Privacy Policy
We respect your right to privacy and take seriously our responsibilities in relation to the processing of personal data. We do not collect or process personal data unnecessarily. This privacy policy (the “Policy”) together with our terms of service (the “Terms of Service”) sets out important information about your rights in relation to the processing of your personal data, and the basis on which any personal data we collect from you, or that you provide to us, will be processed in connection with your use of this website (our “Site” or “the Site”) and/or the LearningLab application (the “App” or the “Services”). We do not knowingly attempt to solicit or receive information from children.
GDPR Controller Notice
Under this Policy, and unless the circumstances otherwise require, we will be what’s known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) as “controller” of the personal data you provide to us. This means that we determine the purposes and means of the processing of personal data we collect.
The information we collect
We will collect and process the following data about you for the following purposes:
Information you give us
Your Data. This is information about you which is consensually given by making a registration on our Site or App.
The information you give us may include:
Identity Data: your full name, picture, e-mail address, title, and name of organization.
Financial Data: your financial and credit card information, including bank account and payment card details, billing contact email address, and VAT number.
Platform Data: the information you upload on the LearningLab platform which may contain personal information
The information we collect about you
Automatically Collected Information. With regard to each of your visits to our Site we will automatically collect the following information:
Technical Data: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type, and version, time zone setting, browser plug-in types and versions, operating system and platform, how often you use the application and other performance data which may be subject to analytics software such as Google analytics;
Usage Data: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through, and from our site (including date and time), products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us; and
Public Data: publicly available data in order to create a more complete customer profile and provide better customer support.
No special categories of personal data: We do not require or collect any personal data that is your sensitive personal data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning your sex life or sexual orientation unless you decide to provide this information to us.
Cookies
What are cookies and why do we use them
The Site may use cookies from time to time. “Cookies” are small text files that are stored by your browser on your computer and are normally used to gather statistical information and to analyze trends of use or access to a website. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies may be used to save your personal preferences, so you do not have to re-enter them each time you access the Site. For more about our use of cookies and how you can disable them, please see our cookie policy.
What we do with your information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interest (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.
We have set out below, in a table format, a description of the ways we plan to use your personal data and the legal basis we rely only on to do so. We have also identified our legitimate interests where appropriate:
Purpose/Activity
Type of data
Legal basis for processing
To respond to your queries and to provide you with the information you request from us in relation to our products or Services.
Identity Data Technical Data Usage Data Public Data
Necessary for our legitimate interests (to respond to new or existing customer queries and grow our business) Performance of a contract with you
To set up and administer your account for the Services.
Identity Data
Performance of a contract with you
To provide the Services and perform our obligations arising from any contracts entered into between you and us.
Identity Data Financial DataParticipation DataTechnical Data Usage Data
Performance of a contract with you
To manage payments, fees, and charges and to collect and recover money owed to us.
Identity Data Financial Data
Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you, including notifying you about changes to the Services, our Terms of Services or Privacy Policy.
Identity Data Technical Data Usage Data Public Data
Performance of a contract Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services).
To provide you with information about goods and services we offer that are similar to those that you have already purchased or enquired about.
Identity Data Technical Data Usage Data Public Data
Necessary for our legitimate interests (to develop our products or Services and grow our business)
Where you have given us your consent to do so, to provide you with information about other goods or services we feel may interest you.
Identity Data Technical Data Usage Data
Consent
To ensure that content is presented in the most effective manner for you and for your computer or device.
Identity Data Technical Data Usage Data
Necessary for our legitimate interests (to keep our Site and the Services updated and relevant and to develop and grow our business).
To administer and protect our business, our Site, the Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
Identity Data Participation DataTechnical Data Usage Data Public Data
Necessary for our legitimate interests (for running our business and as part of our efforts to keep our Site and the Services safe and secure)
To use data analytics to improve or optimize our Site, Services, marketing, customer relationships, and experiences
Technical Data Usage Data
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site and the Services updated and relevant, to develop and grow our business and inform our marketing strategy).
To measure or understand the effectiveness of advertising we serve to you and others, and, where applicable, to deliver relevant advertising to you.
Identity Data Technical Data Usage Data
Necessary for our legitimate interests (to study how customers use our products or Services, to develop them, to grow our business, and to inform our marketing strategy).
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@LearningLab.com 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 this Policy, where this is required or permitted by law.
How long we keep your information
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This means that the period of time for which we store your personal data may depend on the type of data we hold. 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 unauthorized 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. For more information about our data retention policies please contact us at support@LearningLab.com
Disclosure of your information
We do not sell your personal information to third parties for marketing purposes. We may disclose information to third parties if you consent to us doing so as well as in the following circumstances:
You agree that we have the right to share your personal information with the following recipients or categories of recipients.
Any department or authorized person within our company or any member company within our group, which means any subsidiary or holding company.
Selected third parties including:
business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you in relation to the Services. You can view the full list of sub-processors here
Where we have your consent to do so, email marketing service providers, to send information to you from time to time by email about promotions, competitions, updates, and new products or services that may be of interest to you;
Analytics and search engine providers that assist us in the improvement and optimization of our Site;
Credit reference agencies for the purpose of assessing your credit score to the extent this is a condition of us entering into a contract with you.
We will disclose your personal information to third-party recipients.
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of our business or assets.
If LearningLab or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation, or court order.
To protect our rights, property or safety, our customers, or others. This includes exchanging information with other companies and organizations for the maintenance and security of the Site and Services.
