PURPOSE OF THIS POLICY PRIVACY
For users based in the EU and the UK, we are required to describe our role and our responsibility for Personal Information.
- If you access and use the Site and/or the Services in your individual capacity, we are the “data controller” under EU privacy law.
- If you access and use the Platform or any of the other Services in connection with an Enterprise Agreement entered into between your employer or prospective employer and Walirian, and in accordance with that agreement, your employer or prospective employer remains data controller for certain Personal Information you may be required to disclose in connection with your use of the Platform or other Services, the terms of that Enterprise Agreement shall apply with respect to the processing of the Personal Information set forth therein. In these instances, we act as a “data processor” under EU privacy law, meaning that we process your Personal Information to provide a service to your employer and do so at their direction. If you have any questions about specific privacy practices in connection with your use of the Platform or other Services through your employer or prospective employer, please contact your employer or prospective employer.
- If you access and use the Platform or other Services in connection with an Enterprise Agreement entered into between your employer or prospective employer and Walirian, or any parent, subsidiary, or affiliate thereof, and in accordance with that agreement, your employer or prospective employer is not designated as the data controller with respect to any of your Personal Information, then Walirian will be the data controller.
CATEGORIES OF PERSONAL INFORMATION WALIRIAN COLLECTS
Personal Information includes any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (e.g., anonymized or aggregated data).
The categories of Personal Information about you that we may collect, use, store, and transfer include the following, some of which constitute Personal Information only when combined with personal identifiers:
Identity Data: Information we use to identify you, authenticate you as an authorized user of the Services, communicate with you, and record any transactions you make. This includes first name, maiden name, last name, login/user ID and password details, marital status, title, date of birth and gender, and social security number where required for reporting purposes.
Contact Data: Includes billing address, postal address, email address, telephone number, and mobile phone number.
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 our Site and Services.
Usage Data: Includes information about how you use the Site and Services.
Transaction Data: Includes details of the Services for which you have previously registered and/or in which you have been enrolled.
Financial Data: In limited circumstances, we may collect payment information for processing of payments, but this information generally is collected and processed directly by our payment services providers.
Assessment Data: Information on your aptitude in certain technology-based subject areas and your performance on Walirian’s capabilities and learning needs assessments.
Profile Data: Includes your interests, preferences, website browsing history, demographic information such as age, gender, or education level, and feedback and survey responses.
Marketing and Communications Data: Includes your preferences with respect to receiving marketing from us and/or our third-party partners and your communication preferences.
AGGREGATED AND ANONYMIZED, NON-IDENTIFIABLE DATA
We also collect, use, and share aggregated and anonymous data such as statistical or demographic data for a variety of purposes. We may use this type of data to analyze trends with respect to skills, jobs, employment, and the workforce generally; to administer, analyze, and improve the content and functionality of the Site and Services; for marketing; and to gather demographic information about our user base as a whole. We utilize unstructured machine learning technologies to understand user behaviors and to provide user-specific recommendations and other personalization of the Site or Services experience.
Aggregated or anonymized data may be derived from your Personal Information but is not considered to be Personal Information under applicable privacy laws as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated or anonymized data with your Personal Information in such a way that that it can directly or indirectly identify you, we treat the combined data as Personal Information and only use it in accordance with the terms of this Privacy Notice.
FAILURE TO PROVIDE REQUIRED PERSONAL INFORMATION
Where we are required to collect certain Personal Information by law or under the terms of a contract with you or your employer or prospective employer, and you fail to provide that data when requested, we may not be able to perform under the respective contract and may not be able to provide access to or use of the Services. In the situation where we have already entered into a contract with you, we may be required to cancel provision of the Services, but we will notify you in advance of such cancellation if this is the case.
HOW WALIRIAN COLLECTS YOUR INFORMATION
We collect your Personal Information when you:
- Create an account on the Site or register to use the Services;
- Register or apply for a Course, Class, Workshop, or any other Services on the Site, through any of the Services or via a third-party website;
- Participate in our surveys, promotions, and competitions;
- Interact with us on various social media channels such as Facebook, Twitter, LinkedIn, etc.;
- Post information to the Site or Services that includes Personal Information, for example, by posting in a chat room or on a blog post;
- Communicate with us, for example, by submitting queries regarding the Site or the Services, interacting with our customer support, marketing, or sales teams, or requesting additional information from us, including newsletters or other marketing materials; and
- Sign up, in person or online, for events or programs that are run by us or by the third-party organizations with which we partner.
Automated Technologies or Interactions
COOKIES, AUTOMATIC DATA COLLECTION AND RELATED TECHNOLOGIES
Cookies are small text files that include a unique reference code placed on a visitor’s device to store their preferences and sometimes track information. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to our Site or Services and will last for longer. Some cookies are necessary to enable you to move around the Site and use the Services such as accessing the secure areas of the Site, and they enable us to provide you with the Services you have requested. “Performance cookies” collect aggregated, anonymous, statistical information on how visitors use our Site and Services. We use this information to make improvements to the Site and our Services and to enhance your overall experience. Other cookies, called “functionality cookies,” allow the Site and Services to remember choices you make such as your user name when you log in to your account or the language or region you are in. They may also be used to help you watch a video or comment on a blog and are intended to improve your online experience.
