Where we store your personal data and how long for
Our site is hosted on servers located in the UK and support is being provided for our site by our group staff based in the UK and the US. Any personal information that we collect from you is input directly into our Salesforce database, which is hosted and supported in the European Economic Area (EEA), and our Pardot database, which is hosted and supported in the US. For users based in the EEA, this means that the data that we collect from you will be transferred to, and stored outside the EEA. It may also be processed by staff operating outside the EEA who work for us. We have signed EU Model Clauses with our relevant group entities and with Pardot, which means that such transfers would be lawful transfers of personal data outside the EEA, in accordance with Applicable Legislation (as defined below).
Unfortunately, the transmission of information via the internet is almost never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data that is transmitted to our site or otherwise gathered by us; any transmission and supply of personal data to us is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access to it.
We will keep a copy of any personal data obtained from you through our site or otherwise for as long as we believe is reasonably required, or such longer period as may be required for legal, audit and compliance purposes. This does not affect your right to opt out from receiving marketing communications, as outlined above and in the section “Your rights” below. Please note that you may request that your details are deleted from our Salesforce and Pardot databases at any point of time, however you should be aware that if your details are deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future.
Uses made of the information
We use information held about you in the following ways:
- To provide you with information via post, email or telephone, about our products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
- To carry out our obligations arising from any contracts entered into between you and us or to enable us to deal with any query you have raised;
- To allow you to participate in interactive features of our service, when you choose to do so;
- To notify you about changes to our service;
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure.
This will include your details being included in our Salesforce and Pardot databases.
Disclosure of your information
We may disclose your personal information to any member of the Learning Technologies Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, provided however that we shall remain responsible for the treatment by such group members of your personal data in accordance with this Privacy Policy. As stated above, where such disclosure involves the transfer of personal data outside of the EEA, we have entered into EU Model Clauses with those relevant group entities to ensure any such disclosure is on a legal basis.
Our general policy is not to disclose any personal data to a third party except with your prior consent. However, we may disclose your personal information to third parties:
- If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of business and other agreements; or to protect our rights, property, or safety, or that of our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Legal basis of our processing of your personal data.
We process your personal data on the basis of your consent (in relation to sending you marketing information following your submitted request through our site), and alternatively or additionally, for our legitimate interests of promoting, growing and developing our business and, where you are a customer, in order to perform our obligations under the contract between us.
Your rights
You have the right to ask us not to process your personal data for marketing purposes. You may also choose not to receive publications or certain other communications from us by explicitly indicating so in the appropriate section of the Registration Form or by opting-out by phone, email or via direct marketing emails sent to you.
We will inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to, or may disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by (un)checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at privacy@ltgplc.com or by unsubscribing per the method outlined in any emails sent, or during any phone calls with you.
Our site may, from time to time, contain links to and from the websites of our group companies, partner networks, clients, and/or affiliates. If you follow a link to any of these websites, please note that these websites are subject to their own privacy policies and we do not accept any responsibility or liability for these sites and policies. Please check these policies before you submit any personal data to these websites.
You also have the right to ask us to amend inaccurate personal data held about you by us, or to delete it. However you should be aware that if you request your details to be deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future. If you send us any personal information in digital format, such as photographs, you are entitled to ask for a copy of this to be sent to you.
Where you are based in the EU you have the right to contact your local data protection authority and you can request details of how to do this by contacting us at privacy@ltgplc.com.com.
Any queries concerning your rights or the exercising of them and any complaints concerning the processing of your personal data should be sent to privacy@ltgplc.com.com.#
Access to information
We are subject to the Data Protection Act in the UK and, for our processing activities in Europe, the Data Protection Directive 95/46/EC and e-Privacy directive 2002/58/EC (together with national implementing legislation), and, effective May 25, 2018, the General Data Protection Regulation 2016/670, all as may be updated or replaced over time (together referred to as “Applicable Legislation”). The Applicable Legislation gives you the right to verify whether we hold your personal data and (have) access your personal data. Any data access request may be subject to a reasonable fee to meet our costs in dealing with your request.
Changes to our privacy policy
This policy may be updated by us from time to time, so please check this policy periodically to ensure you are aware of our latest policies.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@ltgplc.com. Complaints should be sent to the same address.
