PRIVACY POLICY
& DATA PROTECTION
1. About VLE
VLE
is an innovative virtual learning platform that supports users
unique needs and brings virtual on-demand learning courses designed by
experienced education practitioners who are committed to providing
highest-quality quality training and education services. You may buy, enrol, access and complete a Course on VLE for which we may
collect obtain, store and use information about you. VLE platform is owned and
operated by Upskill Online Limited trading as Olive Media (referred to as VLE
we , our or us ). We care about your privacy. This Policy, which applies to
the VLE platform, vle.olivegroup.io ( Site ), (together with our VLE Terms of
Use and any other documents referred to in the Site) explains how we collect
and use your information. Please read it carefully. For questions about this
Policy, or if you want to enforce your rights: please contact Olive s Privacy
Officer, at compliance@olivegroup.io.
2. Who we are
Upskill
Online Limited is a limited company incorporated in Ireland with company number
470792, whose registered office is at Glasshouse 1, Dun Laoghaire, Harbour Court, George s Place, Dun Laoghaire, A96 P0A4 Co.
Dublin, Ireland. For the purpose of applicable data protection laws Olive forms
part of the data protection regime in the Ireland and the Data Protection Act
2018 (DPA 2018) and EU General Data Protection Regulation 2016/679 applies to
the processing of personal data wholly or partly by automated means and to the
processing your Personal Information collected through the Site.
2.2 Definitions
2.2.1
Personal Information in this Policy means Personal Data ; as defined in the
EU General Data Protection Regulation 2016/679(EU). In summary, it means
information that identifies you, whether directly or indirectly, including for
example your name, gender, address, email address, phone number and any other
information that you may voluntarily submit to us, as well as any online
identifiers such as your click stream data or IP address.
2.2.2
Data Protection Laws means the data protection and information privacy laws
of Ireland and the European Union and includes any legislation in force from
time to time which implements Directive 95/46/EC or Directive 2002/58/EC of the
European Community, the Data Protection Acts 1988 and 2003 (as amended), and
once applicable the General Data Protection Regulation (EU) 2016/679 (the
GDPR ) and/or any corresponding or equivalent Irish laws or regulations, once
in force and applicable.
2.2.3
Data Processing refers to any action performed on Personal Data, such as
collecting, recording, organizing, storing, transferring, modifying, using,
disclosing, uploading or deleting.
2.2.4
General Data Protection Regulation means Regulation (EU) 2016/679, known as
the General Data Protection Regulation (the GDPR ).
2.2.5
Special Categories of Data has the meaning as set out in Data Protection
Laws.
2.2.6
Sensitive personal information is information about an individual that
reveals their racial or ethnic origin, political opinions, religious or
philosophical beliefs, or trade union membership, genetic information,
biometric information for the purpose of uniquely identifying an individual,
information concerning health or information concerning a natural person s sex
life or sexual orientation.
3. When do we collect information about
you?
We
collect Personal Information when you visit our platform or site, when you enrol for a Course and register get access to VLE Platform,
when you email, call or write to us, or provide us with information in any
other way, including by interacting with us via social media such as Facebook
or Twitter. We also collect information when you take a Course or otherwise,
use our apps, or if your company has provided your details to us to enable us
to provide you with access to and use our courses or apps. All the information
collected in the local storage of about you is deleted
when you logout from the application.
4. Consent
Where
we process your personal data on the basis of your consent, you have the right
to withdraw your consent at any time. You can withdraw your consent by
contacting us at compliance@olivegroup.io.
5. What types of personal information do
we collect and process?
5.1
Each time you visit a Site we may automatically gather the following
information:
5.1.1
technical information about your computer such as domain name, browser type and
version, operating system and platform, IP address, cookie information and time
zone setting; and Following are the information we
store in the local storage for logged in user:
First and Last Name
Email Address
User Authentication token from backend servers
Member ID
Profile pic url
mobile number
Information of client under which user is logged in:
Client Name
Client domain
Client ID
Client logo url
5.1.2
information about your visit including the full Uniform Resource Locators (URL)
clickstream to, through and from the Site (including date and time), what web
pages you visited on the Site and how long you spend on each page, page
interaction information (such as scrolling, clicks and mouse-overs), page
response times, download errors, traffic data, location data, weblogs, history
of resources accessed on the Site, methods used to browse away from the page
and information on what website you visited before accessing the Site.
5.2
We process the following kinds of personal information if you provide it to us,
or if your company provides it to us, or if it comes into existence by virtue
of you taking a Course:
5.2.1
Information about you, including your name, job title, address, email and other
contact details;
5.2.