We and our third-party vendors, including Google, use first-party cookies and third-party cookies to gather information about the pages visited through our advertising partners, both on our Site as well as other websites that you visit, so as to place you in a "market segment." This information is then used by us and our third-party vendors to serve interest-based advertisements when you visit our Site and other websites and our third-party vendors will combine it with other information from your visits to other websites and apps to learn more about your interests. For more information about this type of interest-based advertising, and about how to opt out of the automated collection of information by third-party ad networks, please visit the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/. Without these cookies, advertisements you encounter will be less relevant to you and to your interests.
We also use Google Analytics Advertising Features including Google Analytics Remarketing to advertise across websites, Demographics and Interest Reporting, and AdWords and AdSense integrations to collect data about our Site traffic via advertising cookies and anonymous identifiers. We do not facilitate the merging of personal information with non-personally identifiable information previously collected through any Google advertising product. Google may serve ads across other websites that you visit based upon your past visits to our Site, and may also serve our advertisements on other websites. Site visitors can opt out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ad Settings found at https://www.google.com/settings/u/0/ads?hl=en. You can also opt out of Google Analytics tracking with the Google Analytics opt-out browser add-on found at https://tools.google.com/dlpage/gaoptout/.
In addition to cookies, we use the following similar technologies:
- Pixel Gifs/web beacons: These are small image files that may be placed by us or third parties on the Site or Services, or within the body of our newsletters so we or third parties can understand which parts of the Site and Services are visited or whether particular content is of interest.
- Flash cookies: We do not serve Flash cookies but Adobe Flash Player may be used by third parties serving advertisements to the Site in cases where these advertisements are served with flash related content. It is not possible to block or restrict Flash cookies using your browser settings; however, information on how to do this is available from the Adobe website at http://www.adobe.com/products/flashplayer/security.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can use your browser to notify you each time a cookie is set or to block and delete cookies from your browser. The effect of disabling cookies depends on which cookies you disable, but please note that if you do that, the Site and Services may not work properly and you may not be able to take full advantage of the Site or our Services. You can learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browsers.
Details on how to review your cookie settings and disable cookies on the most popular browsers are set forth below:
Microsoft Internet Explorer:
- From the menu bar, choose “Tools” then “Internet Options”.
- Click on the “Privacy” tab.
- Select the appropriate settings.
- From the menu bar, choose “Chrome” then “Preferences”.
- On the “Settings” page, scroll down and click “Advanced”.
- Under ''Privacy and Security,'' click ''Content settings'' then “Cookies”.
- Select the appropriate settings.
- From the menu bar, choose “Safari” then “Preferences”.
- From the “Preferences” box, choose the “Privacy” tab in the menu bar.
- Select the appropriate settings in the “Website tracking” menu.
- Click on “Manage Website Data” and make the appropriate selections.
- From the menu bar, choose “Firefox” then “Preferences”.
- Click on the “Privacy” tab on the menu bar.
- Select the appropriate settings in the “Tracking” menu.
- Click on “remove individual cookies” and make the appropriate selections.
PURPOSE FOR WHICH WALIRIAN USES YOUR INFORMATION
We have set forth below the ways in which we may use your Personal Information, along with the legal bases and legitimate business interests on which we rely to do so where appropriate.
Please note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your Personal Information. Please contact us if you need more information about the specific legal ground on which we are relying to process your Personal Information:
CHANGE OF PURPOSE
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the new purpose is compatible with the original purpose, please contact us at email@example.com If we need to use your Personal Information for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do this.
NOTICE TO JOB APPLICANTS
If you are located outside of the United States, please note that the Personal Information that you submit will be transferred to, processed, and stored in the United States (and may also be stored in the relevant jurisdiction(s), as required by applicable law, if the job relates to one of our affiliated entities outside of the United States), and you consent to the transfer, storage, and processing of your information in the United States. To the extent your Personal Information contains details of your race or ethnic origin or physical or mental health or condition, you expressly consent to the collection, storage and processing of this information for the purposes of your job application.
HOW TO OPT OUT OF FUTURE COMMUNICATIONS
If you do not want us to contact you with marketing communications or other information regarding our products and services (or if you agreed to be contacted for such purposes at the point Personal Information was collected by us but you no longer wish to be contacted or have your information used in such way), you can let us know by following the unsubscribe instructions on any communications sent to you. You can also unsubscribe at any time by contacting us at firstname.lastname@example.org
Please note that if you have registered an account on the Site or Services or are registered for a Course, opting out of receiving marketing messages will not apply to Personal Information provided to us as a result of signing up to use our Site or Services, and we reserve the right to send you certain communications relating to your account, your registration, and your use of the Site and Services, such as messages relating to account management, customer service, and system maintenance. These transactional account messages will thus be unaffected if you choose to opt out of marketing communications.
