PRIVACY POLICY

A. Personal Information We Collect

When you first sign up to use our Service, our sign-up form requests you to provide your first name, last name, and email address and possibly other contact information. We, and/or our contractors, collect and store any information you choose to put in an email or contact form you send us.

We may also collect user name, phone number, gender, country, county, city, town, profile picture, user ID, universally unique identifier, and data communicated while using the Service.

We, and/or our contractors, also collect data on how our Service is used: for example, number of page visits and duration, type of browser. This “usage data” includes what some jurisdictions consider personal information, like visitors’ devices’ Internet Protocol (“IP”) addresses (which include general location).

Some of this usage data may come through “cookies” and other technologies. A cookie is a string of data our Service sends your device and then uses to identify that device when used to return to our Service. You can set up most browsers to refuse all cookies, or to notify you of any cookies you receive. (Do be aware that if you don’t accept certain cookies, you won’t be able to make as efficient use of many websites, including ours). You can also select an option to reject non-essential cookies, and we provide you with that selectable option when you access our platform.

Our Service is not meant to collect information from anyone under age 18. If you know of children’s information collected through our Service, please contact us at info@learn.ink.

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B. Our Use Of Personal Information

We use your personal information to reply to messages you send us via email, live chat or through our contact forms, and to otherwise correspond with you. Also, if you send us a contact form or other information, we’ll put your name and email address and any other contact information you provide on our notices list(s), so that you get email or other notice of future communications and announcements from us. (You can unsubscribe when you receive one of those announcements, or at any time by contacting us at the email address below.)

We use cookies and other technologies – including the personal information they collect – so that, for example, our Service can remember your device(s) and give you the information you’re most likely to need. We also use information gained through cookies and other technologies to compile statistical information about use of our Service, such as the pages users visit most often, and for security purposes. Finally, we use personal information collected by cookies and other technologies on our Service for tracking, as explained below.

User Tracking and Do Not Track Notice: As described in more detail below, we and/or some of our contractors may track certain users across third party websites, in order to advertise to them elsewhere, beyond our Service. That tracking includes certain personal information (i.e., IP address). See Section F, and Appendix A below as to our contractors.

Do Not Track (“DNT”) is a setting in a web browser (but for which there is no universal standard) that expresses a preference that websites not track your on-line behaviour elsewhere. Our Service does not respond to DNT signals or turn off tracking.

The data concerning the user is collected to allow us to provide the Service, comply with our legal obligations, respond to enforcement requests, protect our rights and interests(or those of our users or third parties), detect any malicious or fraudulent activity, as well as the following: Content commenting, Registration and authentication, Analytics, Displaying content from external platforms, Registration and authentication provided directly by this Application, Hosting and backend infrastructure and user database management. 

For specific information about the personal information used for each purpose, the user may refer to the section “Detailed information on the processing of Personal Data” in Appendix A.

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C. Mode and Place of Processing the Data

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the personal information.

The processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. Personal data is stored in secure cloud servers that are encrypted at rest. Any data stored on employee computers (such as emails) is protected by secure passwords. In addition to us, in some cases, the personal information may be accessible to certain types of persons in charge, involved with the operation of the Service (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. The updated list of these parties may be requested from us at any time.

Legal basis of processing

 We may process personal information relating to users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations we may be allowed to process personal information until the user objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of the personal information is subject to European data protection law;
• provision of data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of the personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

Place

The data is processed at our operating offices and in any other places where the parties involved in the processing are located.

Depending on the user's location, data transfers may involve transferring the user's data to a country other than their own. To find out more about the place of processing of such transferred data, users can check the section containing details about the processing of personal information/data.

Users are also entitled to learn about the legal basis of data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard their data. If any such transfer takes place, users can find out more by checking the relevant sections of this document or inquire with us using the information provided in the contact section.

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D. Retention of Personal Information

We retain your personal information so long as it serves the purposes listed in this Privacy Policy, including to send you notices and other general messages (unless you’ve unsubscribed), to collect and monitor traffic and other usage statistics at our Service, and to comply with our legal obligations.

We may be allowed to retain personal information for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn.

Once the retention period expires, personal information will be deleted.  Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

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E. Transfer of Personal Information

We may store or process your data outside your city, province, state, or country, including through one of our contractors (described below).So your personal information may be stored in a jurisdiction that operates under privacy and data protection laws different from (and potentially less protective than) those of your home jurisdiction.

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F. Contractor and Other Third-Party Access to Personal Information

We may disclose personal information to attorneys or law enforcement authorities to address contract violations or illegal behaviour, or to enforce our rights. We disclose information demanded in a court order, subpoena, or otherwise required by law, or to prevent harm to persons or property. We may share personal information in connection with a corporate transaction, like a merger or sale of our company, the sale of most of our assets, or a bankruptcy.

