The Learning People Ltd is “a controller” and The Learning People Ltd (IRE) is “a processor” under the General Data Protection Regulation and the Data Protection Act 2018.
The Learning People Ltd – “the Learning People”, “we”, “us”, “our” – recognises the importance of your privacy and is committed to protecting any personal information we collect about you.
FOR THE PURPOSES OF THIS PRIVACY Promise, THE WORD “YOU” INCLUDES WEBSITE VISITORS, THE LEARNING PEOPLE’S REGISTERED USERS AND PURCHASERS OF THE LEARNING PEOPLE’S PRODUCTS AND SERVICES.
THE PURPOSE OF THIS PRIVACY PROMISE IS TO INFORM YOU ABOUT:
- What personal information about you is collected by the Learning People
- How the information is used
- With whom the information may be shared
- How you can access and change any personal information the Learning People holds about you
- What security procedures are in place to protect the loss, misuse or alteration of your personal information by the Learning People
- How to contact the Learning People
THIS PRIVACY PROMISE APPLIES TO ANY PERSONAL INFORMATION YOU PROVIDE US:
- When visiting the Learning People website
- When using the Learning People’s online services
- When entering into an agreement with the Learning People and/or another third party
- When you request the Learning People forward information about yourself to third party credit providers for loan or credit application purposes
- When you correspond, or communicate with the Learning People over the telephone or in any other manner including by letter, facsimile or email
- In addition to collecting personal information directly from you, we may also obtain personal information about you from third party sources such as our training providers and other third party service providers
Failure by you to provide personal information when requested by the Learning People may mean that we are unable to provide certain services and products to you.
WHAT TYPES OF INFORMATION DO WE COLLECT?
The Learning People gathers three types of information about you, namely:
- Aggregated information generated by our systems – or third party systems – to track our website traffic but that which does not identify you personally; and
- Personal information about you such as your name, contact information, including email address, and in some cases, your billing details and general financial and credit information
- Other information relevant to customer surveys and/or offers
The type of information that the Learning People collects about you is dependent on how you use the services offered on our website and the products you are interested in purchasing through the Learning People.
Generally, the Learning People does not collect ‘sensitive information’ about you.
Sensitive information includes – but is not limited to – information about your race or ethnic origin, your religion and your sexual preferences.
The Learning People will only collect sensitive information about you in the event that it is necessary for the purpose of providing you with a product or service.
In such circumstances, the Learning People will only collect sensitive information with your consent unless we are required by law to collect such information from you.
COLLECTION OF AGGREGATE DATA
The Learning People also collects non personal information in aggregate form to track data such as the total number of visits to our website, the number of visits to specific areas of our website and the domain names of our website visitors’ internet service providers.
We use this information, which remains in aggregate form, to understand how our website visitors use our website so that we can constantly improve and enhance our services.
We may also share this information with our training providers for the purpose of providing you with optimal online career management services.
Your Internet Provider – IP – address
The Learning People’s web servers provide us with your IP address – this assists us in the diagnosis of problems and or support issues with our services.
COOKIES AND APPLETS
The Learning People uses ‘cookies’ and ‘applets’ in its website systems. These enable you to use services such as free demonstrations of our training courses. You are able to disable cookies and applets via your computer’s web browser however this will restrict access to some web pages and services within the Learning People’s website.
HOW WE COLLECT INFORMATION
The Learning People may collect personal information about you when you visit our website and you elect to use our online services when you register as a Learning People Registered User. Personal information may also be collected when you enter into a contract with the Learning People, facilitate with our CV Detox and StudentCare services and when you deal with the Learning People over the telephone or correspond with the Learning People via facsimile, letter or email or any other mode of communication.
The Learning People may also collect personal information about you from our training providers and other third party service providers.
HOW WE USE YOUR PERSONAL INFORMATION
The Learning People may use your personal information for one of the following purposes, subject to your opt-in preferences:
- to communicate with you, including via email newsletters
- to facilitate and process contracts between yourself and the Learning People and/or third parties
- to identify the number of people using the Learning People’s website services and establish the nature of their interests
- to facilitate the Learning People registration
- to conduct the Learning People marketing activities
- to provide you with information about the Learning People and its services and products
- to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
The Learning People may disclose your personal information to our training providers in order to facilitate your enrolment in a selected training course.
