Contents

Platforms & Services users

[05.03.2021]

This privacy policy relates to the use of platforms and services delivered by:
ELEARNINGFORCE International ApS
Mariane Thomsens Gade 4B, 5
8000 Aarhus
Denmark
In this document referred to as “ELEARNINGFORCE” / “we” / “our” / “us”.
We are committed to protecting and respecting your privacy as a user of our platforms and services. You can read more about how we approach this in the sections below.

Purpose of this Privacy Policy

Your organization has entered into an agreement with ELEARNINGFORCE (“Agreement”) to grant you access to the ELEARNINGFORCE platform (“Platform”) to make training and/or other content available for you or otherwise use the Platform. This Privacy Policy sets out how we collect and process your personal data.
References in this Privacy Policy to “your organization” shall refer to the entity who has entered into the Agreement with us. You will typically be an employee, officer, contractor, or consultant of an ELEARNINGFORCE client.

Our status and responsibilities

Your organization is the data controller for the purposes of personal data processed under this Privacy Policy. ELEARNINGFORCE will process your personal data on behalf of your organization and in accordance with its lawful instructions.
The information you provide to ELEARNINGFORCE and/or upload to the Platform (whether or not it constitutes personal data) will also be governed by the Agreement.
Access to your and your organizations data is governed by your organization as data controller.
Information for your organization about data handling and security in relation to Platform and Services provided by ELEARNINGFORCE is available online in our Trust Center, including our general statement on GDPR and Customer user data processing.
Where ELEARNINGFORCE acts as a data controller; for example, in cases where you receive marketing communications from us, our Privacy Policy regarding Marketing & Website Users will apply.
If you should wish to contact us, please find information on how in the Contact Section below.

Personal data we collect and process

When your organization and you make use of our platform, we will collect and process certain information about you:

Information you provide

You may give us information about you:
When you use the Platform’s features – for instance, but not only, when you sign up for, complete or rate training
This information may include your: Microsoft 365 profile information, name, company email address, company telephone number, job title, department, primary office location, country, city, manager, and your training activities, results and records.
If you contact or correspond with us (for example via any support function made available by us), we may keep a record of that correspondence (either directly or through our service providers).
This also applies to any comments, opinions and/or feedback you provide to us regarding the Platform, for example during any product trials, tests, surveys, customer fora or research panels that you may participate in.

Information your organization provides

Your organization may give us information about you:
When they create a user profile for you to be able to access and use the Platform under the Agreement (whether on a trial or full basis), to enable us to contact you for purposes relating to your and your organization’s use of the Platform, to troubleshoot any issues relating to your or your organization’s use of the Platform, that is reported to us, and otherwise in the course of your organization’s use of the Platform.
This information may include your: Microsoft profile information, name, company email address, company telephone number, job title, department, primary office location, country, city, manager, and your training activities, results, and records.

Information we collect

Each time you use the Platform we may automatically collect the following information:
• A record of the details of your usage, including the date, time, location, frequency and duration.
• Technical information about your computer or mobile device for system administration and analysis, including your IP address, URL clickstreams, unique device identifiers, operating system, and network and browser type.
• Other information about your use of the Platform, including the pages you have viewed, the duration spent on the Platform and data files you have uploaded to the Platform. This information may be linked to your user profile (where relevant).

Information provided by other sources

We work closely with third parties (including for example, business partners, subcontractors, and analytics providers), and we may receive information about you from them. Details of third party providers are described in the section below: “Who we share your information with”.

How we process and personal data

Please note that we process all personal information in accordance with the Agreement.
Where we have collected, received, or generated personal data from or about you, we may process and use this for the purposes as set out below.

Information you or your organization provide

We will use this information to:
• Carry out our obligations arising from the Agreement, including deliver platform and services to your organization as the Agreement specifies.
• Contact you for feedback on our platform and services and to help us evaluate and improve these, for example by acting on any information you have provided to us.
• Notify you about changes to the Platform and any other services of ours that you use, including informing you about new versions of the Platform and about new features, functionality and service offerings.
• Deal with any enquiries, correspondence, concerns or complaints you have raised, or that have been raised by or concerning third parties (such as your organization) involving you and any issues caused by your use of the Platform.

Information we collect

We will use this information:
• To administer and improve the Platform and other services, including ensuring that content is presented in the most effective manner for you and for your computer or device.
• To report to your organization relating to the use of the Platform.
• For internal operations, including troubleshooting, data analysis, testing, research and development, statistical and survey purposes.
• To allow you to participate in interactive features of the Platform.
• As part of our efforts to keep the Platform safe and secure.
• To compile general Platform usage reports (which do not personally identify you).
• In an aggregated and anonymized form for statistical and benchmarking purposes, including comparisons to other organizations, e.g. within the same industry or geographical location.

Information provided by other sources

We may combine information from other sources with the information you give to us or we collect about you and use this information as specified above.
In relation to the above uses, we shall process your personal data on the legal basis determined by your organization or where it’s necessary for the purposes of our legitimate interests, including:
• to enable us to perform our contractual obligations under the Agreement;
• to improve or optimize our services;
• to maintain the security of our computer systems;
• to understand how the Platform is used and to improve the user experience of the Platform;
• to protect and defend our legal rights;
• for troubleshooting, and
• for data analysis, testing and research and development purposes.

