Privacy Policy
Contents
Clause
1. Important information and who we
are.......................................................
1
2. The data we collect about
you....................................................................
2
3. How is your personal data
collected?..........................................................
4
4. How we use your personal
data..................................................................
4
5. Marketing................................................................................................
..
7
6. Disclosures of your personal
data................................................................
7
7. International
transfers................................................................................
8
8. Data
security..............................................................................................
8
9. Data
retention...........................................................................................
8
10. Your legal
rights.........................................................................................
9
Introduction
Welcome to Enterprise Learning Academy Limited's privacy policy.
Enterprise Learning Academy Limited (%u201CELA%u201D) respects your privacy and is
committed to protecting your personal data. This privacy policy will inform you
as to how we look after your personal data and tell you about your privacy
rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how ELA collects and
processes your personal data, including any data you may provide when you
sign up to our newsletter, purchase a product or service or take part in a
competition or promotion.
It is important that you read this privacy policy together with any other privacy
policy or fair processing policy we may provide on specific occasions when we
are collecting or processing personal data about you so that you are fully aware
of how and why we are using your data. This privacy policy supplements other
notices and privacy policies and is not intended to override them.
Controller
Enterprise Learning Academy Limited is the controller and responsible for your
personal data (collectively referred to as %u201CEnterprise Learning Academy%u201D, %u201CELA,%u201D
"we," "us" or "our" in this privacy policy).
We have appointed an individual who is responsible for overseeing questions in
relation to this privacy policy. If you have any questions about this privacy
policy, including any requests to exercise your legal rights, please contact Mark
Kelly, our commercial manager using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices,
please contact us in the following ways:
Full name of legal entity: Enterprise Learning Academy
Email address: info@enterpriselearningacademy.com
Postal address: Office 2 Sandbank Estate, Cumeragh Lane, Longridge,
Lancashire, PR3 2AJ
You have the right to make a complaint at any time to the Information
Commissioner's Office (ICO), the UK supervisory authority for data protection
issues (www.ico.org.uk). We would, however, appreciate the chance to deal
with your concerns before you approach the ICO so please contact us in the
first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. It is important that the
personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
By using ELA%u2019s website you are bound by the terms of this privacy policy.
Please be aware that for the purpose of providing the best service we can as
well as changes in legal legislation, this policy may change or update from time
to time.
Third-party links
This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these thirdparty websites and are not responsible for their privacy statements. When you
leave our website, we encourage you to read the privacy policy of every
website you visit.
Cookies
Our online website uses both %u201Csession%u201D and %u201Cpersistent%u201D cookies.
A cookie consists of information sent by a web server to a web browser
and stored by the browser. The information is then sent back to the server
each time the browser requests a page from the server. This enables the
web server to identify and track the web browser. We will use the session
cookies to: keep track of you whilst you navigate the website. We will use
the persistent cookies to: enable our website to recognise you when you
visit. Session cookies will be deleted from your computer when you close
your browser.
Persistent cookies will remain stored on your computer until deleted, or
until they reach a specified expiry date. We use Google Analytics to
analyse the use of this website. Google Analytics generates statistical and
other information about website use by means of cookies, which are
stored on users%u2019 computers. The information generated relating to our
website is used to create reports about the use of the website. Google will
store this information. Google%u2019s privacy policy is available at: http://
www.google.com/privacypolicy.html.
Most browsers allow you to reject all cookies, whilst some browsers allow
you to reject just third-party cookies. For example, in Internet Explorer you
can refuse all cookies by clicking %u201CTools%u201D, %u201CInternet Options%u201D, %u201CPrivacy%u201D,
and selecting %u201CBlock all cookies%u201D using the sliding selector. Blocking all
cookies will, however, have a negative impact upon the usability of many
websites. Your personal data will be used for the purposes specified in this
privacy policy or in relevant parts of the website.
2. The data we collect about you
Personal data, or personal information, means any information about an
individual from which that person can be identified. It does not include data
where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about
you which we have grouped together as follows:
· Identity Data includes first name, maiden name, last name, username or
similar identifier, marital status, title, date of birth and gender.
· Contact Data includes billing address, delivery address, email address
and telephone numbers.
