PRIVACY POLICY

Who we are

AppLearn Ltd (“we”, “us”, “our”, “AppLearn“), a company registered in England & Wales with company number 07620235 with registered offices at Riverside House, Kings Reach Business Park, Yew Street, Stockport, Cheshire, SK4 2HD.  This includes any other company within our group, including AppLearn Inc and YesElf s.r.o.

We are committed to protecting and respecting your privacy. Ensuring you have control and decision-making power over your personal data is central to our principles and ethos as business.

We are the “data controller” which means that AppLearn determines the purposes for which, and the way, your personal data is processed.

What does this policy relate to?

This policy sets out how we will process personal data about you.  In particular, when you use our websites (www.applearn.com; www.yeself.com) (Website(s)), use our AppLearn customer hub (https://hub.applearn.com) (Hub) engage with us as a customer or supplier, or we market to you.

This policy also details when we may share your data, how it is kept secure, how you can communicate with us or make a complaint, as well as explaining your rights and how they may be exercised by you. Please read this policy carefully.

We may update this Policy from time to time and such changes will be made available on our Websites and, in some circumstances, we may contact your directly about the changes. This Policy was last updated on 17/05/2022.

Understanding this policy

Please click on the sections to the left to navigate easily around our policy and privacy information.

Contact us

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy and how we process personal data. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Email address: [email protected]

Providing our Services

When we provide our Software as a Service and related to products to you, we are usually the data processor and act on the instructions of our clients, for whom you may work. We rely on your employer having the necessary lawful bases to share any of your personal data with us, and our processing of that data is covered under a contract with the client. This privacy policy does not cover this data processing and you should speak to your employer for further information, but we will assist with any query as far we are able.

Providing our Hub

When providing the AppLearn Customer Hub, certain nominated users will be required to register to access the Hub on behalf of one of our clients (your employer). The provision of the Hub is provided to assist our clients through the purchase process, implementation and ongoing management of our services and products.

We are the data controller for the personal data we process in provision of the Hub. In order to register you for the Hub and provide ongoing access, we will need to process information on who you are, who you work for and your work contact details.

Third party sites

Our Websites may contain links to other independent third-party websites or mobile applications. These Third-party Sites are not under our control, and we are not responsible for and do not endorse their content or their privacy policies (if any). When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Data we collect

We may collect the following Data, from you:

  • Name and basic identity.
  • Contact Information such as work email addresses and telephone numbers.
  • Job information and place of work.
  • Communications, requests, feedback and complaints.
  • Information about the services we provide to you.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password for the Hub, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Website, products and services.
  • Marketing and communications data which includes your preferences in receiving marketing from us (and our third parties if applicable) and your communication preferences.

Sensitive Data. We do not usually collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. In other circumstances you may not be able to receive the full benefit of our websites and related functions.

How we collect data

Direct Interaction: We will collect your personal data in several ways, for example:

  • when you contact us through the Website, by telephone, post, e-mail or through any other means.
  • When your register for our Hub.
  • When you receive our services.
  • When you supply products or services to us.
  • when your complete surveys that we use for research purposes (although you are not obliged to respond to them).
  • when you enter a competition or promotion, or otherwise interact through a social media channel.
  • When you submit an enquiry to us regarding our services and/or client products or request a demo.
  • when receive marketing communications from us.

Third parties: We may receive personal data about you from the following third parties/publicly available information:

  • From your employer when they are a client or supplier of ours.
  • From banks, financial institutions and payment processing facilities.
  • Credit Check providers, Companies House and any other agreed third-party references.
  • Technical data from analytics providers such as Google.
  • Identity and contact Data from publicly available sources based inside the UK such as Companies House.
  • Data aggregators, who have collated and analysed businesses who may be interested in our products. We may then receive contact information for business owners or key decision makers, for whom we believe we have a legitimate interest to contact. For such aggregators we will conduct due diligence to ensure compliance with the UK GDPR and will also contact you within 30 days of receiving any personal data about you, to ensure you are fully aware and are able to exercise your rights (see Your Legal Rights section).
  • From social media platforms if you link to our Websites via those platforms.
  • From analytics and online service providers (with your consent or relying on those providers’ bases for processing), including:
    • Pardot.
    • Google Tag Manager.
    • Google Analytics.

Automatically: To the extent that you access the Website, we may collect your personal data automatically, for example we request permission to automatically collect some information about your visit to the Website or use the Hub. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

Any collection automatically via cookies, will in line with your permissions given the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the Cookies section below.

 

How we use your data

We have set out below, in a table format, a description of all the common ways we may process your data and our usual reasons for doing so (known as a lawful basis).

 

 

Purpose/Activity Lawful basis
To supply our SaaS products to your organisation a) in performance of a contract

b) In accordance with our legitimate interests

To receive your, or your organisations, products and services a) in performance of a contract

b) In accordance with our legitimate interests

To market our products to you. (a) With your consent.