Who we share personal data with

We may also share your personal data with selected third parties in accordance with this policy, including:
• Sub-processors, service providers (for example of IT services), business partners and/or suppliers for the performance of any contract that we enter into with your organization (such as the Agreement), including the following:
• Microsoft who provide cloud hosted infrastructure and services used by us to operate the Platform as a hosted solution.
• Microsoft Inc., Google LCC (Google Analytics), CreateShift Ltd (ProdPad), Zendesk Inc. who provide product tools and functionality used by us in delivery of the Platform and associated services.
• Government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information).
We require all our third party service providers to take appropriate and stringent security measures to protect your personal data in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.
We may also disclose your personal data to other third parties in the following circumstances:
• If we sell or buy any business assets or receive investment into our business, we may disclose your personal data to the prospective or actual buyer, seller or investee of such business or assets;
• If ELEARNINGFORCE International ApS or substantially all of its assets are acquired by a third party, in which case personal data held by us, including your data and data about our customers, suppliers and correspondents will be one of the transferred assets;
• We may disclose your personal data to our legal advisers if they need to have access to this information in order to advise us on our legal rights and obligations; and
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or other contracts between us and you or your employer; or to protect the rights, property or safety of us, our customers or others.

No personal data will ever be used or shared by ELEARNINGFORCE and/or Partners in respect to marketing.
Except as explained above, we will not disclose your personal data to any third parties for any other purpose unless we have a legal right or obligation to do so.

International data transfers

We may use service providers that are based outside the European Union and European Economic Area, most likely in the United States. We may transfer your personal data to such services in order to provide our services via the Platform.
We have put in place appropriate measures to ensure that your personal data are treated by such third parties in a way that is consistent with and which respects the EU laws on data protection, including putting in place written contractual agreements to meet EU-approved data protection obligations. If you require further information about these protective measures, please contact us at dataprotection@elearningforce.com.

Security

We maintain relevant technical and organizational measures to ensure an appropriate level of security in respect of all customer and personal data we process. Details about security and encryption and data breach procedures for our platforms and services are available for your organization online in our Trust Center.

Consent and retention period

Since your access to use the platform and your usage is administrated by your organization, the user consents required for the platform to function as intended is granted on behalf of you as a user by your organization.
Details of this administrative consent are specified for your organization online in our Trust Center.
General information for your organization about retention and deletion of data, e.g. on request or following termination of the Agreement is available online in our Trust Center.

Your rights in relation to personal data

As stated above our use and processing of your personal data is governed by the Agreement with your Organization. Even so, you always have certain rights in regards to your personal data, which are listed below.
• Access: You have the right to access information about the personal data we hold about you.
• Right to object to processing: You have the right to object to processing of your personal data.
• Rectification: You have the right to request rectification of inaccurate personal data held about you.
• Erasure: To the extent permitted by applicable data protection laws, you have the right to request erasure of personal data held about you.
• Request to restriction of processing: This enables you to request to restrict the processing of your personal data in certain circumstances.
• Portability: You have the right to obtain copies of your personal data to enable you to reuse your personal data across different services and with different companies.
• Automated processing: Not to be subject to a decision based solely on automated processing, including profiling (“Automated Decision-Making”).
In case you would like to exercise any of these rights in relation to your use of the platform and services we deliver to your organization, please contact your organization’s platform responsible directly.
Information for your organization about GDPR compliance with regards to their platform users’ personal data are available in our online Help Center.

Cookies & similar technologies

Our Platform uses cookies, which are small text files placed on your device, and similar technologies to distinguish you from other users. This helps us to provide you with a good experience when you use the Platform, and it also assists us in our efforts to improve the Platform. Cookies enables us to, among other things, store your preferences and settings; enable you to sign-in; combat fraud, and analyze our platform and services.
We use cookies specifically for authentication, application insights, and general platform analytics and diagnostics.
You have various tools to control cookies, and similar technologies, including your browser controls to block and delete cookies , e.g. from third-party analytics service providers, and to opt out of data collection through web beacons.
Your browser and other choices may impact your experiences with our services.

Changes to the Privacy Policy

Changes to the platform and services we deliver to your organization are released and communicated as specified in the agreement. In relation to platform and services updates and improvements, or for other reasons, we may update and amend our Privacy Policy from time to time.
Where we make 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.

How to contact us

Your organization’s use of our platform and services are typically administrated by certain people in your organization, who will have the responsibility to govern the usage. In most cases the platform responsible will be the point of contact for any questions or issues relating to use of the platform within your organization, including concerns relating to data processed via the platform. Usually it will also be this platform responsible who will be the point of contact between us and your organization, for instance relating to requests for support or professional services.
If your organization or you have questions to this Privacy Policy you are welcome to reach out to our responsible Compliance Officer via email to dataprotection@elearningforce.com or send your request via regular post services to ELEARNINGFORCE International, Mariane Thomsens Gade 4B, 5., 8000 Aarhus, Denmark.
We are committed to resolving any privacy concerns you may have. However, if you feel we have not addressed your specific concern, you have the right to make a complaint at any time to the relevant supervisory authority in your country responsible for data protection issues.