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\nLearning Technologies Group Plc. its subsidiaries, and its associated businesses (\u201cLTG\u201d, \u201cwe\u201d or \u201cus\u201d) are committed to protecting and respecting your privacy. <\/span>The Learning Technology Group companies includes the following entities: LEO Learning, LEO GRC, Preloaded, Affirmity, Gomo Learning, Rustici Software, PeopleFluent, Watershed, VectorVMS, Breezy, Instilled, Open LMS, and GetBridge. <\/span>We provide this privacy notice (\u201cPrivacy Notice\u201d) to explain how we collect, use and disclose certain personal information online via our group websites, and our SaaS or Subscription Services (as listed below, collectively referred to as \u201cSites\u201d).<\/span><\/p>\n This policy sets out the basis on which personal data is collected from you either through our Sites or our Subscription Services (collectively “our Sites\u201d). Please read the policy carefully to understand our practices regarding our collection and use of your personal information and how it will be treated.<\/span><\/p>\n If you have any questions regarding our privacy practices or this Privacy Notice, please contact us using the contact details given below.\u00a0\u00a0<\/span><\/p>\n This Privacy Notice describes how we use \u201cyour\u201d information. To understand which of our uses of information are actually applicable to you and your information see the following useful definitions.<\/span><\/p>\n You may be a(n):\u00a0<\/span><\/p>\n Customer \u2013 <\/b>an entity, or person representing an entity that has an agreement in place with LTG or one of its subsidiaries under which we provide you with SaaS or Subscription Services, or is visiting our Site to purchase SaaS or Subscription Services via an online payment system.<\/span><\/p>\n End-User <\/b>\u2013 a person with a user account to one of our Customer\u2019s instances of our SaaS or Subscription Services. For example, you may be a user of your workplace or educational institution\u2019s Learning Management System, of which we are the provider. Or you may be an applicant to your employer or prospective employers recruitment system, of which we are the provider.\u00a0<\/span><\/p>\n Visitor <\/b>\u2013 a person who is visiting our website, or has expressed an interest in our products or services by filling in a contact form or sign-up sheet in relation to an event or webinar, or has had conversations about our products with our sales team and provided them with your details.<\/span><\/p>\n Please select the correct option based on the above definitions to access the information applicable to you and your information.<\/span><\/p>\n Our Agreement with you is the best source of information on which personal data we process for you and how we use and protect that personal data. We encourage you to familiarize yourself with the terms of our agreement and reach out to your account manager if you have any questions.\u00a0<\/span><\/p>\n If you make a purchase via one of our Sites, or by clicking the \u201cPay by Debit or Credit Card\u201d link in one of our emails or invoices (\u201cOnline Payments\u201d), this section shall apply.\u00a0<\/span><\/p>\n When you click the \u201cPay\u201d or \u201cpay by credit or debit card link, you will be taken to another site, managed by our payment processor in order for your payment to be processed. Your personal data will be securely encrypted and for further information upon this details of the privacy policy of our payment processor(s) are set forth below, and if applicable, in the email informing you of how to pay by credit or debit card. When you click on this link we will receive details of your IP address. You will be required to provide your payment details, which will be made available to a third party payment gateway and merchant bank to process the transaction. We will not receive and\/or store your payment details, but once you have made payment we will receive confirmation that your payment has been processed and with certain details regarding the transaction including the amount paid you will be required to provided your payment details We are required to retain a copy of the transaction details for up to 7 years; however, this does not include card data.\u00a0<\/span><\/p>\n For further information regarding the payment providers used on each of our sites, please see below. Please note that we are not responsible for the privacy practices or the content of such web sites, and this Privacy Policy does not apply to such sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every site that collects personally identifiable information.<\/span><\/p>\n For payments made at <\/span>www.breezyhr.com<\/span><\/a>, we use Stripe (<\/span>www.stripe.com<\/span><\/a>) as our payment provider. Stripe protects your personal data as described in their privacy policy, which can be found here: <\/span>https:\/\/stripe.com\/gb\/privacy<\/span><\/a>. Your personal data will only be used by Stripe for the purposes of processing your payment, and will be securely encrypted.