· Financial Data includes bank account and payment card details %u2013
primarily payment to us is done through the company known as Paypal, but in
exceptional circumstances we may find ourselves in possession of such data.
We may also collect data through other companies or businesses in a similar
sector to Paypal.
· Transaction Data includes details about payments to and from you and
other details of products and services you have purchased from us.
· Technical Data includes internet protocol (IP) address, your login data,
browser type and version, time zone setting and location, browser plug-in types
and versions, operating system and platform, and other technology on the
devices you use to access this website.
· Profile Data includes your username and password, purchases or orders
made by you, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you use our website,
products and services.
· Marketing and Communications Data includes your preferences in
receiving marketing from us and our third parties and your communication
preferences.
We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data could be derived from
your personal data but is not considered personal data in law as this data
will not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data
with your personal data so that it can directly or indirectly identify you, we treat
the combined data as personal data which will be used in accordance with this
privacy policy.
We do not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical beliefs,
sex life, sexual orientation, political opinions, trade union membership)). Nor do
we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract
we have with you, and you fail to provide that data when requested, we may not
be able to perform the contract we have or are trying to enter into with you (for
example, to provide you with goods or services). In this case, we may have to
cancel a product or service you have with us, but we will notify you if this is the
case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you, including
through:
· Direct interactions. You may give us your Identity, Contact and Financial
Data by filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
· apply for our products or services;
· create an account on our website;
· subscribe to our service or publications;
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us feedback or contact us.
· Automated technologies or interactions. As you use our services and/
or interact with us and our website, we will automatically collect Technical Data
about your equipment, browsing actions and patterns. We collect this personal
data by using cookies, server logs and other similar technologies. We may also
receive Technical Data about you if you visit other websites employing our
cookies.
· Third parties or publicly available sources. We will receive personal
data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks;
(c) search information providers; and
(d) Contact, Financial and Transaction Data from providers of technical,
payment and delivery services.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly,
we will use your personal data in the following circumstances:
· Where we need to perform a contract we are about to enter into, or have
entered into, with you.
· Where it is necessary for our legitimate interests (or those of a third
party) and your interests and fundamental rights do not override those
interests.
· Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your
personal data although we will get your consent before sending third-party
direct marketing communications to you via email or text message. You have
the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan
to use your personal data, and which of the legal bases we rely on to do so. We
have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please
contact us if you need details about the specific legal ground we are relying on
to process your personal data where more than one ground has been set out in
the table below.
Purpose/Activity Type of data Lawful basis for
processing including
basis of legitimate
interest
To register you as a
customer
(a) Identity
(b) Contact
Performance of a
contract with you
To register you with the
relevant Awarding Body
and track learner%u2019s
progress.
(e.g. Focus Awards or
Active IQ)
(a) Identity
(b) Contact
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to
provide the correct
certification and
training)
Establishing your online
learning platform with
Enterprise Learning
Academy
(a) Identity
(b) Contract
Performance of a
contract with you
To process and provide
the purchased service
including:
(a) Manage payments,
fees and charges
(b) Collect and recover
money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to
recover debts due to us)
To manage our
relationship with you
which will include:
(a) Notifying you about
changes to our terms or
privacy policy
(b) Asking you to leave
a review or take a
survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance of a
contract with you
(b) Necessary to comply
with a legal obligation
(c) Necessary for our
legitimate interests (to
keep our records
updated and to study
how customers use our
products/services)
To enable you to
partake in a prize draw,
competition, promotion
or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to
study how customers
use our products/
services, to develop
them and grow our
business)
To administer and
protect our business
and our website
(including
troubleshooting, data
analysis, testing, system
maintenance, support,
reporting and hosting of
data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our
legitimate interests (for
running our business,
provision of
administration and IT
services, network
security, to prevent
fraud and in the context
of a business
reorganisation or group
restructuring exercise)
(b) Necessary to comply
with a legal obligation
To deliver relevant
content and
advertisements to you
and measure or
understand the
effectiveness of the
advertising we serve to
you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our
legitimate interests (to
study how customers
use our products/
services, to develop
them, to grow our
business and to inform
our marketing strategy)
To use data analytics to
improve our website,
products/services,
marketing, customer
relationships and
experiences
(a) Technical
(b) Usage
Necessary for our
legitimate interests (to
define types of
customers for our
products and services,
to keep our website
updated and relevant, to
develop our business
and to inform our
marketing strategy)
To make suggestions
and recommendations
to you about goods or
services that may be of
interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
Necessary for our
legitimate interests (to
develop our products/
services and grow our
business)
Purpose/Activity Type of data Lawful basis for
processing including
basis of legitimate
interest
To register you as a
customer
(a) Identity
(b) Contact
Performance of a
contract with you
To register you with the
relevant Awarding Body
and track learner%u2019s
progress.
