KLIK2LEARN PRIVACY NOTICE | EFFECTIVE 8th June 2022
Klik2learn Ltd (“Klik2learn,” “we,” or “us”) offer an English language and vocational training platform to customers and learners. This Privacy Notice (“Notice”) applies to the personal information that Klik2learn, its subsidiaries, and affiliates located worldwide within the Klik2learn family of companies (“Affiliates”) collect through www.klik2learn.com and other websites (e.g., edu.klik2learn.com) (individually, “Website” and collectively the “Websites”), applications, products, and services owned or controlled by Klik2learn or Websites within the Klik2learn family of companies that post a link to this Notice. In this Notice, personal information means information that (either in isolation or in combination with other information) enables you to be directly or indirectly identified (“Personal Information”).
This Notice aims to inform you about how we collect, use, disclose and store Personal Information when you:
– Interact or use our Websites, including when you download materials from our resources page or request a demo.
– Register and/or attend our events and webinars (collectively “Events”).
– Use any of our products, services, or applications, including any trials (collectively the “Services”) in any manner.
Personal Information you provide to us:
From Websites or Events: We may collect Personal Information that you choose to send to us or provide to us, for example, on our “Request a Demo” (or similar) online form or if you register for any Events. If you contact us through the Websites, we will keep a record of our correspondence.
From the Services: We receive and store the Personal Information you provide directly to us. For example, when setting up new users, we collect Personal Information, such as name, e-mail address, postal address, phone number, etc. We may collect and store media, documents, or other information you provide to us. We collect commercial information, such as records of the purchased Services or information related to requests for demos.
Our customers will typically act as data controllers for any Personal Information related to them or Personal Information that third parties upload in our systems, products, and applications in connection with the provision of our Services. Klik2learn will typically act as a data processor in accordance with applicable Service and/or data processing agreements (“Agreement/s”). Further information, including specific obligations of the data controller and processor, can be found in the Agreements.
When you use the Websites:
When you visit our Websites, we collect Internet or other electronic network activity information through the use of cookies and other trackers. Depending on your tracking preferences, the information we collect may include but is not limited to your device’s Internet Protocol (“IP’) address, referring website, what pages your device visited, and the time that your device visited our Website. We may also rely on analytics and tools used to prevent spam and other security risks related to the use of abusive automated software. You can choose your preferences with regards to the cookies and other trackers by accessing the preference centre on our Websites. Visit our Cookie Notice for more information on the types of cookies and other trackers we use on our Websites.
When you use the Services:
Internet or other electronic network activity information may also be collected when you use the Services:
– Usage information – we keep track of user activity in relation to the types of Services our customers and their users use, the configuration of their computers, and performance metrics related to their use of the Services.
– Log information – we log information about our customers and their users when they use one of our Services, including their IP addresses.
– Information collected by cookies and other similar technologies – we use various technologies to collect information, including saving cookies to users’ computers.
– Customer feedback – While using the Services, you may be asked to provide feedback (e.g., in the software directly or after receiving help from our support team). Providing this feedback is optional.
For further information please visit the Klik2learn Cookie Notice.
We will use the Personal Information we collect through our Websites:
– To administer our Websites, our Events, and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes.
– To improve our Websites to ensure that content is presented most effectively for you and your device.
– For trend monitoring, marketing, and advertising.
– For purposes made clear to you at the time you submit your Personal Information, for example, to fulfill your demo request, to provide you with access to one of our webinars, or to provide you with information you have requested about our Services.
As part of our efforts to keep our Websites secure.
Our use of your Personal Information may be based on our legitimate interests to ensure network, information security, and business performance improvement. Our direct marketing purposes are based on your consent (for example when you request a demo, contact us directly, provide us your business card, agree to receive communications after an Event, and similar circumstances). We may also rely on our legitimate interests to improve business and marketing practices or contact you to offer similar Services or products that you may have bought from us, requested a demo, or negotiated with us.
We may use the Personal Information we collect from our customers and their users in connection with the Services we provide for a range of reasons, including to:
– Set up a user account.
– Provide, operate and maintain the Services.
– Process and complete transactions, and send related information, including transaction confirmations and invoices.
– Manage our customers’ use of the Services, respond to enquiries and comments, and provide customer service and support.
– Send customers technical alerts, updates, security notifications, and administrative communications.
– Investigate and prevent fraudulent activities, unauthorised access to the Services, and other illegal activities.
For any other purposes about which we notify customers and users.