\u00a0<\/span><\/p>\n For payments made at <\/span>www.gomolearning.com<\/span><\/a>, we use Recurly (<\/span>www.recurly.com<\/span><\/a>) as our payment gateway. Recurly uses several layers of encryption to protect your data, as detailed in their Security policy (<\/span>https:\/\/recurly.com\/security\/<\/span><\/a>). Recurly sends your encrypted data onto our merchant bank, to verify the transaction. We use Stripe (<\/span>www.stripe.com<\/span><\/a>) as our merchant bank, and they protect your personal data as explained in their Privacy Policy. Once Stripe has received authorisation that the transaction is complete, it sends this information back to Recurly, which informs you and us that your transaction is complete.\u00a0 Your personal data will only be used by Recurly and Stripe for the purposes of processing your payment, and will be securely encrypted.\u00a0<\/span><\/p>\n For payments made at <\/span>www.peoplefluent.com<\/span><\/a>, or by invoices sent by Affirmity, PeopleFluent, or VectorVMS, we use Adyen (<\/span>www.adyen.com<\/span><\/a>) as our payment processor Adyen.\u00a0 Adyen\u2019s privacy policy can be viewed at <\/span>https:\/\/www.adyen.com\/policies-and-disclaimer\/privacy-policy\/update-statement<\/span><\/a>. Your personal data will only be used by Stripe for the purposes of processing your payment, and will be securely encrypted<\/span><\/p>\n We have been provided with your information, and handle your information subject to an agreement with one of our clients. Our client may be your employer (or an affiliate of your employer), a prospective employer to whom you have submitted a job application or resume, your educational institution, or another company which has either given you or asked you to sign up for an account with one of our Sites. Our client acts as \u2018data controller\u2019 for your information, and we act as \u2018data processor\u2019. This means that we do not determine how we collect or use your data. Our client determines how we collect or use your data, and provides us with instructions on what to do with it in our agreement with them. We only collect and use your data in accordance with the agreement between us and our client. Further to this,\u00a0<\/span><\/p>\n Our client is responsible for the management of your account on our Site. If you have any questions or concerns regarding our use or collection of your data, or if you wish to make a request to exercise your rights as a data subject or a consumer (as explained below), please reach out to our client as they are best placed to assist you.\u00a0<\/span><\/p>\n Your information will either have been provided to us by our client if they have set your account up for you, or provided to us by you where our client has invited you to set up an account or submit information such as a resume.\u00a0<\/span><\/p>\n This depends upon which of our Sites you are using, and how our client is using our Site to collect your information. Broadly, the types of data we collect may include:\u00a0<\/span><\/p>\n If you require more information about which of your information we use, please contact our client as they can advise you on which of your information they have used our Site to collect.\u00a0<\/span><\/p>\n We only use your information to provide our services to our client in accordance with the agreement between us and our client. Our services to our client include the routine activities of providing cloud based services such as hosting, support, and maintenance. The majority of the time we have no need to access any individual\u2019s information to provide these Services. There are only certain scenarios in which we would ever need to access your information. These scenarios largely are based around providing technical support to your or our client, in which case we may need to access your information to identify or resolve a technical issue. We will only ever access your information to the extent required, and with the permission of our client.\u00a0<\/span><\/p>\n For more information about how we or our client use your information, please contact our client as they are best placed to provide you with this information.<\/span><\/p>\n All of your information is stored on secure servers, with layers of security to keep your information protected. The location of the server on which your information is stored depends on which of our Sites you are using, and also on what we have agreed with our client. The length of time for which we store your information is also determined by our agreement with our client. Our client as the \u2018data controller\u2019 is responsible for determining both of these things.<\/span><\/p>\n For more information about where and for how long we store your information, please contact our client as they are best placed to provide you with this information.<\/span><\/p>\n You directly provide us with the data that we collect. We collect data and process data when you:<\/span><\/p>\n Data collected via online forms will advise which fields are mandatory and which are optional.<\/span><\/p>\n The types of information we may collect through our Sites includes:<\/span><\/p>\n A visitor to our Sites who is not seeking employment or expressing interest in purchasing products or services is not required to reveal any personal information, provided that the applicable Site Cookie policy applies to all visitors.