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Award Learning Services Ltd – Privacy Policy

1. Introduction

This Policy details our commitment to protecting the privacy of individuals who:
a. visit our Websites (defined below) (“Website Visitors”) or individuals who request us to contact them via our online web forms;
b. who register to use the products and services which we market for subscription (available at www.awardls.com, www.onprogramme.com, www.testvq.com, www.learnvq.com, (the “Service(s)”); or
c. attend or register to attend sponsored events or other events at which AwardLS participates (“Attendees”).

For the purposes of this Policy, the term “Websites” shall refer collectively to www.awardls.com website and websites that AwardLS operates and that link to this Policy. This Privacy Policy describes how AwardLS collects, uses, shares and secures the personal information that you provide. It also describes your choices regarding use, access and correction of your personal information.

1. Scope Of This Policy

When this Policy does not apply – Third Party Business Subscribers:

Our Services are intended for use by businesses such as, but not restricted to, colleges, training companies and elearning providers. Where our Services are made available to you through a business that contracts with AwardLS (Subscriber), that business is the data controller of your personal information. AwardLS is not responsible for our Subscribers’ privacy or security practices which may be different to this Policy.

Subscribers to our Services are solely responsible for establishing policies for, and ensuring compliance with, all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals (also referred to as “data subjects”) with whom our Subscribers interact. If you are an individual who interacts with a Subscriber using our Services, then you will be directed to contact our Subscriber for assistance with any requests or questions relating to your personal information.

When this Policy does not apply – Third party websites:

Our Websites may contain links to other websites. The information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

3. Information That You Provide To Us

Account and Registration Information:

We ask for and may collect personal information about you such as your name, address, phone number, email address, social media account ID’s, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Services (an “Account”). We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with Your Account. We base the processing of your personal information on our legitimate interest to provide you with the necessary functionality required during your use of our Service(s);

We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us.

Other Submissions:

We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including: elearning, quizzes, contests, promotions, requesting customer support, or otherwise communicating with us. We process your personal information to perform our contract with you for the use of our websites and the Service(s) and to fulfil our obligations under the Services Agreement to You; where we have not entered into the Services Agreement with you, we base the processing of your personal information on our legitimate interest to operate and administer our websites and to provide you with the content you access and request.

Attendee Information:

We ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which any member of AwardLS participates, in order to facilitate your registration or attendance at an event, including sending related communications to you.

4. Information That We Collect From You on our Websites

Cookies and Other Tracking Technologies:

We and our authorized partners may use cookies and other information gathering technologies for a variety of purposes. These technologies may provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites.

We may use web beacons, tags and scripts on our Websites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

We use Local Storage such as HTML5 and Local Shared Objects (“LSOs,” also known as Flash cookies) to store content information and preferences. Various browsers may offer their own management tools for removing HTML5.

Logs:

We gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.

Analytics:

We collect analytics information when you use the Websites to help us improve them, including through the use of cookies. We may also share aggregated and/or anonymized data about your actions on our Websites with third-party service providers of analytics services.

5. Information Collected From Other Sources

Social Media Widgets:

The Websites include social media features, such as the “Facebook Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our Websites. These features may collect your Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Information From Services Provided by Third Parties:

We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Websites. For example, we may have access to certain information from a third party social media provider. Any access that we may have to such information from a third party social media provider is in accordance with the authorization procedures determined by that service. If you authorize us to connect with a third party service, we will access and store your name, email address, current city, company, and other personal information that the third party service makes available to us, and use and disclose it in accordance with this Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services.

6. How We Use Information That We Collect

General Uses:

We may use the information we collect about you (including personal information, to the extent applicable) in order to perform our obligations under our Services Agreement with you and on the basis of our legitimate interest including to (a) provide, operate, maintain, improve, and promote the Websites and the Services; (b) enable you to access and use the Websites and the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners; (f) process and deliver contest entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Websites and the Services, and other illegal activities; (i) personalize the Websites and Services; and (j) for other purposes for which we obtain your consent.

