Privacy Policy

We all want our personal information to be secure and here is our policy that outlines how we use and store yours.

Wahoo Learning Limited, is a company registered in England and Wales (company number 10018280) whose registered office is at 13 Northern Way, Cropmead, Crewkerne, Somerset, TA18 7HJ. References to we, us and our means Wahoo Learning Limited. We are registered with the Information Commissioners Office with reference number Z9651070.

This privacy notice describes the ways we capture your personal data and governs what we will do with it. We want to be upfront about the data we collect, how we use it, who we share it with and the choices we give you to control, access and update your data.

Our role in your privacy

If you are a customer, or just visiting our website, this policy applies to you.

Our responsibilities:

If you are a registered customer or a visitor to our website we act as the ‘controller’ of your personal data. This means we determine how and why your data are processed.

Your responsibilities:

  • Read this Privacy Policy
  • If you are our customer, please also check the contracts between us, such as the Website Terms of Use: they may contain further details on how we collect and process your data.
  • If you provide us with personal data about other people, or if others give us your data , we will only use that data for the specific reason for which it was provided to us. By submitting the data, you confirm that you have the right to authorise us to process it on your behalf in accordance with this Privacy Policy.

 Wahoo Learning Limited contact details

Name: Donna Drew (Data privacy manager)

Postal address: 13 Northern Way, Crewkerne, TA18 7HJ

Telephone number: 01460 279927

Email: contact@wahoolearning.com

You 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 1st May 2019 We may be required to make changes this Privacy Policy at any time. While significant changes will be notified to our users by email, we request that your check back here occasionally to view more minor changes.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications.

Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

The personal data we collect and use

We ensure that your privacy is respected at all times and our primary goal is to improve upon and make sure our services and messaging are relevant for all our users, while also ensuring that personal data of all users is respected and protected.

When and how we collect data

We collect the majority of your personal data directly from you, via the website. However, we may also automatically collect personal data from cookies on our website – for more information on our use of cookies, please see the section on cookies, below.

Here’s when and how we do this:

  • You browse any page of our website
  • You purchase training on our site
  • You contact us
  • You receive emails from us
  • You chat with us for customer support
  • You opt-in to marketing messages

Types of data we collect

This privacy notice applies to the personal data we collect about you through the Platform, by telephone, in person, or when you otherwise communicate with us. In particular, we collect your:

Business data

This includes the name of the business you work for, the business address and contact details, details of associations with parent or subsidiary companies and the primary company contact.

Contact details

Your name, address, telephone number, email address.

Marketing and communications data

This includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

Device and browser data

We collect data from the device and application you use to access our website. Device data mainly means your IP address, operating system version, device type, system and performance information, and browser type. If you are on a mobile device we also collect the UUID for that device. All data relating to your device and browser is anonymous and will never contain your contact details.

Usage data

This includes which webpages you visit, what you click on, when you perform those actions, what language preference you have, and so on. All usage data is anonymous and will never contain your contact details.

Log files

Our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our website (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps. All log data is anonymous and will never contain your contact details.

Information from page tags

We use third-party tracking services that employ cookies and page tags to collect data about visitors to our websites. This data includes usage and user statistics. Emails sent by us or by users through our services include page tags that allow the sender to collect information about who opened those emails and clicked on links in them.

Information from third parties and integration partners

Our website connects directly with third-party websites so that we can better understand the use of our website, and to show you relevant content, including ads.

 

What about really sensitive data?

We don’t collect any “sensitive data” about you (like racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offences or alleged offences) except when we have your specific consent, or when we must to comply with the law.

What about children’s data?

We generally provide a business-to-business service directed to and intended for use only by those who are 18 years of age or over. We do not target the our services at children, and we do not knowingly collect any personal data from any person under 16 years of age.

How and why we use your data

Data protection law means that we can only use your data for certain reasons and where we have a legal basis to do so. Here are the reasons for which we process your data:

Business data

We use your business data to:

  • maintain an accurate training record for the business; and
  • for analytical and statistical purposes

Legal basis: contract | legitimate interests

Contact details

We use your contact details:

  • to enable you to register for an account;
  • to enable you to use the services;
  • for analytical and statistical purposes;
  • where you have consented, to direct market to you about other services we provide; and
  • to contact you for feedback about our services

Legal basis: contract | legitimate interests | consent

Marketing and communications data

This includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Legal basis: consent | legitimate interests

Device and browser data

We use device and browser data to troubleshoot problems with our website and to make improvements to it, or to customise the interface for that device. We also infer your geographic location based on your IP address for abuse and tax purposes.

Legal basis: legal requirement | legitimate interests

Usage data

We collect data about the types of content you engage with so we can direct you to other relevant features and services we offer.

