eThink and Learning Light Privacy Policies

Contacting eThink via the contact form at learninglight.com will send details of your enquiry to eThink Education and Learning Light Ltd.

OUR COMMITMENT TO YOUR PRIVACY

eThink and Learning Light respect your privacy. Because we gather certain types of information about our users, we feel you should fully understand the terms and conditions surrounding the capture and use of that information. More information about how we use collected data is included in these privacy policies:

 

eThink Education Privacy Policy

Effective date: 8/28/2018
Last updated: 9/06/2019*

eThink Education (further referred to as eThink) prepared this Privacy Policy to provide an overview of the personal information we may collect from users and how we process and/or use that information. The use of personal information collected through our services shall be limited to the purposes described in this Privacy Policy.

IMPORTANT NOTICE FOR USERS: This Privacy Policy does not govern the collection, use, or disclosure of personal information through the Service by the organization or institution which has given you (or your child) access to the service, or which is providing a course you are taking via eThink’s services. Please contact the controlling organization to better understand its privacy practices. eThink will retain personal information we process on behalf of organizations for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

FOR EU AND EEA RESIDENTS

eThink complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (“EU”) and Switzerland to the United States (“U.S.”) respectively, as that term is defined in the Privacy Shield Framework. eThink has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. We are committed to subjecting all personal data received from the EU and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield: https://www.privacyshield.gov.

eThink’s privacy policy, provided below, describes the types of personal information that we collect, the types of third parties to which we disclose personal data, and the purposes for which we do so. eThink collects contact and demographic information to respond to requests or to personalize and deliver the services. eThink transfers this information to third parties acting as an agent on our behalf. We are accountable for the processing of personal data we receive, under the Privacy Shield Framework, and subsequently transfer to a third party. eThink complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

Residents of the EU and Switzerland have the right to access the personal information that eThink maintains, and in some cases, may have the right to correct or amend information that is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, contact us using the up-to-date contact information listed below.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, eThink is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, eThink may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Residents of the EU and Switzerland with inquiries or complaints regarding this Privacy Policy should first contact eThink at:

jeremy.schweitzer@ethinkeducation.com or 515-989-1324

We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

DATA YOU PROVIDE TO US

We collect information from you, such as first and last name and e-mail address when you create an account to log in to one of our services or support tools. We may also collect mailing addresses, phone numbers, professional title, company name, user names, and a password, as needed to provide services.

We also may retain information on your behalf, such as files and messages that you store using your account. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail. We also collect other types of personal information and demographic information that you provide to us voluntarily.

DATA COLLECTED VIA TECHNOLOGY

To make our services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including browser type, operating system, Internet Protocol (IP) address, referring domain name, unique device identifiers, information about how you use our Services and/or a date/time stamp for your visit. We also use cookies and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed. We automatically gather this data and store it in log files each time you use our services.

In accepting this Privacy Policy, you consent to our placement and continued use of cookies on your device.

Internet cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our websites.

Services we use (such as Google Analytics) may use cookies and/or scripts to collect and store information such as how users interact with our services, browser and site performance metrics, errors users encounter when using our services, device identifiers, how often users visit the websites, what pages they visit, and what other sites they used prior to coming to the websites. We use the information we get from Google Analytics only to improve our websites and services. Please see the following links for more information about Google Analytics: http://www.google.com/privacy_ads.html, http://www.google.com/privacy.html, and http://www.google.com/analytics/tos.html. We do not tie the information gathered using third party analytics to your personal information.

Managing cookies:

  • Most web browsers are set to accept cookies by default. You can usually remove and reject cookies from our site via your browser settings. If you remove or reject our cookies, it may affect how our websites and services work.
  • If you do not wish us to track emails we send you, some email services allow you to adjust your display to turn off HTML or disable download of images which should effectively disable our email tracking, or you may unsubscribe from our marketing emails.
  • You may opt out of tracking of certain information collected by Google Analytics, one of our analytics providers as discussed above, by clicking here.

While we and others give you the choices described in this Privacy Policy, there are many ways web browser signals and other similar mechanisms can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism.