Cookies: When Klik2learn customers access their platform hosted in the Cloud we use strictly necessary cookies and other trackers to provide authentication tools, enhance security, and prevent fraud. The Klik2learn apps (the “Apps”) are the subdomains of our Websites e.g. edu.klik2learn.com. Therefore, the preferences signalled on our Websites (through the cookies banner and preference centre) will be reflected on the Apps. For example, if you choose to accept analytics cookies on one of our Websites, these will be active in the Apps unless you modify your choices by resurfacing the preference centre. For more information about our use of cookies and other trackers visit the Klik2learn Cookie Notice.
We use your Personal Information in this context based on the Agreement that we have in place with you or our legitimate interests, typically, either for security purposes or business practice improvement (e.g., the prevention and investigation of fraudulent activities).
Provision of Personal Information in these instances may be necessary to enable our proper execution of the Agreement. Failure to provide Personal Information may cause some services to become unavailable. Personal Information will be deleted based on the terms of the Agreement that we have in place with you.
We share and disclose information, including Personal Information, about our customers in the following limited circumstances:
Vendors, consultants, and other service providers:
We may share your Personal Information with third-party vendors, consultants, and other service providers we employ to perform tasks on our behalf. These companies include (for example) our English and vocational learning coaches and tutors, our payment processing providers, website analytics companies (e.g., Google Analytics), tools used to prevent spam and other security risks related to the use of abusive automated software (e.g., Google reCAPTCHA), online activities, product feedback or help desk software providers (e.g., HubSpot), CRM service providers (e.g., HubSpot), email service providers (e.g., Google Mail) and others. If Klik2learn receives your Personal Information in the United Kingdom and subsequently transfers that information to a third party agent or service provider for processing, Klik2learn remains responsible for ensuring that such third party agent or service provider processes your Personal Information to the standard required by the applicable privacy laws, including the GDPR. These transfers will typically be based on our legitimate interests or agreed upon in the Agreement.
For further information please see the International data transfers section below.
Event sponsors:
When you attend an event organised by Klik2learn, we ask your preferences on sharing your contact details with the event sponsor. Based on your choice, we may share your contact details (such as your name, email address, company name, and phone number) with the Event sponsor. If you’d like to opt out of sharing your details with sponsors, you can always do so either at the time of registration or by submitting a request.
Business transfers:
We may choose to buy or sell assets and may share and/or transfer customer information, including Personal Information, in connection with the evaluation of and entry into such transactions and based on our legitimate interests. Also, if we or our assets are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be one of the assets transferred to or acquired by a third party.
Klik2learn group companies:
We may also share your Personal Information within the Klik2learn family of companies for purposes consistent with this Notice and based on our legitimate interests.
Protection of Klik2learn and others:
We reserve the right to access, read, preserve, and disclose any Personal Information as necessary to i) comply with a law or a court order, ii) enforce or apply our Agreements with you and other agreements, or iii) protect the rights, property, or safety of Klik2learn, our employees, our users, or others.
Disclosures for national security or law enforcement:
Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements, based on our legitimate interests or legal obligations.
We store your Personal Information for different time periods depending on the category of Personal Information. Some information may be deleted automatically based on specific schedules, such as marketing information. Other information e.g. account information, may be retained for a longer period of time based on the Agreement you have with us. Finally, we may further retain information for business practices based on our legitimate interests or legal purposes, such as network improvement, fraud prevention, record-keeping, or enforcing our legal rights.
We use appropriate technical, organisational, and administrative security measures to protect any Personal Information we store from loss, misuse, and unauthorised access, disclosure, alteration, and destruction.
No company or service can guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of a user’s Personal Information at any time. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorised access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
What choices do I have?
You can always opt not to disclose information to us, but keep in mind that some information may be needed to register with us or take advantage of some features of our Services or products.
Marketing communications:
You can opt-out of receiving certain promotional or marketing communications from us at any time by using the unsubscribe link in the emails communications we send, or by filling out a request form. Please note that if you have an account with us and you opt out of receiving promotional and marketing related communications from us, we may continue to send you non-promotional communications, e.g. service-related emails.
Cookies:
You can change your preferences with regards to the cookies and other trackers at any time.
If you would like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), you can click the “GDPR Rights” link located on the bottom of our website and fill out this request form. Our privacy team will examine your request and respond to you as quickly as possible. Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual and may also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our Agreements.
We remind you that you have a right to lodge a complaint with a supervisory authority should you feel unsatisfied with our treatment of your Personal Information. For more information, you can visit the Information Commissioner’s Office website at www.ico.org.uk.
Residents of the European Economic Area or the United Kingdom: If you are a resident of the European Economic Area or the United Kingdom, please see the section titled Additional Information for users in the European Economic Area and the United Kingdom below for further information about your privacy rights.