2 Information about the company you are associated with;
5.2.3
Information about your use of our mobile applications, including information
about which pages you view;
5.2.4
Information concerning your progress in taking a Course including information
concerning your performance in assessments and where appropriate, your
entitlement to a certificate;
5.2.5
Information you provide to us during communications you have with us and with
our staff, for example comments or queries about the courses we provide.
5.2.6
Information about the course or about the content that you provide, such as the
location of the person or the date on which you posted a photo or created an
event, what you see through features that we provide, so we can do things such
as propose masks and filters that you might like, or give you guidelines on
using the same.
5.2.7
We also process the following kinds of personal information if you provide it
to us, or if your company provides it to us, or if it comes into existence by
virtue of you taking a Course: 1) Information about you, including your name,
job title, address, email and other contact details; 2) Information about the
company you are associated with; 3) Information concerning your progress in
taking a Course including information concerning your performance in
assessments and where appropriate, your entitlement to a certificate; 4)
Information you provide to us during communications you have with us and with
our staff, for example comments or queries about the courses we provide. 5)
Information about the course or about the content that you provide, such as the
location of the person or the date on which you posted a photo or created an
event, what you see through features that we provide, so we can do things such
as propose masks and filters that you might like, or give you guidelines on
using the same. 6) VLE shall have the right to access the outlook calendar of
the Teams User who set up a video classroom using VLE.
6. Why do we collect and use your
Personal Information, and what are our lawful grounds for doing so?
6.1
We use your Personal Information for the following purposes:
6.1.1
To process and respond to requests, enquiries and complaints received by you,
in accordance with our legitimate interest to provide you with a responsive
service.
6.1.2
To track your progress through a Course, to assess your performance in
assessments and to determine whether you have reached the standard which is
required if you are to earn a certificate.
6.1.3
To provide services and products requested by you. We do this as necessary to
carry out our legitimate interest to operate a business which offers training
courses.
6.1.4
To communicate with you about services and/or products provided to you. We do
this as necessary to carry out our legitimate interest to operate a business
which offers training courses.
6.1.5
To update our records and for audit purposes, in accordance with our legitimate
interest to operate a business which offers training courses.
6.1.6
To prevent or detect fraud, in accordance with our legitimate interest to do
so.
6.1.7
Where legally required or where it is in our legitimate interest to do so, to
comply with requests from law enforcement and regulatory authorities.
6.1.8
To analyse trends and profiles, for our legitimate
interest to aim, to enhance, modify, personalise or
otherwise improve our services and communications for the benefit of our
customers.
6.1.9
To carry out customer satisfaction research, for our legitimate interest to aim
to enhance, modify, personalise or otherwise improve
our services and communications for the benefit of our customers.
6.1.10
If you make enquiries through a Site and agree in the contact form to receive
email updates we will send you such updates on the
grounds of your consent.
6.1.11
To enable third parties to carry out any of the purposes set out above on our
behalf. For this we use our legitimate interest to run our business as
efficiently as possible.
6.1.12
To create personalized services with clear recommendations and suggestions that
are unique and relevant to users, we use users
preferences, interests and activities based on the data that we collect and
learn from users.
6.1.13
To communicate with users about our services and let users know about the
Policies and Terms as well as to respond to users when the user contacts us.
6.2
The legal basis on which we collect, process and transfer your information in
the manner described above are:
(i) your consent (where we have sought it and you have
provided it to us), and in which case, you can withdraw your consent at any
time;
(ii)
where any such processing is necessary for the performance of a contract with
us; and
(iii)
our legitimate interests in conducting our business in a responsible and
commercially prudent manner.
(iv)
Our legitimate interest in maintaining a business relationship and
communicating with you, as a business contact, about our courses, events and
providing you with information about new developments.
6.3
Where we store your Personal Information
The
Personal Information we collect from you may be transferred to, and stored at,
a destination outside the European Economic Area ( EEA ) as it may be processed
by staff or service providers outside the EEA who work for us. We will take all
steps reasonably necessary to ensure that your Personal Information is treated
securely and in accordance with this Policy, and that adequate measures are in
place if the country in question is not deemed to provide the same level of
protection for your data and rights as you would enjoy within the EEA.
Contracts are in place with these service providers, incorporating the European
Commission s approved model clauses, to ensure that any Personal Information
involved is safe.
7. Transfers abroad
Where
relevant and necessary for Olive s business, we may transfer your personal data
outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an
equivalent level of protection for personal data as is provided for in the
European Union. If and to the extent that we do so, we will ensure that
appropriate measures are in place to comply with our obligations under
applicable law governing such transfers, which may include (i)
entering into a contract governing the transfer which contains the standard
contractual clauses approved for this purpose by the European Commission or
(ii) seeking and obtaining your explicit consent to the transfer.
8. How long do we keep your Personal
Information?
