Last updated: 11 March 2022.
IF YOUR ACCESS IS PROVIDED BY YOUR EMPLOYER OR ANOTHER ORGANIZATION ACCORDING TO A BUSINESS-TO-BUSINESS (“B2B”) AGREEMENT WITH INTERSKILL, THIS PRIVACY NOTICE MAY NOT APPLY TO YOU OR YOUR USE OF INTERSKILL PRODUCT(S). PLEASE CONTACT YOUR EMPLOYER OR THE OTHER ORGANISATION WITH YOUR PERSONAL DATA OR PRIVACY QUESTIONS ABOUT THEIR RESPECTIVE PRIVACY POLICIES GOVERNING THE SAME.
This privacy notice also describes your choices regarding use, access, and correction of your personal data. The notice is provided in a layered format so you can click the numbered links (above) to quickly navigate to the specific areas of interest (below). Please also refer to the Glossary in section 13 for definitions of some of the terms used in this privacy notice.
- 1. Interpretation
- 2. Important Information and Who We Are
- 3. The Data We Collect About You
- 4. How Is Your Personal Data Collected?
- 5. How We Use Your Personal Data
- 6. Disclosure Of Your Personal Data
- 7. International Transfers
- 8. Data Security
- 9. Data Retention
- 10. Your Legal Rights
- 11. California Residents: Your California Privacy Rights
- 12. Brazilian Residents: Your LGPD Rights
- 13. Glossary
- 14. Policy Updates
The General Data Protection Regulation (EU) 2016/679 (“GDPR”) is a regulation in EU law on data protection and privacy for all individuals within the European Union (EU) and the European Economic Area (EEA). It also addresses the transfer of personal data outside the EU and EEA areas. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU. The retained EU law version of the GDPR in the UK (“UK GDPR”) and the Data Protection Act 2018 (“DPA 2018”) set out the framework for data protection law in the UK.
2. Important Information and Who We Are
This website is not intended for children, and we do not knowingly collect data relating to children.
We have appointed EU Rep as our Representative under Article 27 of the GDPR. All GDPR queries from EU Data Subjects or Data Protection authorities should be addressed to EU Rep using the details set out below.
Interskill Learning Services Ltd.
Registered Office Address:
Wilmslow House, Grove Way
Email: [email protected]
External EU Representative: BizLegal Ltd. trading as EU Rep
Registered Office Address:
27 Cork Road
Email: [email protected]
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues:
Information Commissioner’s Office
Wycliffe House, Water Lane
Tel: 0303 123 1113 (local rate) or initiate a live chat via their website here.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated on the 11th of March 2022. Historic versions can be obtained by contacting us.
We may update this privacy notice and its last updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior and/or by notice in your use of our Product(s) (where applicable) to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or if you are aware that any personal data we hold is inaccurate.
3. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes but is not limited to your first name, last name, username or similar identifier, title, and employer.
- Contact Data includes billing address, corporate or personal email address and telephone numbers.
- Transaction Data includes details about payments from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, unique device identification numbers (such as your Media Access Control (MAC) address), type of device, your login data, browser type and version, time zone setting and geo location, operating system and versions, platform, and other technology on the device(s) you use to access our Product(s).
- Profile Data includes your login details, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our Product(s) and services.
- Marketing and Profile Data includes your interests and preferences in receiving marketing from us and select third parties, news about our Products, your communication preferences and survey responses.
If you decide to make a payment for any of our products and services, your Financial Data, which includes your bank account and payment card details, will be collected and processed by our external payment service provider. We will not have access to, collect, use, store or transfer your Financial Data.
We do not 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 access to one of our Products). 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.
4. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including, but not limited to:
- Direct interactions. You may give us your Identity Data, Contact Data, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: inquire about our products or services; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources based inside AND outside the UK and the EU. Please use the following links for more information about how these third parties collect and use personal data: Companies House. Google. LinkedIn. PayPal. Stripe. ZoomInfo.
5. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- For the performance of a contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our own or third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by checking or unchecking relevant boxes to adjust your marketing preferences or by following the “Unsubscribe” link in any marketing message sent to you. The withdrawal of consent will not affect the lawfulness of any processing that took place before the withdrawal.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register you as a new customer
|Performance of a contract with you
|To process and deliver your order including:
(a) Manage payments, fees, and charges
|(a) Performance of a contract with you
(b) Explicit consent
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
|(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 administer and protect our business and our Product(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(f) Profile Data
|(a) Performance of contract
(b) 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)
(c) Necessary to comply with a legal obligation
(d) Necessary for our legitimate interests to detect or prevent unlawful acts
|To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
|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 Product(s) and services, marketing, customer relationships and experiences
(c) Marketing and Communications
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you
|Necessary for our legitimate interests (to develop our products/services and grow our business)
We provide you with choices regarding our use of your personal data for marketing and advertising purposes. We have established the following personal data control mechanisms:
You will receive marketing communications from us if you have subscribed for an account with us and you have opted in to receive marketing.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted-out of receiving that marketing.
All our marketing communications to you contain an opt out option and you can opt out at any time. Please note that the opt out will not affect the lawfulness of processing that has taken place before the opt out.
We will get your explicit opt-in consent before we share your personal data with any company outside Interskill for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
CHANGE OF PURPOSE
We will only use your personal data 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 we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosure Of Your Personal Data
We may share your personal data with third parties set out below for the purposes set out in the table in section 5 above.
|Interskill Learning (USA), LLC
|The United States of America
|Second-level technical support for MyInterskill.
|Interskill Learning Pty. Ltd.
|Subject Matter Expert support for Interskill course content.