(e.g. Focus Awards or
Active IQ)
(a) Identity
(b) Contact
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to
provide the correct
certification and
training)
Establishing your online
learning platform with
Enterprise Learning
Academy
(a) Identity
(b) Contract
Performance of a
contract with you
To process and provide
the purchased service
including:
(a) Manage payments,
fees and charges
(b) Collect and recover
money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to
recover debts due to us)
To manage our
relationship with you
which will include:
(a) Notifying you about
changes to our terms or
privacy policy
(b) Asking you to leave
a review or take a
survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance of a
contract with you
(b) Necessary to comply
with a legal obligation
(c) Necessary for our
legitimate interests (to
keep our records
updated and to study
how customers use our
products/services)
To enable you to
partake in a prize draw,
competition, promotion
or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to
study how customers
use our products/
services, to develop
them and grow our
business)
To administer and
protect our business
and our website
(including
troubleshooting, data
analysis, testing, system
maintenance, support,
reporting and hosting of
data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our
legitimate interests (for
running our business,
provision of
administration and IT
services, network
security, to prevent
fraud and in the context
of a business
reorganisation or group
restructuring exercise)
(b) Necessary to comply
with a legal obligation
To deliver relevant
content and
advertisements to you
and measure or
understand the
effectiveness of the
advertising we serve to
you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our
legitimate interests (to
study how customers
use our products/
services, to develop
them, to grow our
business and to inform
our marketing strategy)
To use data analytics to
improve our website,
products/services,
marketing, customer
relationships and
experiences
(a) Technical
(b) Usage
Necessary for our
legitimate interests (to
define types of
customers for our
products and services,
to keep our website
updated and relevant, to
develop our business
and to inform our
marketing strategy)
To make suggestions
and recommendations
to you about goods or
services that may be of
interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
Necessary for our
legitimate interests (to
develop our products/
services and grow our
business)
Purpose/Activity Type of data Lawful basis for
processing including
basis of legitimate
interest
To register you as a
customer
(a) Identity
(b) Contact
Performance of a
contract with you
To register you with the
relevant Awarding Body
and track learner%u2019s
progress.
(e.g. Focus Awards or
Active IQ)
(a) Identity
(b) Contact
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to
provide the correct
certification and
training)
Establishing your online
learning platform with
Enterprise Learning
Academy
(a) Identity
(b) Contract
Performance of a
contract with you
To process and provide
the purchased service
including:
(a) Manage payments,
fees and charges
(b) Collect and recover
money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to
recover debts due to us)
To manage our
relationship with you
which will include:
(a) Notifying you about
changes to our terms or
privacy policy
(b) Asking you to leave
a review or take a
survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance of a
contract with you
(b) Necessary to comply
with a legal obligation
(c) Necessary for our
legitimate interests (to
keep our records
updated and to study
how customers use our
products/services)
To enable you to
partake in a prize draw,
competition, promotion
or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to
study how customers
use our products/
services, to develop
them and grow our
business)
To administer and
protect our business
and our website
(including
troubleshooting, data
analysis, testing, system
maintenance, support,
reporting and hosting of
data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our
legitimate interests (for
running our business,
provision of
administration and IT
services, network
security, to prevent
fraud and in the context
of a business
reorganisation or group
restructuring exercise)
(b) Necessary to comply
with a legal obligation
To deliver relevant
content and
advertisements to you
and measure or
understand the
effectiveness of the
advertising we serve to
you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our
legitimate interests (to
study how customers
use our products/
services, to develop
them, to grow our
business and to inform
our marketing strategy)
To use data analytics to
improve our website,
products/services,
marketing, customer
relationships and
experiences
(a) Technical
(b) Usage
Necessary for our
legitimate interests (to
define types of
customers for our
products and services,
to keep our website
updated and relevant, to
develop our business
and to inform our
marketing strategy)
To make suggestions
and recommendations
to you about goods or
services that may be of
interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
Necessary for our
legitimate interests (to
develop our products/
services and grow our
business)
5. Marketing
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
This is how we decide which products, services and offers may be relevant for
you (we call this marketing).