8.1
We hold your Personal Information for as long as we need to for legitimate
legal or business reasons, including complying with any regulatory obligations.
Personal Information collected through a
application may be kept as follows:
8.1.1
The Analytics Companies keep anonymised information
concerning your visits to the application on their servers, in accordance with
their respective privacy policies.
8.2
We will keep your information for at least as long as our relationship with you
is active, and for any further period as required by our retention policy.
8.3
If you would like more detailed information about our retention policy, please
email us at compliance@olivegroup.io or use one of the other methods in the
Contact us section below.
9. Disclosure of your Personal
Information
9.1
We may disclose your Personal Information to companies within our corporate
group. We will not share Personal Information collected through our Site with
unrelated third parties, except as provided in this Policy.
9.2
We may disclose to your employer details concerning your progress in taking the
Course, up to and including the award of a certificate.
9.3
We may disclose your Personal Information to competent regulatory authorities
and bodies as requested or required by law.
9.4
If we sell all or any part of our business, the parties which buy it may have
access to your Personal Information.
9.5
We also provide information and content to research partners and academies to
conduct research and support innovation as well as promote our business and
these parties are not authorised to keep or use your
Personal Information for any other purpose.
9.6
We may disclose the data to third parties who we engage to provide services to
us in connection with this website, such as outsourced service providers, IT
services providers, professional advisers, and auditors.
10. Controlling your Personal Information
You
have the right to ask us not to process your Personal Information for marketing
purposes. You can exercise your right to prevent such processing by ticking
certain boxes on the forms we use to collect your Personal Information, by
clicking unsubscribe in any of our marketing emails to you, or by contacting
our Privacy Officer at any time at compliance@olivegroup.io.
We
at VLE do not knowingly or intentionally collect what is commonly referred to
as sensitive personal information . Please do not submit sensitive personal
information about you to us. For more information, please see the definition of
Sensitive Personal Information under clause 2.2 above.
11. Security
We
aim to ensure that your Personal Information is secure. In order to prevent unauthorised access or disclosure, we have appropriate
physical, technical and organizational measures to safeguard and secure the
Personal Information we collect. Our service providers are required to do the
same. Unfortunately, the transmission of information via the internet is not
completely secure. Although we will do our best to protect your Personal
Information once we receive it, we cannot guarantee the security of your data
transmitted to a Site; any transmission is at your own risk. Once we have
received your Personal Information, we will use strict procedures and use
leading technologies and encryption software to safeguard your data, and keep
strict security standards to prevent any unauthorized access.
11.1
While using some third parties services for the
purpose of payment processing, research or statistical data analysis, some
personal information may be transferred to those third parties. We remain
responsible for your information when shared with third parties, and shall
instruct such third parties to abide by the GDPR rules.
11.2
All private information like User s e-mail address, access log-in can be
accessed only by providing User s password.
12. Cookies
Each
Site uses cookies to distinguish you from other users of the Site. This helps
us to provide you with a good experience when you browse a Site and also allows
us to improve the Site. Providing us with your Personal Information is always
your choice. However, your decision not to provide certain information may
limit our ability to provide you with our complete services. For detailed
information on the cookies we use and the purposes for
which we use them, see our Cookie Policy linked at clause 10 above.
13. Links to other
Website
A
Site may contain links to the website of other companies and organisations which may be of interest ( Third Party
Site ). If you decide to leave the Site and access the Third-Party Sites or to
use or install any Third-Party Applications, Software or Content, you do so at
your own risk and you should be aware that our terms and policies no longer
govern. You should review the applicable terms and policies, including privacy
and data gathering practices, of any site to which you navigate from the Site
or relating to any applications you use or install from the site.
14. Your rights and how to update your
information
You
have the following rights, in certain circumstances and subject to certain
restrictions, in relation to your personal data:
14.1
The right to be informed about the processing of your personal data;
14.2
The right to access your personal data;
14.3
The right to rectification of your personal data;
14.4
The right to erasure of your personal data;
14.5
The right to data portability;
14.6
The right to object to processing of your personal data;
14.7
The right to restrict processing of your personal data.
14.8
The right to request access to your information and information related to our
use and processing of your information;
14.9
The right to withdraw your consent to our use of your information at any time
where we rely on your consent to use or process that information. Please note
that if you withdraw your consent, this will not affect the lawfulness of our
use and processing of your information on the basis of your consent before the
point in time when you withdraw your consent.
In
order to exercise any of the rights set out above, or if you have any questions
about how we process your personal data, you can email us at
compliance@olivegroup.io or write to us at Glasshouse 1, Dun Laoghaire
, Harbour Court, George s Place, Dun
Laoghaire, A96 P0A4 County Dublin. Please note that the limitation or deletion
of your personal data may mean that we will be unable to provide you with the
communications and/or invitations described above.