(b) In accordance with our legitimate interests.

To register you for our Hub

 

 Necessary for our legitimate interests
To manage our relationship with you which will include:

(a) Provide our services

(b) Notifying you about changes to our terms or privacy notice

(c) Asking you to leave a review, feedback or take a survey

(d) dealing with an enquiry from you

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (to provide our services, keep our customers updated, keep our records updated, to study how customers use our products/services and to develop customer relationships to help our business grow)

(e) Help grow performance and consumer confidence by using reviews of our potential services and products.

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal requirement.

To enable you to partake in a prize draw, competition or complete a survey.

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences With your consent.
To make suggestions and recommendations to you about products or services that may be of interest to you (a) Necessary for our legitimate interests (to develop our products/services and grow our business)

(b) On the basis of your request for this information or by joining our emailing database (consent)

To provide customer service, support and manage returns Necessary for our legitimate interests (to develop our products/services and grow our business)

 

To train our staff Legitimate interests, so when you contact us you will receive the best service possible


 

Profiling. We do use software to automatically assess your personal data in order to determine more information you or your characteristics (known as Profiling), to understand how you engage with us and use our Website and related services (this is based on our legitimate interest or your consent). Please also refer to our Cookies section.

Automated Decision Making. Please note, we do not take automated decisions about you based on the personal data we hold, which may have a significant impact on your rights and freedoms (known as Automated Decision Making). We will update this Policy and other privacy information in the event this changes.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Comms & Marketing

We do not usually collect personal data for our business customers, beyond business emails and a telephone number of you or your employees, as well as recording a history of contact.

We rely on legitimate interest to store and use this information, because we need to communicate with you in order to market to you, provide our products or services and perform our functions, as well as responding to requests for information and placing orders.  We believe it is within your reasonable expectations that we will process this minimal contract information and this will not impact the legal rights and freedoms of you and/or your employees. We also provide the opportunity for you to opt out of any marketing communications and you may exercise your data rights (set out below).

In some instances, we may ask you to sign up to a newsletter or consent to specific marketing communications. You may withdraw this consent at any time.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us or opting out to a communication you receive.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Disclosures of your personal data

We may share your personal data with the parties set out below:

  • Group companies and their personnel.
  • External Third Parties including specialist IT support, help desk providers, data analytics and technology providers, suppliers and sub-contractors for the performance of our website, our applications and any contract we enter into with them or you, including Pardot.
  • Professional advisers including lawyers, bankers, marketing agencies, auditors and insurers.
  • Credit reference agencies, law enforcement and fraud prevention agencies to help us prevent and deal with fraud.
  • HM Revenue & Customs, regulators and other authorities who require reporting or processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

International transfers

Some of our clients and external third parties are based outside the UK so the processing of your personal data may involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government (e.g. the EEA).
  • Where we use certain service providers, we may use specific contracts approved by the UK Government and ICO which give personal data the same protection it has in the UK, as well as conducting an appropriate risk assessment.

Keeping data secure

We will use technical and organizational measures to safeguard your Data, for example:

  • access to your account is controlled by a password and a user name that is unique to you.
  • we store your Data on secure servers.

We are certified to ISO 27001. This family of standards helps us manage your Data and keep it secure.

Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us via this e-mail address: [email protected]

How long will we keep your data for?

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted and we have no over-riding reason to retain it.

For example, we may need to keep some or all of it for legal, tax or regulatory purposes.

Your legal rights

You have the following rights in relation to your personal data:

  • Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information that we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
  • Right to correct – the right to have your data rectified if it is inaccurate or incomplete.
  • Right to erase – the right to request that we delete or remove your data from our systems.
  • Right to restrict our use of your data – the right to “block” us from using your Data or limit the way in which we can use it.
  • Right to data portability – the right to request that we move, copy or transfer your data.
  • Right to object – the right to object to our use of your data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: [email protected]

How you can complain

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

Cookies

This Website may place and access certain Cookies on your computer. AppLearn Ltd uses Cookies to improve your experience of using the Website and to improve our range of products and services. AppLearn Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies which are not strictly necessary. By giving your consent to the placing of Cookies, you are enabling AppLearn Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

This Website may place the following Cookies:

  • Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies: They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We require your consent for these.
  • Functionality cookies: These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). We require your consent for these.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalization settings.

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

Cookies we use

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

Strictly necessary cookies: We use the following strictly necessary cookies:

  • Pardot: To enable the use of our contact forms on our website, so our team can deal with your request in a timely manner

Analytical/performance cookies: We use the following analytical/performance cookies:

  • Google Analytics: To help us know where our customers are located in order to better help us with product and website development

Functionality cookies: We use the following functionality cookies:

  • Google Analytics: To allow us to optimize our website based on user behaviour
Article by

AppLearn Admin

Article by

AppLearn Admin