Third-level technical support for MyInterskill.
|Amazon Web Services, Inc.
|The European Union (Germany and Ireland)
|Microsoft Ireland Operations Limited.
|The European Union and United Kingdom.
|Campaign Monitor Pty. Ltd.
|The United States of America
|The United States of America
|Crisp IM SAS
|The European Union (France)
|The United States of America
7. International Transfers
Some of our external third parties are based outside the UK and the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the UK and the EEA.
Whenever we transfer your personal data out of the UK and the EEA, 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 Secretary of State or the European Commission (as appropriate)
- Appropriate safeguards are in place in accordance with data protection laws. These safeguards include the use of standard contractual clauses/data protection clauses approved by the UK Secretary of State or the European Commission (as appropriate) or binding corporate rules.
- The transfer is otherwise allowed under data protection laws (including where we have your consent, or the transfer is necessary for the performance of a contract with you).
8. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, disclosed or being unavailable. In addition, we limit access to your personal data to those employees, agents, professional advisers, contractors and other third parties who have a business need to know on the principle of least privilege (PoLP). They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We periodically review all privacy and security policies and update when necessary in line with changes in data protection laws or when any new technologies are introduced into our business. Where the introduction of new technologies results in a high risk to your personal data we will perform a data protection impact assessment and will only proceed if we are able to mitigate any identified high risks. Methods of collecting personal data are reviewed by management before they are implemented to confirm that personal data is obtained (a) fairly, without intimidation or deception, and (b) lawfully, adhering to all relevant rules of law, whether derived from statute or common law, relating to the collection of personal data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six tax years plus the current tax year as part of our legal obligations to do so.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10. Your Legal Rights
Under certain applicable laws (including UK and EU data protection laws) and under certain circumstances, you have rights in relation to your personal data. We set out below a brief description of such rights:
- Request access to your personal data (commonly known as a “data subject access request”): This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request rectification of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we have a legal obligation to erase your personal data. Note, however, that the right to request erasure is not absolute and there are circumstances where we do not need to comply with the request which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data: This enables you to object to processing where we are relying on our legitimate interest (or those of a third party) to process your personal data or where we are processing your personal data for scientific or historical research or statistical purposes. We do not need to stop processing if we can give strong and legitimate reasons to continue processing your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. This is an absolute right but does not automatically mean that we need to erase all of your personal data and in particular, we may put your details on a suppression list to ensure we don’t send you direct marketing in the future.
- Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data in certain scenarios including: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party: We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to personal data you have provided to us which you initially provided consent for us to use or where we used the personal data to perform, or take steps prior to performing, a contract with you and where the processing is automated.
- Withdraw consent at any time where we are relying on consent to process your personal data: However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Please note that the above rights are not all absolute and are subject to applicable data protection law and may be subject to conditions and provisions set out in applicable data protection laws. For further information or if you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
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 which case we will inform you of an extension period of up to 2 months. In this case, we will keep you informed on progress.
11. California Residents: Your California Privacy Rights
12. Brazilian Residents: Your LGPD Rights
The below information set out in this section 12 only applies to the processing of personal data of individuals in Brazil. The Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais or LGPD) is a law passed by the National Congress of Brazil on 14 August 2018 and came into effect on 15 August 2020.
RIGHT OF CONFIRMATION OF THE EXISTENCE OF THE PROCESSING OF YOUR DATA
You may request confirmation of processing of your data.
RIGHT TO ACCESS
Users have the right to access their data being processed by the us by completing a data subject access form. Users have the right to be informed about the origin of the data, the purpose of the processing and the existence of any records.
You have a right to the portability of your data to another service or product provider, upon express request, in accordance with the regulations of the national authority and subject to commercial and industrial secrets and any data which has been anonymised.
You have the right to have your personal data rectified if it is inaccurate, outdated, or incomplete.
You are entitled to request the anonymization, blocking or elimination of unnecessary or excessive personal data, or of any data that is not being processed in compliance with LGPD.
You have the right to have your personal data deleted if the data is unnecessary or excessive, or if the processing of that data was based on consent.
You have the right to be informed about the duration of the processing of your data, the specific purpose of the processing, the sub-processors and other third parties that access or process your personal data. You also have the right to be informed about your consent choices and the consequences of refusing consent.
REVOCATION OF CONSENT
You have the right to revoke or withdraw consent.
BRING A COMPLAINT
You will have the right to lodge a complaint with the ANPD (the National Data Protection Authority) when established.
You have the right to oppose the processing of your personal data where there is non-compliance with the provisions of the law or if you revoke your consent, as above.
You have the right to request the review of decisions made solely on the basis of automated processing of personal data which affect your interests. If you wish to action any of the above requests, please contact us.
Please note that not all of the above rights are absolute. You will not be discriminated against, or otherwise suffer any sort of detriment if you exercise any of your rights.
Collectively, the licensed programs, program documentation, materials, media, technical literature, any part of the software packages, localised versions thereof, the platform through which they are accessed, all releases and versions thereof, and any other related products, websites, applications, or services made available by Interskill.
The interest of our organization in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
PERFORMANCE OF CONTRACT
The processing of your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
COMPLY WITH A LEGAL OR REGULATORY OBLIGATION
The processing of your data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
EXPLICIT CONSENT FOR EXTERNAL MARKETING
Your personal data will not be disclosed to any third party unless you have given your explicit consent to such disclosure.
14. Policy Updates
Policies and procedures are reviewed and compared to the requirements of applicable laws and regulations at least annually, and whenever changes to such laws and regulations are made privacy policies and procedures are revised to conform with the requirements of applicable laws and regulations.