<\/span><\/p>\n We use information in the following ways:<\/span><\/p>\n Once we receive your information, it is subject to strict security measures in accordance with applicable law. We may transfer personal information to companies that help us to provide our Services and that we believe offer a secure solution that improves our Service delivery. We may also transfer personal data to our affiliates and partners.\u00a0<\/span><\/p>\n If you are a system user of one of our customers and have questions regarding the processing of your personal information, please contact our respective customer directly as they control the handling of your data.<\/span><\/p>\n Our site uses cookies to distinguish you from other visitors to provide you with a better experience and to help us improve our site. A cookie is a small data file placed on the hard drive of your computer when you visit a website.\u00a0<\/span><\/p>\n Our site may use session cookies, persistent cookies, and web beacons. A “session cookie” expires when you end your session (i.e. close your browser).\u00a0 A “persistent cookie” stores information on your hard drive so when you end your session and return to the same website at a later date, the cookie information is still available. A “web beacon” is a small string of code that represents a clear graphic image, a redirect URL or JavaScript and is used in conjunction with a cookie. The cookies we place on our server are readable only by us, and cookies cannot access, read or modify any other data on your computer. We may use web beacons alone or in conjunction with cookies to compile information about your usage of our site and interaction with emails from us. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our site, in order to improve our site and email communications.<\/span><\/p>\n We use Cookies for several purposes. Please see information below on each of these purposes.<\/span><\/p>\n We use preference cookies to collect information about your choices and preferences, and to allow us to remember language or other local settings and customize our site accordingly.<\/span><\/p>\n We also use analytics cookies to collect information about your use of our site, and to enable us to improve the way our site works. For example, analytics cookies show us which are the most frequently visited pages on our site, help us record any difficulties you have with our site, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on our site, rather than the usage of a single person. We use the information to analyse the site traffic, but we do not examine this information for individually identifying information.\u00a0<\/span><\/p>\n We use Remarketing with Google Analytics to advertise online. Third party vendors, including Google, may show our ads on sites across the internet.\u00a0<\/span><\/p>\n We, and third party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to our website. Remarketing cookies used by us expire after 30 days. To opt out of Remarketing or to control your ad preferences, please <\/span>click here<\/span><\/a>.<\/span><\/p>\n Most web browsers have a “help” menu where you can review how to prevent your browser from accepting new cookies, how to have your browser alert you when you receive a new cookie or how to fully disable cookies on your browser. You can learn more about cookies at sites like www.aboutcookies.org. If you use your browser settings to block all cookies, you may not be able to access all or parts of our site.<\/span><\/p>\n In addition to the cookies that we own, we may also use third-parties cookies on our Sites for the purposes detailed above.\u00a0<\/span><\/p>\n As the owners of these cookies, you are entitled to information from these third parties regarding their privacy and security policies, and on how to opt-out from their cookies. You can find more information on our third party cookie providers below:<\/span><\/p>Who are \u201cYou\u201d?<\/span><\/h1>\n
Your Information<\/span><\/h1>\n
Customer Information<\/span><\/h2>\n
Online Purchases<\/span><\/h3>\n
Breezy HR Payments:\u00a0<\/span><\/h4>\n
Gomo Payments<\/span><\/h4>\n
PeopleFluent Payments<\/span><\/h4>\n
End-user information<\/span><\/h1>\n
How do we collect your Information?<\/span><\/h2>\n
Which Types of Information do We Collect?<\/span><\/h2>\n
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How Do We Use Your Information?<\/span><\/h2>\n
Where We Store Your Information and for How Long<\/span><\/h2>\n
Visitor Information<\/span><\/h1>\n
How Do We Collect Your Information?<\/span><\/h2>\n
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Which Types of Information do We Collect?<\/span><\/h2>\n
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How Do We Use Your Information?<\/span><\/h2>\n
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Cookies and Other Tracking Technologies<\/span><\/h1>\n
Types of Cookies<\/span><\/h2>\n
Purposes of Cookie use<\/span><\/h2>\n
Preference Cookies<\/span><\/h3>\n
Analytics Cookies<\/span><\/h3>\n
Marketing Cookies<\/span><\/h3>\n
Controlling Cookies<\/span><\/h3>\n
Third Party Cookie providers<\/span><\/h2>\n