Legal basis: legitimate interests

Log files

We use log data for many different business purposes, including:

  • monitoring abuse and troubleshooting;
  • tracking behaviour at the aggregate/ anonymous level to identify and understand trends in the various interactions with our website; and
  • fixing bugs and troubleshooting functionality

Legal basis: legitimate interests

Information from page tags

We collect data from page tags to enable us to:

  • understand our users’ behaviour; and
  • determine the success of our advertising campaigns

Legal basis: legitimate interests

Information from third parties and integration partners

We collect and use data from third parties and integration partners to:

  • ensure you can sign-up to the platform from a third-party integration; and
  • ensure you can use our website in conjunction with other services.

Legal basis: legitimate interests

Here is what each of these “legal bases” mean:

Consent

You have given clear consent for us to process your personal data for a specific purpose.

You can change your mind!

If you have previously given consent to our processing your data, you can freely withdraw such consent at any time. You can do this by updating preferences in your user profile, or emailing us at contact@wahoolearning.com.

If you do withdraw your consent, and if we do not have another legal basis for processing your data, then we will stop processing your personal data. If we do have another legal basis for processing your data, then we may continue to do so subject to your legal rights.

Contract

Processing your data is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.

Legal requirement

The law otherwise permits or requires it.

Legitimate interests

Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests. These legitimate interests are:

  • Gaining insights from your behaviour on our website or in our app
  • Delivering, developing and improving the Platform
  • Enabling us to enhance, customise or modify our services and communications
  • Determining whether marketing campaigns are effective
  • Enhancing data security

In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests

Communications

This section explains how we will ensure that you only receive communications that you wish to receive

Marketing communications:

We can only use your personal data to send you marketing messages if we have either your consent or it is a ‘legitimate interest’. Such as where you are an existing customer and have not opted out of marketing.

The personal data we hold about you is made up of what you tell us and the data we collect about you when you use our services, or data provided to us from third parties we work with. We study this 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.

By consenting to receive additional communications (by post, telephone, or email) from us and any named third parties that feature at the point of obtaining consent in respect of such data, we will process your personal data in accordance with this privacy policy.

If you have provided your consent to receive marketing communications from us and you change your mind, you can change your preferences and unsubscribe at any time by unsubscribing from the relevant communication channel or by contacting us at contact@wahoolearning.com. If you choose not to receive this information, we will be unable to keep you informed of new products, services and promotions that may interest you.

Service communications:

We may send you communications such as those which relate to any service updates (e.g. appointment confirmations) or provide customer satisfaction surveys. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely to effectively provide you with the best service we can and to grow our business.

Your privacy choices and rights

Your choices:

You can choose not to provide us with personal data

If you choose to do this, you can continue to use the website and browse its pages, but we will not be able to process transactions, allow you to log in or provide you with any training without personal data.

You can turn off cookies in your browser by changing its settings

You can block cookies by activating a setting on your browser allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off cookies, you can continue to use the website and browse its pages, but you will not be able to log in the Platform and certain services (like SnapEngage and Groove, which are customer support tools) will not work effectively.

You can ask us not to use your data for marketing

We will inform you (before collecting your data) if we intend to use your data for marketing and if third parties are involved. You can opt out from marketing by using the link in the email, by updating your marketing preferences of your user profile, or emailing us at contact@wahoolearning.com.

Your rights:

You can exercise your rights by sending us an email at contact@wahoolearning.com.

You have the right to access data we hold about you

This includes the right to ask us supplementary information about:

  • The categories of data we’re processing
  • The purposes of data processing
  • The categories of third parties to whom the data may be disclosed
  • How long the data will be stored (or the criteria used to determine that period)
  • Your other rights regarding our use of your data

We will provide you with the data within one month of your request, unless doing so would adversely affect the rights and freedoms of other (e.g. another person’s confidentiality or intellectual property rights). We’ll tell you if we can’t meet your request for that reason.

You have the right to make us correct any inaccurate personal data about you

You can update much of your personal data from your Profile page if you have a user account, or emailing us at contact@wahoolearning.com.

You can object to us using your data for profiling you or making automated decisions about you

We may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behaviour). Otherwise, the only circumstances in which we will do this is to provide the Platform service to you.

You have the right to port your data to another service

We will give you a copy of your data in CSV or JSON so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you. We will not do so to the extent that this involves disclosing data about any other individual.

You have the right to be ‘forgotten’ by us

You can do this by asking us to erase any personal data we hold about you, if it is no longer necessary for us to hold the data for purposes of your use of the Platform.

You have the right to lodge a complaint regarding our use of your data

Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the UK Information Commissioner’s Office, either by calling their helpline or as directed on their website at www.ico.org.uk.

How secure is the data we collect?

We have physical, electronic, and managerial procedures to safeguard and secure the data we collect and have been awarded a Cyber Essentials certificate from the UK National Cyber Security Centre. Certificate no: QGCE1425 We limit access to your personal data to those who have a genuine business need to know it. Those processing your data will do so only in an authorised manner and are subject to a duty of confidentiality.