USE OF YOUR DATA

Personal information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. eThink uses your personal information in the following ways: to create and maintain your account; to identify you as a user in our system; to process support tickets that you may initiate; to operate, maintain, and improve our services; to personalize and improve your experience; to send you administrative e-mail; to respond to your comments or inquiries; to send you surveys, promotional communications about our products and services with your permission; to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and to make telephone calls to you, or to solicit your feedback with your permission. We may use data which has been de-identified and aggregated data for additional purposes.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We will share your personal information with third parties only in the ways that are described as follows or with your express consent.

AFFILIATES

eThink Education LTD is an UK based subsidiary of eThink Education LLC and  we may share some or all of your information with this and any future Affiliates, in which case we will require our Affiliates to honor this Privacy Policy.

THIRD PARTY SERVICE PROVIDERS

We may share your personal information with third party service providers for the sole purpose of providing you with the services that we provide. For example, we may share data with service providers who host our websites (such as Rackspace or Amazon Web Services), provide client relationship management service (Zendesk), or provide email services on our behalf.

CLIENT ORGANIZATIONS (EDUCATIONAL INSTITUTIONS, COMPANIES, AND SIMILAR ORGANIZATIONS)

We will share your information with the educational institution, corporation, or organization (the data controller) which is linked to your use of eThink’s services. In this context eThink is a data processor. For example, this would apply:

  • If your educational institution hosts Moodle or Totara with us and has given you access to the system
  • Your employer uses eThink to host its learning management system.

OTHER DISCLOSURES

eThink may disclose information about you if it believes such disclosure is necessary to (a) comply with laws or to respond to lawful requests and legal process; or (b) protect or defend the rights, safety, or property of eThink, users of our services, or any person including to enforce our agreements, policies, and terms of use, or (c) in an emergency to protect the personal safety of any person.

We may also share de-identified and aggregated data with others for their own uses.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

MARKETING CHOICES: By accepting this Privacy Policy when submitting your personal information, you consent to us contacting you with newsletter and promotions by email. When you receive newsletters or promotional communications from us, you may “opt-out” by following the unsubscribe instructions provided in e-mails you receive from us or by contacting us directly at the contact information below. You do not have to provide us with any personal information, however if you do not do so we may not be able to provide services to you.

SECURITY OF YOUR PERSONAL INFORMATION: eThink takes reasonable steps to help protect your personal information in an effort to prevent unauthorized access, use, or disclosure. Despite these measures, you should know that eThink cannot fully eliminate security risks associated with personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. Any content you post while using our services is at your own risk.

CHANGES TO THIS PRIVACY POLICY

eThink may change this Privacy Policy from time to time. If we make any changes to this Policy, we will change the “Last Updated” date above. If such changes are material, a notice of the changes will be posted along with the revised Privacy Policy. All efforts will be made to post changes prior to the change becoming effective. We encourage you to visit this page from time to time for the latest on our privacy practices.

If you have any questions or concerns about this privacy policy, please contact us using the information below:

jeremy.schweitzer@ethinkeducation.com

 

* Updated to acknowledge our UK subsidiary. See Affiliates section for details.

 

Learning Light Privacy Policy

Learning Light Limited is committed to data security and the fair and transparent processing of personal data.

This privacy policy (Policy) sets out how we will treat the personal data which you provide to us in compliance with applicable data protection law, in particular the General Data Protection Regulation (EU) 2016/679 (GDPR).

Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data, how to contact us and supervisory authorities in the event that you would like to report a concern about the way in which we process your data.

 

Who are we?

Learning Light Limited (company number: 5535941) has its registered office at:
500 Charlotte Road, Lowfield, Sheffield S2 4ER, UK. 

For the purposes of the GDPR, Learning Light is the ‘controller’ of the personal data you provide to us

If you have any queries about this Policy, the way in which Learning Light Limited processes personal data, or about exercising any of your rights, please send an email to info@learninglight.com or write to us at:
Learning Light Limited, Suite 21, Sheffield Technology Parks, Arundel St, Sheffield S1 2NS

Learning Light owns and operates www.learninglight.com and www.e-learningcentre.co.uk  This Policy, together with our Website terms of use and any other documents referred to in them, sets out the basis on which Learning Light processes personal data.

 

What personal data do we collect?

We may collect and process the following personal data:

1. Information you provide to us if you:

  • complete a form on our Websites
  • complete a survey
  • correspond with us by phone, e-mail, or in writing
  • report a problem
  • sign up to receive our communications
  • create an account with us
  • enter into a contract with us to receive products and/or services

2. Your name, e-mail address, postal address, telephone number and job role.

Information we collect about you

If you visit our Website, we may automatically collect the following information:

  • technical information, including the internet protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
  • information about your visit to our Website such as the products and/or services you searched for and view, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Information we receive from other sources

We may also receive information about you if you use any of the other websites we operate or the other services we provide.

