Effective date 2019-09-01
Why we process your Personal Data
A. Customer Contacts and Software Users
For us to manage our customer relations and to fulfill our commitments to customers, we need information about you in your role as contact person for our customer or as a user of the Offerings. The purposes for processing are:
- Execute agreements with customers
- Provide requested offers to customers
- Deliver in accordance with agreements made with you or the customer
- Offer support to users of the Offerings
- To provide, maintain and improve the Offerings and our other products and services
- Detect, mitigate and prevent security threats and perform maintenance and debugging
- Prevent abuse of the Offerings
- Process orders, invoicing, payments and other financial details
- To communicate directly with you, including by sending you newsletters, promotions and special offers or information about new products and services.
The legal grounds for processing personal data according to the above purposes are i) fulfillment of our contractual obligations and ii) legitimate interest in processing from a business perspective, which we believe do not interfere with your interests. The personal data mentioned in no. 8 above is also processed to fulfill our legal obligations (as we are obligated to keep accounts).
B. Potential Customers
We process personal data about potential customers in order to provide relevant and targeted content. The legal ground for such processing is legitimate interest in processing from a business perspective (direct marketing).
In order for us to monitor access to our premises, we process personal data about visitors to our Websites. The processing is based on our legitimate interest to protect our business secrets, employees and you as a visitor.
Information We Collect
We collect information about you when you (a)register to use the Services and (b) otherwise provide information to us via email, mail, or through our Offerings. Such personal data about you may also be delivered to us by other persons linked to our customer, such as a manager or a colleague.
We may also collect information about you from other sources, such as third-party data aggregators (for example lists of potential customers) or public sources.
- Customer details such as name, title, address, telephone and mobile numbers, email address, date of birth, customer number, purchase and/or service use history and details
- Corporate Customer – contact person details - such as name, title, telephone and mobile numbers, email address, date of birth, customer number, purchase and/or service use history and details
- Financial and transactional details such as items purchased, bank account number, payment transaction information and credit card number
- IT management details such as details of equipment data related to the Services including technical identifiers, user name, location, IP address, contact details, technical events related to the Services including system and application logs and email and communication data and metadata
- Security details such as security log information, facility and system surveillance information and security incident information
- Feedback, comments or questions about Scandlearn or concerning the Offerings
Scandlearn as Data Processor
Scandlearn provides a cloud-based software as a service (SaaS) platform for e-learning and other services. The purposes and means of the processing of personal data related to end-users of Scandlearn’s platforms are determined by Scandlearn’s customers, acting as data controllers. Scandlearn will in these cases act as data processor, in accordance with instructions given by the customer. The relation between the customer as data controller and Scandlearn as data processor shall be regulated by a data processing agreement.
Sharing Your Information with Third Parties and use of Subcontractors
We do not sell, trade, share or transfer your personal information to third parties except when transferring data to other Scandlearn Products and Services.
We do, however, use subcontractors to process personal data and may export your or our customers data outside EU/EEA. Such subcontractors typically provide cloud services or other IT-related services to Scandlearn.
We will enter into data processing agreements when using subcontractors in order to safeguard your privacy rights and to fulfill obligations towards customers. When transfers are made outside the EU/EEA, Scandlearn ensures that such transfers are made under the Privacy Shield (US) or EU model clauses.
Scandlearn currently relies on the following subcontractors to provide business services:
- Hubspot – provider of our Customer Relationship Management (CRM) system
- Amazon Web Services – provider of our technical platform for cloud services
- Stripe Payments Europe, Ltd – provider of our payment services
Other Access to or Disclosure of Your Information
Your Controls and Choices
We may provide you with the opportunity to “opt-out” of having your personal information used for certain purposes when we ask for this information. If you decide to optout, we may not be able to provide certain features of the Offerings to you.
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications or on the Offerings. Please note, however, that you may be unable to opt-out of certain service-related communications.
How We Respond to Do Not Track Signals
Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Offerings do not respond to this type of signal.
Accessing, Storing and Updating Your Personal Information
When you use the Offerings, we provide you with access to your personal information upon your request and either provide you the means to correct this information if it is inaccurate or to delete such information at your request if it is not otherwise required to be retained by law or for legitimate business purposes. You may access, review, correct, update, change or delete your information at any time. To do so, please contact us at [email protected] with your name and the information requested to be accessed, corrected or removed, or if you are using the Service, sign in to your account, go to your profile, and make the desired changes.
We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
Please note that if you cease using the Service or we terminate your access to the Service, you may no longer have the ability to access or update your information.
We retain your information as long as necessary for the stated purpose, to comply with our legal obligations or to resolve disputes. When the personal data we have collected is no longer necessary we will erase it.
No Children Under Age 13
The Offerings are not intended for use by anyone under the age of 13, nor does Scandlearn knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, you may not attempt to register for the Offerings or send any information about yourself to us, including your name, address, telephone number, or email address.
In the event that we confirm that we have collected personal information from someone under the age of 13 without verification of parental consent, we will delete that information promptly. If you are a parent or legal guardian of a child under 13 and believe that we might have any information from or about such child, please contact us by email at [email protected]