If you want detailed information from Get Safe Online on how to protect your data and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Please remember:

  • You provide personal data at your own risk: unfortunately, no data transmission is guaranteed to be 100% secure
  • You are responsible of your username and password: keep them secret and safe!
  • If you believe your privacy has been breached, please contact us immediately on contact@wahoolearning.com.

Where do we store the data?

The personal data we collect is processed at our offices in the UK and in any data processing facilities operated by the third parties identified below.

How long do we store your data?

We will keep your personal data for no longer than is necessary for the purposes for which it was obtained. The criteria for determining the duration for which we will retain your personal data is as follows:

  1. We will retain your personal data in a form that permits identification only for as long as:
    1. we maintain an ongoing relationship with you; or
    2. your personal data is necessary in connection with the lawful purposes set out in this privacy notice for which we have a valid legal basis;
    3. The duration of:
      1. any applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against us in connection with your personal data , or to which your personal data may be relevant); or
      2. an additional reasonable period following the end of such applicable limitation period;
  2. If any relevant legal claims are brought, we may continue to process your personal data for such additional periods as are necessary in connection with that claim.

During the periods specified in paragraph 1(iii) above, we will restrict our processing of your personal data to the storage of, and maintaining the security of, that data, except to the extent that data needs to be reviewed in connection with any legal claim or obligation under applicable law.

After this period your personal data will be anonymised so that you are no longer identified or identifiable from such information, or securely deleted/destroyed.

We may retain personal data about you for statistical purposes. Where data is retained for statistical purposes it will always be anonymised, meaning that you will not be identifiable from that data.

Third parties who process your data

Tech businesses often use third parties to help them host their application, communicate with customers, power their emails etc. We partner with third parties who we believe are the best in their field at what they do.

When we do this, sometimes it is necessary for us to share your data with them in order to get these services to work well. Your data is shared only when strictly necessary and according to the safeguards and good practices detailed in this Privacy Policy.

Your personal data may be stored and processed in any country where we engage service providers, including outside the EEA. Whilst these counties will have data protection rules that differ from the EEA, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal data remains protected to the standards described in this privacy policy.

If you would like further information about who we share your personal data with, please contact us.

Here are the details of our main third-party service providers, and what data they collect or we share with them, where they store the data and why they need it:

Infrastructure

Service provider Data collected or shared Purpose Place of processing
Amazon AWS
  • Contact details
  • Your record of learning
  • Data that identifies you
This is a web hosting provider: we use it to host are webservers and databases. US
Rackspace
  • Contact details
  • Your record of learning
  • Data that identifies you
This is a web hosting provider: we use it to host are webservers and databases. EU
Dalaric
  • Contact details
  • Your record of learning
  • Data that identifies you
Provides web application development, testing and maintenance services. EU

Analytics

Service provider Data collected or shared Purpose Place of processing
Google Analytics
  • Contact details
  • How you use the Platform
  • Data that identifies you
  • Cookies
GoogleAnalytics is a web analytics service: we use it to track your use of the service, and prepare reports on user activity. US
Facebook
  • Data on how you use the Platform
  • How you use the Platform
  • Cookies
This is a web analytics service: we use it to track your use of the service, and prepare reports on user activity. EU

Comms

Service provider Data collected or shared Purpose Place of processing
SnapEngage
  • Contact details
  • Data that identifies you
  • Cookies
We use this service for sending, storing and tracking online ‘webchats’. US
Groove
  • Contact details
  • Data that identifies you
  • Cookies
We use this service for customer communications, user interaction and helpdesk assistance. US
ZoHo Sales IQ
  • Contact details
  • Data on how you use the Platform
  • Cookies
We use this service for customer communications, hosting landing pages and sending marketing emails to those who have opted in. US
Mailchimp
  • Contact details
  • Data that identifies you
  • Data on how you use the Platform
We use this service to store email addresses for our mailing list and send email communications to our users. EU and US

Cookies

We use cookies. Unless you adjust your browser settings to refuse cookies, we (and these third parties) will issue cookies when you interact with the Platform. These may be ‘session’ cookies, meaning they delete themselves when you leave the Platform, or ‘persistent’ cookies which do not delete themselves and help us recognise you when you return so we can provide a tailored service.

How can I block cookies?

You can block cookies by activating a setting on your browser allowing you to refuse the setting of cookies. You can also delete cookies through your browser settings. If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website will not function fully. In some cases, our website may not be accessible at all. Please note that where third parties use cookies we have no control over how those third parties use those cookies.

Which specific third-party cookies do we use?

Service provider Purpose
Google, Inc.

Google Analytics uses cookies allows us to see information on the activities of visitors to our website and users of our service, including page views, source and time spent on the Platform. The information is depersonalized and is displayed as numbers, meaning it cannot be tracked back to individuals. This will help to protect your privacy.

To opt out of being tracked by Google Analytics across all websites click here.

Browser Update Browser-update is a tool to collect information about your browser and notify visitors that they should update their web browser in order to use your website.
Zoho SalesIQ Cookies are used to gather site usage information and to allow us to make improvements to our services.

 

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