HOW WALIRIAN MAY SHARE YOUR INFORMATION
Vendors and Third-Party Service Providers. We may share any information we receive, including your Personal Information, with vendors and third-party service providers, including Instructors, retained in connection with the provision of the Site or Services. This includes those providing website and data hosting services (e.g., Amazon Web Services and Heroku), distributing communications and supporting or updating marketing lists (e.g., Sailthru and Salesforce), facilitating feedback on our services (e.g., SurveyMonkey); and providing IT support services from time to time. These organizations (which may include third-party suppliers, agents, subcontractors, and/or other companies in our group) will only use your information to the extent necessary to perform their support functions. In addition, where necessary, we have entered into Data Processing Agreements with these third-party service providers.
Displaying to Other Users. Some content that you post to the Site or Services may be displayed publicly. Other users of the Site or Services may be able to see some information about you, such as information contained in comments posted in a chat room or on a blog post. You should exercise caution when using public forums. We discourage the posting of sensitive or Personal Information in comments or posts to the Site and/or Services and we are not responsible for the use of any Personal Information by third parties that you publicly post on the Site or Services.
Social Networking and Other Websites. The Site or Services may allow you to post information to social networking websites. We do not share your information with such social networking websites unless you direct the Site or Services to share it. The use of the information by such social networking websites will be governed by their privacy policies, and we do not control their use of the shared data.
As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, usage information and device identifier (including IP address), and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order, warrant or subpoena; respond to your requests; enforce our policies related to our Site or Services, or other applicable policies; or protect your, our, or others' rights, property, or safety. Unless prohibited by law or court order, or unless we determine in our sole discretion that notification is inappropriate under the circumstances, we will take all reasonable steps to notify all affected users of a legal request for information or intended disclosure prior to disclosure.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information, including Personal Information, may be sold or transferred as part of such a transaction as one of the transferred assets as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.
With Your Consent. We may also disclose your information, including your Personal Information, where you have specifically provided your consent for the disclosure. You may withdraw consent to disclosures where you have previously give a specific consent by emailing us at email@example.com
SECURITY OF YOUR INFORMATION
We have implemented appropriate physical, technical, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. In addition, we limit access to your
Personal Information to only those employees, agents, contractors, and other third parties who need to have access to such information for the operation of our business, including operation of the Site and Services. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site or the Services like message boards. The information you share in public areas may be viewed by any user of the Site or the Services.
Unfortunately, no electronic data transmission or storage of information can be guaranteed to be completely secure or error free and we cannot warrant or guarantee the security of any Personal Information transmitted to our Site or Services. Any transmission of Personal Information is at your own risk.
Our Site and the Services are not intended for nor directed toward children under the age of 16 and we do not knowingly collect personal information from children under 16 years of age. If you believe that your child under the age of 16 may have provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org If we learn that we have inadvertently collected any Personal Information from children under 16, we will promptly take steps to delete such information and terminate the child's account.
We will only keep your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of your Personal Information; the purposes for which we process your Personal Information and whether we can achieve those purposes through other means; and the applicable legal requirements.
Details of retention periods for different aspects of your Personal Information are available on request by emailing us at email@example.com
YOUR LEGAL RIGHTS
Under the General Data Protection Regulation 2016/679 (the GDPR), data subjects located in the EU have the right under certain circumstances to:
- Be provided with a copy of your Personal Information held by us;
- Request that we correct any of your Personal Information held by us;
- Request that we restrict the processing of your Personal Information (while we verify or investigate your concerns with this information, for example); and
- Object to any further processing of your Personal Information, including the right to object to marketing;
- Request that the Personal Information you have provided be transferred to a third party;
- Withdraw consent: Where the basis of the processing of your Personal Information is based on consent you have the right to withdraw that consent without detriment at any time;
- Request that we delete any of your Personal Information held by us.
To exercise any of the rights outlined above, please email us at firstname.lastname@example.org
You will not have to pay a fee to access your Personal Information (or to exercise any other rights). We may, however, charge a fee if we believe your request is excessive, unfounded, or repetitive. Alternatively, we may refuse to comply with your request in these circumstances.
In response to any of the requests outlined above, we may need to request specific information from you to enable us to confirm your identity and to ensure you have the right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that your Personal Information is not disclosed to any person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request in order to speed up our response time.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case we will notify you and keep you updated.
If your request or concern is not satisfactorily resolved by us and you are located in the EU, you may approach your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index en.html) who can provide further information about your rights and our obligations in relation to your Personal Information, as well as deal with any complaints that you have about our processing of your Personal Information.
UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION
It is important that the Personal Information we hold about you is accurate and up to date. Please keep us informed if your Personal Information changes during your relationship with us. You can update, correct, or delete any information that you have provided to us through your use of the Site or Services by sending an email to email@example.com
If you have questions about unsubscribing from email or other communications, you may send an email to firstname.lastname@example.org