We
are required to keep all personal data accurate and up to date. To assist us in
doing so, we ask you to contact your usual business contact at Olive Group or
email compliance@olivegroup.io with any relevant changes, such as change of
address or contact telephone numbers.
15. Access to your Personal Information,
deletion, restriction, rectification, and transfer
You
have the right to request details and a copy of the Personal Information we
hold about you and to ask us to delete, restrict, stop using, correct, rectify
or transfer (port) your Personal Information. Our response to your requests may
depend on which legal grounds we are using to process the data in question (see
section above). For more information about your rights under the EU General
Data Protection Regulation 2016/679 &680 please see the EU Directives given
effect in Ireland by the Data Protection Act 2018 in Ireland. You can exercise
your rights by sending us a written request using our by email at
compliance@olivemedia.co; by post at Glasshouse 1, Dun Laoghaire
, Harbour Court, George s Place, Dun
Laoghaire, A96 P0A4 Co. Dublin, Ireland. With each request
please include identification information (a copy of your passport or driving licence and a recent utility bill). Please be as specific
as possible in your request about your requirements, so that we can respond to
you as quickly as possible.
16. Complaints to the ICO
If
you are unhappy with us, our service, or with the way that we treat your
Personal Information, please contact us. You also have the right to contact the
Irish Data Protection Commission by emailing info@dataprotection.ie or by
telephone at 1890 252 231. However, we would appreciate it if you would contact
us first so that we can endeavour to resolve any
issues that you might have. Our contact details are set out below.
17. Unsubscribe
If
you no longer wish to receive further marketing communications and/or
invitations from us, you can unsubscribe at any time by emailing us at
compliance@olivegroup.io.
18. Disclosure of your information to
third parties
We
disclose your information to third parties, only to the extent necessary to run
our business, to our service providers, to fulfil any contracts we enter into
with you, where required by law or to enforce our legal rights. We will not
sell your Personal Information collected through the application with any third
party.
19. Data Retention Policy
It
is the responsibility of the Olive Group to take all precautions necessary to
secure proprietary information and to prevent unauthorised
access to the data. The management of OLIVE GROUP is dedicated to mitigating
the risks associated with data breaches.
19.1. Data Retention Period
General
Data:General
Data: We will retain all client-related data for a standard period of 6 months
from the date of their exit from our services. After this period, the data will
be permanently deleted from all systems and storage media and will not be
accessible to anyone.
Contractual
Obligations: In instances where the Company has
contractual obligations with clients regarding data retention, the data will be
preserved for the duration specified in the respective contracts.
19.2. Data Handling and Security
Data
Access: Access to client data will be
granted only to authorised personnel with a
legitimate business need. Strict access controls are being enforced to prevent unauthorised access.
Data
Security: We have implemented robust security
measures, including encryption and access controls, to protect stored data from
unauthorised disclosure, alteration, or destruction.
Data
Backup and Recovery: Regular data backups are being
conducted to ensure data integrity and facilitate data recovery in the event of
accidental loss or system failures.
19.3. Data Disposal
Expiry
of Retention Period: At the end of the 6-month retention
period, all general client data will be permanently deleted from our databases,
archives, and backup systems.
Contractual
Data: In case of contractual obligations
regarding data retention, data will be disposed of in accordance with the terms
specified in the respective agreements.
19.4. Client Data Retrieval
Client
Request for Data: If a client requests access to
their data within the 6-month retention period, we will provide the data in a
timely manner, subject to verification of the client s identity.
Contractual
Obligations: We will adhere to contractual
obligations concerning data access and retrieval as outlined in the respective
agreements with clients.
20. Changes to this privacy policy
Any
changes we may make to our Policy in the future will be posted on this page
and, where appropriate and feasible, notified to you by email. Please check
these Terms and any Policies periodically for changes. User s continued use of
the application after the changes become effective constitutes the binding
acceptance of such changes. Except as stated elsewhere, such amended Terms will
automatically be effective upon the earlier of (a) the User s ongoing use of
the application with actual notice of the new terms, or (b) 30 days after we
have posted notice of the new terms on this page.
21. Contact us
We
are committed to resolving any privacy concerns you may have. If you have any
questions or comments about this Policy, or if you wish to exercise your
rights, please contact Olive s Privacy Officer for queries or requests relating
to taking a Course: Olive s Privacy Officer for queries or requests relating to
taking Course:
By
email: compliance@olivegroup.io
By
post: Brendan Kavanagh, Upskill Online Limited, Glasshouse 1, Harbour Court, George s Place, Dun Laoghaire, A96 P0A4 Co.
Dublin, Ireland