Security Measures
Acknowledgment and Disclaimer
Security is essential to us, therefore we use the most appropriate physical and technical measures, and require our hosting partner to use the same standard of care. Unfortunately, the transmission of information via the internet is not completely secure and any transmission is at your own risk. We use strict procedures and security features to try to prevent unauthorized access. These are described in more detail below.
Location of Servers and Accessibility
Your personal data is not stored locally but on a secure server. No installs are required on your PC or laptop. Our web application is only accessible via HTTPS, which helps ensure your interactions are secure and private.
Data Storage
Your personal data is stored on secure servers hosted on Amazon Web Services . These servers are located in multipe locations inside EU countries.
Restricted Access
Access to the environment where your personal data is stored is limited and is held by us. Only our authorized staff from the have access to our servers and this is on a ‘need to access’ basis.
Your Personal Data and Your Rights
Accessing your Personal Data
You may request access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to support@LearningLab.com We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive, or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
Right of Restriction
You may restrict us from processing your personal data in any of the following circumstances:
You have contested the accuracy of the personal data we hold on record in relation to you or for a period of time to enable us to verify the accuracy of the personal data;
The processing of your personal data is unlawful and you request the restriction of the use of personal data instead of its erasure;
We no longer require your personal data for the purpose of processing but you require this data for the establishment, exercise, or defense of legal claims; or
Where you have contested the processing pending the verification of our legitimate grounds.
Corrections or Erasure (Right to Rectification and Right to Be Forgotten)
If we hold personal data concerning you which are no longer necessary for the purposes for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at support@LearningLab.com
Your Right to Object
You have the right to object to the processing of your personal data at any time:
For direct marketing purposes
Where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights, and freedoms or in connection with the enforcement or defense of a legal claim
To exercise your right to object at any time, please email support@LearningLab.com. Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below.
Data Protection Authority
You can also lodge a complaint to the Hungarian National Authority for Data Protection and Freedom of Information (About the Authority - Nemzeti Adatvédelmi és Információszabadság Hatóság ) if you have any complaints regarding the processing activities performed by us.
Marketing Communications
We will not use your data to send marketing communications to you about promotions, competitions, updates, and new products or services that may be of interest to you unless we have your permission to do so.
Your Right to Object
You have the right to object to the processing of your personal data for our marketing purposes. To object or if you change your mind at any later time, you can withdraw your consent to the processing of your personal data for such marketing purposes by contacting us at support@LearningLab.com You may also opt-out of receiving marketing communications at any time by selecting the unsubscribe option when you receive electronic marketing communication from us. The withdrawal of your consent will not impact upon the lawfulness of processing based on your consent prior to the withdrawal.
California Residents Privacy Rights
LearningLab complies with the California Consumer Privacy Act (referred to as “CCPA”) as set forth by the State of California. Company does not sell the collected personal information. We only share your personal information as described in this Privacy Policy.
California residents are permitted one time each year to request certain details about how their personal information is shared with third parties for their direct marketing purposes. To make a request, please submit a request, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.
California residents may also take advantage of the following rights:
Access. You may request, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which we collected your personal information, our business or commercial purpose for collecting your personal information, the categories of personal information that we have disclosed for a business purpose, any categories of personal information about you that we have sold, the categories of third parties with whom we have disclosed your personal information, and the business or commercial purpose for collecting, selling, or sharing your personal information, if applicable.
Deletion. You may request that we delete your personal information that we maintain about you, subject to certain exceptions. As described in more detail in our Statement, there are some reasons for which we will not be able to fully address your deletion request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation. You can also access, update, and remove your information by visiting the Member Profile page on our website.
Correction. You can request that we correct inaccurate personal information that we maintain about you.
Do Not Sell or Share My Personal Information. You may request to opt out of our sale or sharing of your personal information to third parties. For purposes of this California Privacy Statement, “sell” means the sale of your personal information to a third party for monetary or other valuable consideration, subject to certain exceptions set forth in applicable California law. For purposes of this California Privacy Statement, “share” means disclosure of personal information to third parties for cross-context behavior al advertising purposes, subject to certain exceptions in applicable law. To effect the opt out, please click on the “Do Not Sell or Share My Personal Information” button on the bottom of the homepage or submit a request in writing to the contact information below. As described above, we, and certain other companies, place tracking technologies, such as cookies, on our websites which allow us, and those companies, to receive information about your activity on our websites that is associated with your browser or Device. We and these companies may use that data to customize content for you and to serve you more relevant ads on our websites or others. Note that if you would like to opt out of tracking for behavior al advertising purposes, you will need to set your preferences by clicking the “Cookie consent” link at the bottom of the webpage or you may broadcast an opt-out preference signal recognized by Company, such as the Global Privacy Control opt-out preference signal (on the browsers or browser extensions that support such a signal). We do not knowingly sell or share the personal information of minors under 16 years of age.
Changes to this policy
Any changes made to this Policy from time to time will be published at the Site.
Any material or other change to the data processing operations described in this Policy which is relevant to or impacts on you or your personal data will be notified to you in advance by email. In this way, you will have an opportunity to consider the nature and impact of the change and exercise your rights in relation to that change (e.g., to withdraw consent or to object to the processing) as you see fit.
Questions or Complaints
Should you have any queries or complaints relating to this Privacy Policy, please contact us at: support@LearningLab.com
Phone: 0036706089798