Learnerbly has carried out a comprehensive assessment of our current data processing practices based on industry best practices, and the advice of our external Data Protection Consultant.
1. Data Collected by Learnerbly
You may decide to send us your personal information via our website if you are seeking more information or for one or more of the following purposes:
a. User profile and other personal information: users provide Learnerbly with information about themselves (name, email address, job function, learning goals) through the member registration process and learner survey / on-boarding process. From time to time we may invite users to provide information through other parts of the website - for example, where Learnerbly or a partner sponsors a promotion through the website.
b. Member-provided content: Learnerbly allows users to augment their profile information (regarding learning needs, feedback on courses) and other materials which may include personal information about themselves or others, to the website which is available for Company admins/managers who are the main point of contact between Learnerbly and the end-users and therefore need to access the personal data, as well as information which users may choose to make visible to peers if they decide to share information with other users, and therefore these other users may see their name associated with a request. We securely store and host these materials on behalf of our users.
c. Non Member provided content: Learnerbly also collects the IP addresses of the computers used by visitors to the website. They are used, together with further information about visits to the site, to note a visitor's interest in the website and for statistical purposes. They do not allow us to identify the visitor unless they also choose to submit personal information to the website.
2. Personal Data Processing Activities
a. Learnerbly uses personal information collected through the website to authenticate its users, to provide services through the site, to tailor and improve those services and to administer our user relationships. Please find a list of the services below:
- Allow users to log-in to the Learnerbly app
- Request a demo
- Subscribe to the newsletter
d. Upon your written instruction, we will securely delete or return your Personal Data and all copies thereof on termination of this agreement, unless we are required to retain it under a legal or regulatory obligation to store the Personal Data.
3. Sensitive Personal Data
4. Children’s Personal Data
5. Data Subject Rights
As described within GDPR, you have several rights connected to the provision of their personal data to Learnerbly using this website. These include your right to request that Learnerbly:
- corrects any inaccurate or incomplete personal data about you
- changes the consent which you have previously provided to Learnerbly in relation to the processing or storage of your personal data, for example if you no longer wish to receive marketing communications from Learnerbly
- permanently erases all your personal data promptly, and confirms to you that it has done so (there may be reasons why we may be unable to do this)
- provides you with a complete copy of your personal data for you to move to an alternative data processor
- stops processing your personal data, whilst an objection or complaint from you is being investigated and resolved
If Learnerbly does not address your request or fails to provide you with a valid reason why it is unable to do so, you have the right to contact the Information Commissioner’s Office to make a complaint. They can be contacted via their website (www.ico.org.uk) or by telephone 0303 123 1113.
6. Declaration of Sub-Processors
To make an informed decision on whether to provide consent for your personal data to be processed or stored by Learnerbly using this website, we need to make you aware of other organisations that act as Data Processors for us in the provision of our services to you:
- Google, (https://policies.google.com/privacy/frameworks/), a provider for web analytics, cloud and communications services (ie. contacting the Client’s employee about a variant in the resource vie email, sending across monthly invoices and available balance), based in the US who have declared compliance with the Standard Contractual Clauses, as approved by the European Commission under Decision 2010/87/EU, covering the collection, use and retention of personal data transferred from the UK/EU
- AWS, Amazon (https://aws.amazon.com/blogs/security/aws-gdpr-data-processing-addendum/) a provider of web analytics, cloud-based hosting and communications services based in the US who have declared compliance with the Standard Contractual Clauses, as approved by the European Commission under Decision 2010/87/EU, covering the collection, use and retention of personal data transferred from the UK/EU
- Hubspot (https://legal.hubspot.com/privacy-policy/), a provider of software products for internal communications, sales and marketing based in the US who have declared compliance with the Standard Contractual Clauses, as approved by the European Commission under Decision 2010/87/EU, covering the collection, use and retention of personal data transferred from the UK/EU
- Intercom (https://www.intercom.com/terms-and-policies#eu-us), a customer messaging platform based in the US who have declared compliance with the Standard Contractual Clauses, as approved by the European Commission under Decision 2010/87/EU, covering the collection, use and retention of personal data transferred from the UK/EU
- Teamtailor (https://www.teamtailor.com/en/privacy-policy/) a provider of applicant tracking system software based in the EU who have declared compliance with the General Data Protection Regulation.
- Iterable (https://iterable.com/trust/gdpr-commitment/) a provider of growth marketing service based in the US who have declared compliance with the Standard Contractual Clauses, as approved by the European Commission under Decision 2010/87/EU, covering the collection, use and retention of personal data transferred from the UK/EU
- Hotjar (https://www.hotjar.com/legal/policies/privacy) a provider of data analysis service based in the US who have declared compliance with the Standard Contractual Clauses, as approved by the European Commission under Decision 2010/87/EU, covering the collection, use and retention of personal data transferred from the UK/EU
Cookies are small text files sent by us to your computer, or from your computer or mobile device to us each time you visit our website. They are unique to your device or web browser. Session-based cookies last only whilst the browser is open and are automatically deleted when the browser is closed. Persistent cookies last until you (or your browser) deletes them, or until they expire.
7.2 Hubspot Tracking
Learnerbly uses Hubspot to track and record email and attachment opening activity data for sales and marketing analytics purposes.
8. External Links
10. Contacting Learnerbly
Learnerbly Data Protection Manager
9th Floor, 107 Cheapside