Personal Information you submit on our Websites or through our Services will be sent to the United Kingdom and processed by us there or in other countries, or stored and processed on our service providers’ cloud servers. Klik2learn’s Learning Platform is hosted in AWS’s data centres in the United Kingdom.
We will always protect your Personal Information in accordance with this Notice wherever it is processed. Klik2learn does not voluntarily or actively transfer or disclose our customers’ Personal Information to the government or law enforcement authorities (the “Authorities”) and/or otherwise grant any Authorities access to your Personal Information. In the event of a request from the Authority, we have procedures and controls in place to make sure that any such request is assessed according to our outlined procedures.
Information for users in the European Economic Area (“EEA”) or in the United Kingdom (“UK”):
Klik2learn Ltd may transfer Personal Information from the EEA or the UK to the United States, including Personal Information we receive from individuals residing in the EEA or the UK who visit our Websites and/or who may use our Services or otherwise interact with us. Please note that the term Personal Information used in this Notice is equivalent to the term “personal data” under applicable European and UK data protection laws for individuals located in the EEA or the UK. When Klik2learn Ltd engages in such transfers of Personal Information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR), or ii) Standard Contractual Clauses issued by the European Commission. The European Commission has determined that the Standard Contractual Clauses provide sufficient safeguards to protect personal data transferred outside the EU or EEA.
Klik2learn Ltd continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.
Following invalidation of the EU-US Privacy Shield Framework, Klik2learn will no longer rely on the EU-US Privacy Shield as a mechanism of international data transfer until further notice.
This section sets out the privacy principles we follow with respect to transfers of Personal Information from the EEA or the UK to the United States, including Personal Information we receive from individuals residing in the EEA or the UK who visit our Websites and/or who may use of our Services or otherwise interact with us.
Please note that for individuals located in the EEA or the UK, the term Personal Information used in this Notice is equivalent to the term “personal data” under applicable European and UK data protection laws.
In compliance with the EU-U.S. Privacy Shield Principles, we are committed to resolve complaints about your privacy and our collection or use of your Personal Information. Individuals located within the EEA or the UK with enquiries or complaints regarding this Notice should first contact Klik2learn: Ann Attridge, Data Protection Officer, dpo@Klik2learn.com.
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of Personal Information within 45 days of receiving your complaint.
Persons who are minors are not eligible to register for Our products or Services. As a minor, if You wish to use Our products or Services, such use shall be made available to You by Your legal guardian or parents, who have agreed to these Terms. In the event a minor utilises the Application/Website/Services, it is assumed that he/she has obtained the consent of the legal guardian or parents and such use is made available by the legal guardian or parents. Klik2learn Ltd will not be responsible for any consequence that arises as a result of misuse of any kind of our Application or any of our products or Services that may occur by virtue of any person including a minor registering for the Services/products provided. By using the products or Services You warrant that all the data provided by you is accurate and complete and that the ‘user’ using the Application has obtained the consent of a parent/legal guardian (in case of minors). Klik2learn Ltd reserves the right to terminate Your subscription and/or refuse to provide You with access to the products or services if it is discovered that you are under the age of 18 (eighteen) years and the consent to use the products or Services is not made by your parent/legal guardian or any information provided by you is inaccurate. You acknowledge that Klik2learn Ltd does not have the responsibility to ensure that you conform to the aforesaid eligibility criteria. It shall be your sole responsibility to ensure that you meet the required qualification. Any persons under the age of 18 (eighteen) should seek the consent of their parents/legal guardians before providing any Information about themselves or their parents and other family members on the Application.
If you believe that a child under 18 may have provided us their Personal Information, without the consent of their legal guardian, please contact us at dpo@Klik2learn.com.
For your convenience, hyperlinks may be posted on the Websites that link to other websites (“Linked Sites”). We are not responsible for, and this Notice does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the Websites. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read each Linked Site’s privacy notice to understand how your Personal Information is used and protected.
We are constantly trying to improve our Websites and Services, so we may need to change this Notice from time to time. We will alert you about material changes by, for example, placing a notice on our Websites and/or by sending you an email (if you have registered your e-mail with us) when we are required to do so by applicable law. You can see when this Notice was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Notice.
For Customers and Learners: Please contact the entity identified on your order form, which may be Klik2learn, or Klik2learn’s customer who is providing a learning service to learners using Klik2learn’s platform.
Data Processor / Controller’s Contact Information:
Klik2learn Ltd
Glasgow, Scotland (Headquarters)
Clockwise, 77 Renfrew St.
Glasgow, G2 3BZ
Scotland, UK
United Kingdom
Klik2learn’s Data Protection Officer:
Ann Attridge
dpo@Klik2learn.com
If you have questions regarding your privacy and rights, please let us know how we can help.