Certain contractors can access data we collect, including personal information.

Our contractors help us with hosting and storage of this Service, monitoring Service use, marketing to and communications with Service users and payment processing. Except where explicitly stated to the contrary in this Policy, in some cases, particularly given the limited amount and type of information and data collected through our Service we have not restricted contractors’ own use or disclosure of that information or data. We are not responsible for the conduct or policies of our contractors (including plugins, webinar hosts, and webinar payment processors).

Finally, as noted above, we compile Service/Website usage statistics from data collected such as through cookies. We may publish those statistics or share them with third parties.

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G. Protection of Personal Information

We do not directly store the personal information that may be included in usage data collected by cookies and other mechanisms at our site(with exceptions described below). The data we don’t store ourselves is collected and stored by our contractors, including Google, under their policies and procedures. See Appendix A below for information on those contractors and their policies.

We do store information you send us via email, live and chat and through contact forms (such as your contact information). We keep that information on password-protected computers and share it only with contractors who have agreed to use it only as we instruct.

Unfortunately, neither we nor any website can guarantee the security of personal information or other data, including during transmission and storage. Use of the Service is at your own risk.

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H. Accessing and Correcting Your Personal Information

You can access and change contact information we store about you by emailing us at info@learn.ink.

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I. Special Notices Related to Privacy Laws

We provide this Privacy Policy in the interest of transparency to our Service users. Doing so is not intended to suggest, and does not mean that, legal responsibilities apply that would not otherwise. Legal protections for personal information (and even what information is governed) are not the same in all jurisdictions and are rapidly evolving and complex. Simply put, not all laws, including collection notice requirements, apply to all entities, individuals, or information, in all locations, or in all circumstances.

For example, our Service is for business (not personal, family, or household use), and as such is not regulated by certain on-line privacy laws(such as California’s Shine the Light law and Online Privacy Protection Act(“Cal-OPPA”)). Additionally, our Service is not a “business” as so defined and regulated by the California Consumer Privacy Act (“CCPA”). Without conceding that either the CCPA or any data privacy law outside the United States (for example, those applying in the European Economic Area (“EEA”), Switzerland, the United Kingdom, or Brazil) applies to data including personal information collected through our Service:

1. We process (use) the personal information you give us by emailing us, through live chat or in contact forms (email address, other information you choose to provide) because, by contacting us and providing that information, you have authorized us to use it. We (and/or our contractors)process usage data, like number of page visits and IP addresses. That data is used for to, for example, understand usage of and manage our Service (our legitimate interest), and otherwise as described in and pursuant to your consent to this Policy. As noted elsewhere in this Policy, we also process personal information wherever we have a legal obligation, for instance, if it is subpoenaed.

2.Individuals in certain jurisdictions outside the United States (for example “data subjects” in the EEA) have rights as to certain entities processing their “personal data” (for example, as defined by the European Union’s General Data Protection Regulation (“GDPR”)) including, for example, to access, update, or delete it; to have it altered if inaccurate or incomplete; to object to processing or request a company restrict how it is processed; to withdraw consent to processing; to receive a copy, in a structured, machine-readable, and commonly used format; to complain to a data protection authority (a government agency) about management of personal data.

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J. The Rights of Users

Users may exercise certain rights regarding their data/personal information processed by us.

In particular, users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their personal information/data.
• Object to processing of their data. Users have the right to object to the processing of their data/information if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected.
• Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, we will not process their data for any purpose other than storing it. 
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from us.
• Receive their Data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on the user's consent, on a contract which the user is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

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Details about the right to object to processing 

Where personal data or information is processed for a public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether we are processing personal data for direct marketing purposes, users may refer to the relevant sections of this document. 

How to exercise these rights

Any requests to exercise user rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month. 

Throughout this document we are assuming that we are the owner or controller of the personal information/data.  If instead, the organisation to which you are affiliated is the owner or controller, then the organisation should be substituted for us in appropriate statements throughout.

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K. Amendment of this Privacy Policy

We may change this Privacy Policy at any time by posting a new version on this page or on a successor page. The new version will become effective on the date it is posted, which will be listed as the new Effective Date. Via a “cookie banner” appearing each time the Service is accessed, users are invited to view (and are deemed to have accepted and agreed to) the Privacy Policy.

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L. Contact Information

For questions about this Privacy Policy, including if you believe you have legal rights related to our Service not addressed here (which requests we will evaluate and comply with to the extent required under then-applicable law), or to unsubscribe from communications, please contact us at info@learn.ink.  Our mailing address is Square Works, 17-18 Berkeley Square, Bristol, BS8 1HB, United Kingdom. Finally, please do not provide us personal information about others unless you have their permission.

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Latest update: August 13, 2022