You will receive marketing communications from us if you have requested
information from us or purchased goods or services from us and you have not
opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data
with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any
time.
Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a product/service purchase,
warranty registration, product/service experience or other transactions.
Change of purpose
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 you wish to get an
explanation as to how the processing for the new purpose is compatible with
the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify
you 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.
6. Disclosures of your personal data
We may share your personal data with third parties set out below for the
purposes set out in the table, such as:
· Third parties to whom we may choose to sell, transfer or merge parts of
our business or our assets. Alternatively, we may seek to acquire other
businesses or merge with them. If a change happens to our business, then the
new owners may use your personal data in the same way as set out in this
privacy policy.
· Paypal
· DIVIDO
· GOCARDLESS
· Active IQ
· Focus Awards
The above list is not exhaustive.
We require all third parties to respect the security of your personal data and to
treat it in accordance with the law. We do not allow our third party service
providers to use your personal data for their own purposes and only permit
them to process your personal data for specified purposes and in accordance
with our instructions.
7. International transfers
We do not transfer your personal data outside the European Economic Area
(EEA).
8. Data security
We have put in place appropriate security measures to prevent your personal
data from being accidentally lost, used or accessed in an unauthorised way,
altered or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business
need to know. They will only process your personal data on our instructions and
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they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data
breach and will notify you and any applicable regulator of a breach where we
are legally required to do so.
9. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to
fulfil the purposes we collected it for, including for the purposes of satisfying
any legal, regulatory, tax, accounting or reporting requirements. We may retain
your personal data for a longer period in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to our relationship
with you.
To determine the appropriate retention period for personal data, we consider
the amount, nature and sensitivity of the personal data, the potential risk of
harm from unauthorised use or disclosure of your personal data, the purposes
for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal, regulatory, tax,
accounting or other requirements.
In some circumstances you can ask us to delete your data and, on occasion, In
some circumstances we will anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes, in which
case we may use this information indefinitely without further notice to you.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in
relation to your personal data. These rights are:
Request access to your personal data (commonly known as a "data subject
access request"). This enables you to receive a copy of the personal data
we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This
enables you to have any incomplete or inaccurate data we hold about you
corrected, though we may need to verify the accuracy of the new data you
provide to us.
Request erasure of your personal data. This enables you to ask us to delete
or remove personal data where there is no good reason for us continuing to
process it. You also have the right to ask us to delete or remove your
personal data where you have successfully exercised your right to object to
processing (see below), where we may have processed your information
unlawfully or where we are required to erase your personal data to comply
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with local law. Note, however, that we may not always be able to comply
with your request of erasure for specific legal reasons which will be notified
to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a
legitimate interest (or those of a third party) and there is something about
your particular situation which makes you want to object to processing on
this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal
data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your information
which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to
ask us to suspend the processing of your personal data in the following
scenarios: (a) if you want us to establish the data's accuracy; (b) where our
use of the data is unlawful but you do not want us to erase it; (c) where you
need us to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or (d) you have objected to our
use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will
provide to you, or a third party you have chosen, your personal data in a
structured, commonly used, machine-readable format. Note that this right
only applies to automated information which you initially provided consent
for us to use or where we used the information to perform a contract with
you.
Withdraw consent at any time where we are relying on consent to process
your personal data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw
your consent, we may not be able to provide certain products or services to
you. We will advise you if this is the case at the time you withdraw your
consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any
of the other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we could refuse to
comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any
of your other rights). This is a security measure to ensure that personal data is
not disclosed to any person who has no right to receive it. We may also contact
you to ask you for further information in relation to your request to speed up
our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it
could take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you
updated