1. INTRODUCTION
This Privacy Policy describes how XXXX collects, uses, and discloses information from and about you when you visit and use XXXX.com and XXXX associated websites, applications and virtual learning environments/online campus platforms (collectively, the “Websites”), as well as your ability to control certain uses of that information. It also describes certain data protection rights which apply, subject to applicable law, including a right to object to some of the processing which XXXX carries out. More information about your rights, and how to exercise them, is set out in the Accessing and Managing Your Personal Information section below.If you are a resident of the European Union, United Kingdom or South Africa, you may have additional rights to access, delete and restrict use of your data, as described in this Privacy Policy.
XXXX respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. By accessing or otherwise using the Websites, you agree to the terms and conditions of this Privacy Policy ‒ Cookie Policy constitute XXXX’s terms of use ‒ and to xxxx’s collection, use, and disclosure of your information, as data controller, in accordance with this Privacy Policy, where such agreement is permitted by applicable law.
We regularly review our compliance with this Privacy Policy. Whenever we receive a formal complaint, we make best efforts to contact the person who made the complaint to attempt to resolve their concerns. If you have any questions about the use of your information, or the contents of this Privacy Policy, please contact us at privacy@XXXX.com.
2. Collection of Information
Information You Provide
XXXX collects information from you when you choose to provide it to us. For example, we collect your information when you submit a webform requesting information about one of our course offerings, or otherwise contact us or provide information to us through the Websites. The information we collect may include personal information – such as your name, address, email address, telephone number, date of birth, government issued identifier, prior educational background information, work experience, and the content of any communications that we exchange – as well as non-personal information when you:
- indicate an interest in a Course (you may unsubscribe from promotional emails by clicking “unsubscribe” on the emails you receive from us);
- create an account;
- register for a Course, either directly with us, through your employer, or through some other means;
- communicate with us, for example by submitting queries regarding the Website;
use the Website.
In some cases, we require your personal information in order to perform a contract or to comply with a legal obligation.
Information Automatically Collected
When you visit the Websites or interact with emails that we send to you, we passively collect information from you, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We and our third-party partners use cookies and other technologies to collect information about your visit to the Websites, such as the date and time of your visit, the information you searched to find the Websites, your activity on the Websites, and your clicks on our ads. “Cookies” are small files which may be stored on your computer during your use of the Websites and contain data about your use of the Websites. We use session cookies (which expire when you close your browser) and persistent cookies (which stay on your computer until you delete them or after a specified expiry date) to understand more about your activity on the Websites.
Please see XXXX’s Cookie Policy for details about how we use cookies and other tracking technologies and how you can control the cookies set on your browser.
Tracking Options and Do Not Track
Disclosures
You may adjust your browser to limit tracking or to decline cookies through system settings or the cookie banner shown on the Websites, as applicable. If you choose to limit tracking or decline cookies, however, you may be unable to access certain areas of the Websites. Check the “Help” or “Settings” menu of your browser or operating system to learn how to change your tracking settings or Cookie preferences. Learn more about the use of cookies or other tracking technologies and your choices regarding the use of information collected this way by certain Service Providers (as defined below). On your mobile device, you can adjust your privacy and advertising settings to limit tracking for advertising or to control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers. Please see our Cookie Policy for more information or to opt out.
Our Combination of Your Information
We combine the information we receive from and about you via the Websites and from Other Sources to help us tailor our communications to you and to improve the Websites.
Failure to Provide Personal Information
Failure to provide certain information may make it difficult or impossible for you to access some services through the Websites. You should ensure that personal information submitted to us is accurate and up-to-date. For example, we need a current email address to communicate with you about the Course in which you choose to enroll.
3. How We
Purposes for Collecting and Processing
Personal Information
- To fulfill a contract or take steps linked to a contract, including:
- providing our services;
- verifying your identity;
- communicating with you.