If you are an assessor, tutor, or learner, we may also receive information about you from awarding bodies, or employer when they register to receive products and/or services form us.

Information about other people 
If you provide information to us about any person other than yourself, such as your relatives, next of kin, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

Sensitive personal data
In certain limited cases, we may collect certain sensitive personal data from you (that is, information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, or details of criminal offences, or genetic or biometric data).  However, we will only do so on the basis of your explicit consent.

How do we use your personal data?
When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.

Contract performance: we may use your personal data to fulfil a contract, or take steps linked to a contract:

  • to provide the products and/or services to you
  • to communicate with you in relation to the provision of the contracted products and services
  • to provide you with administrative support such as account creation, security, and responding to issues
  • provide you with industry information, surveys, information about our awards and events, offers and promotions, related to the products and/or services.

Legitimate interests: where this is necessary for purposes which are in our, or third parties, legitimate interests.  These interests are:

  • providing you with newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered
  • communicating with you in relation to any issues, complaints, or disputes
  • improving the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our Website
  • performing analytics on sales/marketing data, determining the effectiveness of promotional campaigns.

NOTE: you have the right to object to the processing of your personal data on the basis of legitimate interests as set out below, under the heading Your rights.

Consent:  where you have given your express consent to receive marketing communications, we may use your personal data to:

send you newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered by a member of the Learning Light Limited which may be of interest to you;

developing, improving, and delivering marketing and advertising for products and services offered by a member of the Learning Light Limited.

Where required by law:  we may also process your personal data if required by law, including responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.

 

Who do we share your personal data with?

We may share your personal data with members of the Learning Light Limited. You can read more about our us at learninglight.com

We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations.  We limit access to your personal data to those who have a genuine business need to know it.

We may also share your personal data with trusted third parties including:

  • legal and other professional advisers, consultants, and professional experts
  • service providers contracted to us in connection with provision of the products and services such as providers of IT services and customer relationship management services
  • analytics and search engine providers that assist us in the improvement and optimisation of our Website.

We will ensure there is a contract in place with the categories of recipients listed above which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.

Where a third party recipient is located outside the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws.

We will share personal data with law enforcement or other authorities if required by applicable law.

 

How long will you keep your personal data?

Where there is a contract between us, we will retain your personal data for the duration of the contract, and for a period of six years following its termination or expiry, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.

Where you have consented to marketing communications, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us.

 

Where do we store your personal data and how is it protected?

We take reasonable steps to protect your personal data from loss or destruction.  We also have procedures in place to deal with any suspected data security breach.  We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Where you have a username or password (or other identification information) which enables you to access certain services or parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

 

Your rights

Under the GDPR, you have various rights with respect to our use of your personal data:

Right to Access

You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below.  Please include with your request information that will enable us to verify your identity.  We will respond with 30 days of request.  Please note that there are exceptions to this right.  We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information. Or if your request is manifestly unfounded or excessive.

Right to rectification

We aim to keep your personal data accurate and complete.  We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.

Right to erasure

You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed.  If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to object

In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes.  If you would like to object to the pressing of your personal data, please contact us using the contact details provided below.

Right to restrict processing

In certain circumstances, you have the right to request that we restrict the further processing of your personal data.  This right arises where, for example, you have contested the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted.  Please contact us using the contact details provided below.

Right to data portability

In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.  This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request that your personal data is ported to you, please contact us using the contact details provided below.

Please note that the GDPR sets out exceptions to these rights.  If we are unable to comply with your request due to an exception we will explain this to you in our response.

 

Contact

If you have any queries about this Policy, the way in which Learning Light Limited processes personal data, or about exercising any of your rights, please send an email to info@learninglight.com or write to us at:
Learning Light Limited, Suite 21, Sheffield Technology Parks, Arundel St, Sheffield S1 2NS, UK.

 

Complaints

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint the applicable supervisory authority or to seek a remedy through the courts.

Please visit https://ico.org.uk/concerns/ for more information on how to report a concern to the UK Information Commissioner’s Office.

 

Changes to our Policy

Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Policy.