elearn.lu treats the privacy of our visitors and users with the highest importance. This policy details the measures that we take to preserve and safeguard your privacy when you visit our website or communicate with our personnel. It also demonstrates how we may process data in accordance with the EU General Data Protection Regulation (“GDPR”).
1) Our Details
elearn.lu is a trading name of Governance People Limited, a company incorporated in the Isle of Man with company number 132347C and registered office at 1 The Church View, Braddan, Isle of Man IM4 4TF.
You can contact us by telephone on +352 2099 0101 or by email to firstname.lastname@example.org with the subject title FAO: Data Protection Officer.
2) Information Collection
We call data that identifies or could reasonably be used to identify you as an individual ‘Personal Data’. This includes information about you that you give us by filling on forms on this site, registering or by corresponding with us by phone, live web chat, email or otherwise. This information may include your full name, job title and contact details including your email address and telephone number.
If you complete a course on our web based platform (learning management system) we may also collect data about your progress in the course, the answers you provide to questions, and the score you achieve. If you provide a rating for a course, you may optionally include your name and email address.
We do not collect or process any special categories of Personal Data.
3) Your Information and how we use it
We collect your data, including Personal Data, for certain legitimate business interests of ours. Processing under this basis may occur in the following circumstances:
- When you make a request for further information on our website, either through a demo form, live web chat, contact form or similar transmission, we will use the data you provide to fulfil your request for information. We will also store this information on our database and use it to follow up with you, either by telephone or through an electronic communication.
- When you register on our website, we will use the data provided to give you access to resources on the website.
- When you subscribe to our newsletter, your email address will be stored with our third party processor, MailChimp, and we will use this to fulfil your subscription request.
- When you interact with our website, we use Google Analytics to better understand your journey and help us provide improvements. Google Analytics may record your geographical location, device, internet browser and operating system, none of which would be classified as Personal Data.
- Where you have provided us with your details, we may contact you to notify you of changes to our services.
When you register on our website, you are also given the opportunity to provide us with your consent. If you choose to do this, then we will use the Personal Data provided with your registration to let you know about our products and services which we think you will find interesting. You will be able to access resources on the website and will be sent relevant email notifications based on your interests. We may also contact you by telephone.
You can subsequently withdraw your consent at any time by contacting us, or following the ‘unsubscribe’ link that is provided in emails from Governance People.
Any information that we process, including Personal Data, will be stored on a secure server. We will not retain your Personal Data for longer than is necessary for the processing. Where you have registered and provided your consent to receive communications from us, then we will retain your Personal Data for this purpose until your consent is withdrawn.
4) Where will Your Information be Shared?
Governance People Limited will share your data to ensure smooth processing of your order and learning experience. Governance People Limited is the Data Controller.
We use third party processors to assist us in storing your data safely and securely while interacting with our website. These third parties are carefully screened so we can ensure that there are adequate controls in place and, where relevant, that such third parties are GDPR compliant. Additionally, where this would result in the transfer of Personal Data outside the EEA, we have confirmed that there are appropriate transfer mechanisms in place.
Our third party processors include:
- Google Analytics (no personal data processed)
- Microsoft Office 365
We may change our third party processors from time to time. This policy will be updated to reflect any changes.
If the course that you purchase is a product from a third-party provider (i.e. not a Governance People branded course), the data held within our Learning Management System may be shared with that provider when you have made a purchase or once you start accessing the course.
5) Your Rights
Under the EU General Data Protection Regulation, you possess a number of rights in relation to your Personal Data. These rights include (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to erasure; (v) the right to restrict processing; (vi) the right to data portability; (vii) the right to object; and (viii) rights in relation to automated decision making and profiling. We are committed to upholding these rights. If you wish to exercise any of these rights, please contact us using the details below.
Where you have provided us with consent, you have the right to withdraw this consent at any time. To reiterate, you can do this at any time by contacting us directly or following the ‘unsubscribe’ link provided in any electronic communications you receive from us.
You also have the right to complain to a supervisory authority where you feel that our processing of your Personal Data has infringed your rights. The supervisory authority in the Isle of Man is the Information Commissioner.
6) Accessing your Information
If you wish to exercise your right of access, then you may make a subject access request by contacting us as per the below. In most cases, we will not charge you a fee and will respond within one month. Fees may be charged for repeated or vexatious requests and we may take two months to provide all information in response to particularly complex requests. We will let you know if this is the case.
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser. They enable the site or service provider systems to recognise your browser and capture and remember certain information, such as items saved in your online shopping basket.
8) Third Party Links
We may sometimes include or offer third party products or services on our website. The websites of these third parties will have separate and independent privacy policies, with which you should familiarise yourself. We bear no responsibility or liability for the content and activities of these third-party sites. Nonetheless, we seek to protect the integrity of our website and welcome any feedback regarding these third-party websites.