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LMS365 App Privacy Policy

This Privacy Policy sets out how we, ELEARNINGFORCE International ApS, collect, store and use information about you when you use or interact with our LMS365 App(s), and where we otherwise obtain or collect information about you. This Privacy Policy is effective from the 25th of May 2018.

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data Processor: ELEARNINGFORCE International ApS
  • How we collect or obtain information about you:
    • When you use and interact with LMS365.
  • Information we collect: Account Name, User Display Name, Email Address, Department, Job Title, Office, Country, City, Manager ID/Email, Training Records
  • How we use your information: for recording your training activity and results.
  • Disclosure of your information to third parties: to fulfil any contracts we enter into with your organisation, where required by law or to enforce our legal rights.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
  • How long we retain your information: data retention will be set by the organisation who you have signed up with to take your training.
  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
  • Use of cookies: we use cookies including essential, functional, and analytical. For more information, please visit our cookies policy here.
  • Use of automated decision making and profiling: we do not use automated decision making or profiling.
  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority
  • Sensitive personal information: we 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 main section below entitled Sensitive Personal Information.

Contact details

The data controller is the organisation which is providing you with the training, in most cases this will be your employer. Please contact the data controller in the first place.

The data processor in respect of our application is ELEARNINGFORCE International, of Europaplads 16/4, Aarhus, 8000, Denmark.

You can contact the data processor by writing to ELEARNINGFORCE International, Europaplads 16/4, Aarhus, 8000, Denmark or sending an email to This email address is being protected from spambots. You need JavaScript enabled to view it..

If you have any questions about this Privacy Policy, please contact the data processor.

Information we collect when you use LMS365

We collect and use information from application visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Application server log information

LMS365 runs in the Microsoft Cloud, the privacy policy of which is available here. Our application server automatically logs the IP address you use LMS365 as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our application, and your browser version and operating system.

Use of application server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and application remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our application using server log files is such a measure.

Legal basis for processing: our and Microsoft’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we and Microsoft have a legitimate interest in using your information for the purposes of ensuring network and information security.

Cookies

Cookies are data files which are sent from our application to a browser to record information about users for various purposes.

We use cookies, including essential, functional, and analytical cookies. For further information on how we use cookies, please see our cookies policy which is available here.

You can reject some or all of the cookies we use on or via our application by changing your browser settings by using our cookie control tool, but doing so can impair your ability to use our application or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

Disclosure of your information to third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc.

Google collects information through our use of Google Analytics on our application. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: 
https://www.google.com/policies/privacy/partners/

We use cookies to collect anonymous information about users visits to the application e.g. the number of visits, the average time spent on the application, and which pages have been read. The purpose is to segment the users of the application demographically and geographically to provide us with the opportunity to structure and understand our target group with the purpose of adjusting our online advertisement.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service 
(https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.]

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants and business partners. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): legal obligations to disclose information which are part of the laws of Denmark or if they have been integrated into the Danish legal framework (for example in the form of an international agreement which the Denmark has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the Danish’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

The retention period is set by your organisation as the Data Controller, please check with the Data Controller, in most cases your employer or the organisation providing you with access to the LMS.

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our application
  • only transferring your information via closed system or encrypted data transfers

Transfers of your information outside the European Economic Area

The location of your data is decided by the organisation setting up the LMS, for European Customers all data will remain in the EEA when the European Data Center has been selected. However if you are part of a Multinational organisation your data could reside outside of the EU.

Google Analytics

[Information collected by Google Analytics (your IP address and actions you take in relation to our application) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: 
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to ELEARNINGFORCE International, Europaplads 16/4, Aarhus, 8000, Denmark:

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • 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 accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s application:

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here:
http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Sensitive Personal Information

‘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.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our application.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

We do not knowingly contact or collect information from persons under the age of 18. The application is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to This email address is being protected from spambots. You need JavaScript enabled to view it.

Copyright

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.