In some instances, including for example, where you require financial assistance, the Learning People may collect personal information about you – including financial and credit information – to pass on to the Learning People’s preferred credit suppliers for loan and/or credit application purposes.
The Learning People will only pass on this information where you have expressly consented to allow the Learning People to do so on your behalf.
Credit Suppliers may require a range of additional personal information for loan application purposes which is not specified in this Privacy Promise.
You will be read and must consent to the Credit Supplier’s privacy terms before the Learning People will pass on your personal information to the Credit Suppliers.
The Learning People may also disclose your personal information to third party contractors who perform services for us including the management and maintenance of our information systems.
Where your personal information is passed on to third party contractors, the Learning People takes reasonable steps to ensure that these individuals and/or organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
Other than as outlined above, the Learning People will not disclose your personal information without your consent unless disclosure is necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.
ACCESS TO AND CORRECTION OF INFORMATION WE HOLD ABOUT YOU
Upon your request, the Learning People will provide you with access to your personal information unless there is an exception which applies under the General Data Protection Regulation, Data Protection Act 2018 and The Privacy and Electronic Communications – EC Directive – Regulations 2003. If we deny such access, we will tell you why.
The Learning People may recover any reasonable costs incurred in providing you access to the requested information.
To request access to your personal information, please contact the Learning People using one of the contact options provided in our Privacy Promise.
If you are a Learning People Registered User, you can access your registered profile at any time.
KEEPING INFORMATION UP TO DATE
The Learning People strives to ensure that the information we hold about you is accurate, complete and up to date at all times.
If the personal information we hold about you is inaccurate, incomplete, or no longer up to date, or you wish for your details to be removed from the website, please contact us at email@example.com so that we may take reasonable steps to address this and/or discuss alternative options with you.
STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
The Learning People takes reasonable steps to protect the security of your personal information in accordance with this Privacy Promise.
The Learning People regularly reviews and implements new security and encryption technologies. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.
Whilst the Learning People strives to protect such information, we cannot ensure or warrant the security of any information you transmit to us or obtain from our online products or services.
Accordingly, use is at your own risk.
Once any personal information comes into our possession, we will take reasonable steps to protect that information from misuse and loss and from unauthorised access, modification or disclosure.
In the event of a personal breach we have in place procedures to ensure that the effects of such breach are minimised and shall liaise with the ICO and with you as appropriate.
More information is available from the data protection officer.
LINKS TO OTHER WEBSITES
The Learning People website contains links to other websites.
Please note that these links are intended for your convenience only.
Links to third party websites do not constitute endorsement, sponsorship or approval by the Learning People of the content, policies or practices of those third party websites.
If you have any concerns regarding your privacy when visiting a linked third party, you should ensure that you check the privacy statement/policies of those websites.
DESTRUCTION OF YOUR PERSONAL INFORMATION
The Learning People will take reasonable steps to destroy or de-identify any personal information about you once the information is no longer required for the purposes for which it was collected or as authorised or required by law.
CHANGES TO THE LEARNING PEOPLE PRIVACY PROMISE
From time to time, the Learning People may make changes to this Privacy Promise.
Accordingly, we encourage you to periodically review this promise to remain informed about how we collect and protect your personal information.
Your continued use of the Learning People website constitutes your acceptance of the collection, use and disclosure of your personal information to the extent outlined in this Privacy Promise as amended from time to time.
For further information about the protection of your privacy, please visit the Information Commissioner’s Office website at www.ico.gov.uk
FEEDBACK AND QUESTIONS ABOUT PRIVACY AND THE LEARNING PEOPLE WEBSITE
The Learning People welcomes ideas and feedback about all aspects of the Learning People website. This feedback may be used to administer and refine the services we provide and may be shared with the Learning People partners either in aggregate form or with specific identifying characteristics removed.
If you have any questions regarding this Privacy Promise, practices of the Learning People website or your dealings with the Learning People, you can contact us in the following ways:
Email: Andy.firstname.lastname@example.org, Head of Operations
Phone: 01273 037 130
The Learning People Ltd
Brighton and Hove
The Learning People Ltd ICO registration number: ZA027202
The Learning People Ltd (IRE) ICO registration number: ZA213999
Alternatively you can contact the Information Commissioner’s office, details available at www.ico.org.uk