Legal basis for processing (EEA visitors only):

If you are a visitor from the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we need the personal information to perform a contract with you (e.g. to provide you with our Services), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your personal information. If we process personal information in reliance on your consent, you may withdraw your consent at any time.

If you have questions about, or need further information concerning, the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” section below.

7. Sharing Of Information Collected

Third-Party Service Providers:

We share information, including personal information, with our third-party service providers that we use to provide hosting and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.

Testimonials:

From time to time, we may post testimonials on the Websites that may contain personal information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at admin@awardls.com

8. Other Important Privacy Information

Notice to End-Users

Our Services are intended for use by businesses such as, but not restricted to, colleges, training companies and elearning providers. Where our Services are made available to you through a business that contracts with AwardLS (Subscriber), that business is the data controller of your personal information. Your data privacy questions and requests should initially be submitted to the AwardLS Subscriber in its capacity as your data controller. AwardLS is not responsible for our Subscribers’ privacy or security practices which may be different to this Policy.

AwardLS Subscribers are able to:

Data retention

Where AwardLS is the data controller of personal information (for example, personal information relating to Website Visitors, Attendees and individuals who register to use our Services), then we retain the personal information we collect where we have an ongoing legitimate business need to do so (for example, to provide you with our Services, to enable your participation in an event, and to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or aggregate it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

If your personal information is processed within a Subscriber’s Service Data, we will process the personal information for as long as we are instructed to do so by the relevant Subscriber that is the data controller of the Subscriber Service Data.

9. How to Exercise Your Data Protection Rights

You have certain choices available to you when it comes to your personal information.

Correcting, updating and removing your information:

An individual who seeks to exercise their data protection rights in respect of personal information stored or processed by us on behalf of a Subscriber of ours within the Subscriber’s Service Data (including to seek access to, or to correct, amend, delete, port or restrict processing of such personal information) should direct his/her query to our Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the personal information, we will respond to their request within thirty (30) days. We will retain personal information that we process and store on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers.

Accessing and updating or deleting your information:

In cases where we act as the data controller of your personal information, we will provide you with information about whether we hold any of your personal information upon request. We will respond to such requests within thirty (30) days. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

Request that we stop using your information:

You may request that your personal information no longer be accessed, stored, used and otherwise processed where you believe that a AwardLS or an AwardLS Subscriber do not have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this Policy. Where you gave us consent to use your personal information for a limited purpose, you can contact us to withdraw that consent. You can also opt-out of our use of your personal information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. Please note that an End-User of an AwardLS Subscriber should first contact the AwardLS Subscriber with a request to stop access, storage, use of personal information. If there is delay or dispute as to whether we have the right to continue using your personal information, we will restrict any further use of your personal information until the request is honoured or the dispute is resolved, provided the AwardLS Subscriber does not object (where applicable).

Opt-out of communications:

We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may contact admin@awardls.com and provide the names/email addresses you would like to be removed from our marketing databases and added to our ‘Do Not Contact’ list. You may opt-out of receiving promotional communications from us by using this unsubscribe link within each email. Even after you opt-out from receiving promotional messages from us, if you are a subscriber, then you will continue to receive billing and invoicing messages from us regarding our Services.

Other data protection rights:

If you wish to exercise any other data protection rights that are available to you under your local data protection laws (such as the right to data portability or to data restriction) then please send your request to admin@awardls.com and we will respond to your request in accordance with applicable data protection laws.

You have the right to complain to your local data protection authority if you are unhappy with our data protection practices.

10. Children’s Personal Information

We do not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through the Websites or Services, please contact us at admin@awardls.com and we will use commercially reasonable efforts to delete that information.

11. Business Transactions

We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge. If we do, we will inform them of the requirement to handle your personal information in accordance with this Policy.

Contact:

If you have questions regarding this Policy then please contact us by email at admin@awardls.com or at:

Award Learning Services Ltd. 19 High Street. Maldon. Essex. England. CM9 5PE