPlatform group of companies around the world.
A quick note about the Privacy Shield
While LearnersPlatform does not rely on the Privacy Shield as measure to transfer personal data to other countries, We participates in and have certified our compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (see our certification here). LearnersPlatform is committed to adhere to the Privacy Shield Framework Principles in relation to all personal data received from European Union and Switzerland.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, LearnersPlatform is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, LearnersPlatform may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that We have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedbackform.truste.com/watchdog/request. Under certain conditions, described in more details on the Privacy Shield website, a binding arbitration might be available when other dispute resolution procedures have been exhausted.
To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.
HOW LONG WE KEEP YOUR INFORMATION:
We will retain your information for the time needed to fulfil the purposes described above, unless a longer retention period is required or permitted by law.
If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services.
After the expiry of the applicable retention period, We will either delete your information or, if this is not possible (for example, because the information has been stored in backup archives), We will securely store your information and isolate it from any further use until deletion is possible.
In case you object from any marketing communications, or withdraw your consent, We will promptly stop using your information collected for these purposes. However, We might keep a permanent record of the fact that you have asked Us not to process your information so that We can respect your request in future.
We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, scripts, and other similar technologies to analyze trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests.
SOCIAL MEDIA WIDGETS:
Our website includes Social Media features, such as the Facebook Like button, and widgets, such as the ‘Share This’ button, or interactive mini-programs that run on our websites. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social Media features and widgets are either hosted by a third party or hosted directly on our website. Please read the privacy statement of the company providing these features to understand how your personal data is processed.
EXERCISING YOUR RIGHTS:
Regardless your location, you have the right to know if We process your data, to amend or update inaccurate or incomplete information about you, to request deletion of your personal data, or request that We no longer use it. You may submit a request for access (i.e. request information on personal data collected, used, disclosed or processed by LearnersPlatform) as well. Some of these requests can be processed through the self-service features available inside the LearnersPlatform admin portal (See the User Management section for more information about these).
If you are a resident of European Economic Area, United Kingdom, Switzerland, or Brazil you can also submit a request (i) for rectification, or (ii) to object to our processing of your personal data, or even (iii) to have your data available in a structured, electronic format (‘data portability’).
Where you gave Us consent to use your information for a specific purpose, you can ask Us to withdraw that consent, but this will not affect the lawfulness of any processing activity already taken place before your withdrawal.
You have the right to opt-out of marketing communications We send you at any time. Please read the section ‘Marketing communications’ below for further details on these requests.
In some circumstances, We might need to verify your identity and your relationship with LearnersPlatform before proceeding with your request for security reasons.
Subject to a request required by law, LearnersPlatform might not be able to entirely comply with your request to withdraw.
In order to exercise your rights described above and/or submit inquiries or complaints regarding our processing of your personal data, you can do so at any time by contacting Us using the information given under the “Contact us” section below.
If you believe that We have not been able to assist you with your requests, you have the right to lodge a complaint with your local competent supervisory authority (contact details for European data protection authorities for countries can be found here and for the United Kingdom here).
(a) Marketing communications
If you no longer want to receive marketing-related emails from Us, you can opt out of receiving such emails by clicking the “unsubscribe” link at the bottom of any marketing email you receive from Us. Please be aware that you may continue to receive certain communications from Us that are necessary for the Service (e.g. renewal notifications, invoices, technical updates).
If you are having difficulty unsubscribing from our marketing emails using the above method, please contact Us directly at the email privacy@LearnersPlatform.com.
(b) Your rights as end user
As described above, We may also collect and process personal data submitted by LearnersPlatform customers under their instructions. If you wish to exercise any rights you may have under applicable data protection laws, please check their privacy policies and contact them directly.
If you make your request directly to Us, We will refer your request to the relevant LearnersPlatform customer (as long as they can be identified from the details you provided) and will support them as required.
(c) California residents
In addition to the rights and information provided above, California consumers and their authorized agents can request:
- information about the categories of personal information that We collect about you, including how We collect it, from which the sources We collect it, the business purposes pursued with your information and the way We share it with third parties. Please read sections above to obtain further details on how We manage your personal information;
- to delete all your personal information.
To exercise these rights or for any other questions, please contact Us at privacy@LearnersPlatform.com.We might need to take steps to confirm that you are authorised to make the request (e.g. by asking for a proof of residency or the consumer’s written authorization if you are an agent). You will not be discriminated against for exercising any of your privacy rights. However if you ask CJs to delete your information, We may not be able to entirely provide our
Services to you.
(d) Nevada residents
In addition to the rights and information provided above, Nevada consumers can ask Us to opt out of any potential future sales (as defined in accordance with the applicable data protection law) by contacting Us at privacy@LearnersPlatform.com.At the moment, LearnersPlatform does not sale any personal data collected from you.
If you have any questions or concerns relating to our data protection practices, or wish to exercise any of your rights, please contact Us at privacy@LearnersPlatform.com or by mail at LearnersPlatform headquarter: LearnersPlatform, PP143, Prampram, Ghana.