To conduct XXXXX’s business and pursue our legitimate interests in marketing our business, ensuring that we conduct our business in line with our objectives, improving and developing our products and services, and keeping our records accurate and up to date. This includes:
- using your information to provide products and services you have requested and responding to any comments or complaints you may send us;
- personalizing your experience on the Website and in any Course in which you choose to enroll to help us to better respond to your individual needs;
- targeting advertising to individuals with similar interests or characteristics through services offered by third parties;
- developing new products or services or conducting analyses to enhance current products and services;
- reviewing the usage and operations of the Website and analyzing and improving the Websites (we continually strive to improve the Website based on the information and feedback we receive from you);
- contacting you for legitimate business purposes;
- using personal information to invite individuals to take part in market research;
- where consent is not required by applicable law, for direct marketing purposes;
- protecting the security and functionality of the Website, including using personal information you provide to investigate any complaints received from you or from others about the Websites or our products and services.
We conduct balancing tests for the data processing we carry out on the basis of our legitimate interests described above. For more details on the balancing tests we have carried out, please contact us at privacy@XXXX.com. You may also have the right to object to our use of your personal data on the basis of our legitimate interests as described at the outset of this Privacy Policy.
Where you give us consent. This includes:
- where consent is required by applicable law, sending you direct marketing in relation to our relevant products and services, or other products and services provided by XXXXX;
- on other occasions where we ask you for consent, using the data for the purpose which we explain at that time.
For purposes which are required by law. This includes:
- in response to requests by government or law enforcement authorities conducting an investigation;
- using personal information in connection with legal claims, compliance, regulatory and investigative purposes as necessary, including disclosure of such information in connection with legal process or litigation.
For reasons not described in this Privacy Policy where the reason is compatible with the purpose for which we originally collected your information and where such use is lawful.
Processing Information
In some instances, XXXXXX may collect and process your personal information.
Use of De-identified, Aggregate or Anonymized Information
We use de-identified, aggregate or anonymized information to help us analyze the use of the Website. Where permitted by law, this Privacy Policy does not limit our use or disclosure of de-identified, aggregate, pseudonymous or anonymous information, and we reserve the right to use and disclose such information to our partners, advertisers, and other third parties at our discretion.
How We Disclose Your Information
XXXX shares your information with other entities or individuals in the following limited circumstances:
- Service Providers: We share your information with third parties that provide business, professional, or technical support functions for us. In particular, we use third-party providers for website hosting, maintenance, marketing services, courier services, certification services, business operations, payment services, and identity verification services (“Service Providers”). These Service Providers are only given access to your information to the extent necessary to process your information and/or provide services to GetSmarter, and they are prohibited from using or sharing your information for any other purposes. Where permitted by law, GetSmarter discloses limited information about you to Service Providers to serve relevant advertising on third party platforms to you or to other audiences.
- Legal Matters; Safety: We access or share your information to satisfy any applicable law, regulation, legal process, or governmental request; in connection with an investigation on matters related to public safety; as permitted by law; or otherwise as required by law. We may disclose your information to protect the security of the Course, the Websites, servers, network systems, and databases. We may also disclose your information, as necessary, if we believe that there has been a violation of our Terms of Use (including investigation of potential violations thereof), any other legal document or contract related to the Website, or the rights of any third party.
- Fraud; Security: We access and disclose your information to detect, prevent, or otherwise address fraud, security or other technical issues.
- Consent; Other: We share information with third parties when we have your consent.
Information Security and Data Retention
We are committed to protecting the security of your information. We maintain what we believe to be appropriate physical, electronic, and managerial procedures to safeguard and secure your information and to prevent unauthorized access, maintain accuracy, and ensure appropriate use of your information. The accuracy, safety, and security of your information also depend on you. Where we have given you – or where you have chosen – a password for access to any parts of the Websites, you are responsible for keeping this password confidential. We ask that you not share your password with anyone. Even though we do our best to protect your information, the transmission of information via the internet is not completely secure, and we cannot guarantee our security measures. We are not responsible for any unauthorized access to or acquisition of your information.
We retain your personal information for as long as we have a relationship with you. We also may retain your personal information for longer period of time which enables us to:
- Maintain business records for analysis and/or audit purposes;
- Comply with record retention requirements under the law;
- Defend or bring any existing or potential legal claims;
- Address any complaints regarding the services;
- Enforce our commercial agreements; and
- Support our legitimate interests, as described in this Privacy Policy.
Our use of certain personal information is necessary for us to provide information to provide services to you through the Website or otherwise. If you choose not to provide this personal information or request that xxx delete or restrict the processing of this personal information, we may not be able to provide you with other services, including those provided through the Website.
If you believe your rights regarding your personal information have been infringed upon, please contact us privacy@xxx.com.