Privacy and Cookies Policy
1. Introduction
- 1.1 We are committed to safeguarding the privacy of our website visitors
and service users.
- 1.2 This policy applies where we are acting as a data controller with
respect to the personal data of our website visitors and service users; in other words, where we
determine the purposes and means of the processing of that personal data.
- 1.3 We use cookies on our website. Insofar as those cookies are not
strictly necessary for the provision of our website and services, we will ask you to consent to our use
of cookies when you first visit our website.
- 1.4 In this policy, "we", "us" and "our" refer to DigiBright Ltd. For more
information about us, see Section 17.
2. How we use your
personal data
- 2.1 In this Section 2 we have set out:
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- (a) the general categories of personal data that we may process;
- (b) in the case of personal data that we did not obtain directly from
you, the source and specific categories of that data;
- (c) the purposes for which we may process personal data; and
- (d) the legal bases of the processing.
- 2.2 We may process data about your use of our website and services
("usage data"). The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of visit, page views and website
navigation paths, as well as information about the timing, frequency and pattern of your service use.
The source of the usage data is our analytics tracking system Google Analytics and our own visitor
information logs. This usage data may be processed for the purposes of analysing the use of the website
and services. The legal basis for this processing is our legitimate interests, namely monitoring and
improving our website and services.
- 2.3 We may process your account data ("account data"). The
account data may include your name and email address. The source of the account data is you or your
employer. The account data may be processed for the purposes of operating our website, providing our
services, ensuring the security of our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is consent.
- 2.4 We may process your information included in your personal profile on
our website ("profile data"). The profile data may include your name, email address,
profile pictures, gender, date of birth, interests and hobbies. The profile data may be processed for
the purposes of enabling and monitoring your use of our website and services. The legal basis for this
processing is consent.
- 2.5 We may process your personal data that are provided in the course of
the use of our services ("service data"). The source of the service data is you or your
employer. The service data may be processed for the purposes of operating our website, providing our
services, ensuring the security of our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business.
- 2.6 We may process information that you post for publication on our website
or through our services ("publication data"). The publication data may be processed for
the purposes of enabling such publication and administering our website and services. The legal basis
for this processing is consent.
- 2.7 We may process information contained in any enquiry you submit to us
regarding goods and/or services ("enquiry data"). The enquiry data may be processed for
the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis
for this processing is our legitimate interests, namely the proper administration of our website and
business and communications with users.
- 2.8 We may process information relating to our customer relationships,
including customer contact information ("customer relationship data"). The customer
relationship data may include your name, your employer, your job title or role, your contact details,
and information contained in communications between us and you or your employer. The source of the
customer relationship data is you or your employer. The customer relationship data may be processed for
the purposes of managing our relationships with customers, communicating with customers, keeping records
of those communications and promoting our products and services to customers. The legal basis for this
processing is our legitimate interests, namely the proper management of our customer relationships.
- 2.9 We may process information relating to transactions, including
purchases of goods and services, that you enter into with us and/or through our website
("transaction data"). The transaction data may include your contact details, your card
details and the transaction details. The transaction data may be processed for the purpose of supplying
the purchased goods and services and keeping proper records of those transactions. The legal basis for
this processing is the performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract and our legitimate interests, namely the proper administration of
our website and business.
- 2.10 We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters ("notification data"). The
notification data may be processed for the purposes of sending you the relevant notifications and/or
newsletters. The legal basis for this processing is consent.
- 2.11 We may process information contained in or relating to any
communication that you send to us ("correspondence data"). The correspondence data may
include the communication content and metadata associated with the communication. Our website will
generate the metadata associated with communications made using the website contact forms. The
correspondence data may be processed for the purposes of communicating with you and record-keeping. The
legal basis for this processing is our legitimate interests, namely the proper administration of our
website and business and communications with users.
- 2.12 We may process any of your personal data identified in this policy
where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings
or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate
interests, namely the protection and assertion of our legal rights, your legal rights and the legal
rights of others.
- 2.13 We may process any of your personal data identified in this policy
where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or
obtaining professional advice. The legal basis for this processing is our legitimate interests, namely
the proper protection of our business against risks.
- 2.14 In addition to the specific purposes for which we may process your
personal data set out in this Section 2, we may also process any of your personal data where such
processing is necessary for compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
- 2.15 Please do not supply any other person's personal data to us, unless we
prompt you to do so.
3. Providing
your personal data to others
- 3.1 We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar
as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
- 3.2 Where one of our course programmes is sponsored by a third party, we
may disclose your personal data to them, but we will always inform you of this in the registration
process for that programme.
- 3.3 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of
legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- 3.4 We may disclose your enquiry data to one or more of those selected
third party suppliers of goods and services identified on our website for the purpose of enabling them
to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such
third party will act as a data controller in relation to the enquiry data that we supply to it; and upon
contacting you, each such third party will supply to you a copy of its own privacy policy, which will
govern that third party's use of your personal data.
- 3.5 In addition to the specific disclosures of personal data set out in
this Section 3, we may disclose your personal data where such disclosure is necessary for compliance
with a legal obligation to which we are subject, or in order to protect your vital interests or the
vital interests of another natural person. We may also disclose your personal data where such disclosure
is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or
in an administrative or out-of-court procedure.
4.
International transfers of your personal data
- 4.1 In this Section 4, we provide information about the circumstances in
which your personal data may be transferred to countries outside the European Economic Area (EEA).
- 4.2 The hosting facilities for our website, email and application services
may be situated in the UK, countries in Western Europe and the United States. The European Commission
has made an "adequacy decision" with respect to the data protection laws of each of these countries.
Transfers to each of these countries will be protected by appropriate safeguards, namely the use of
standard data protection clauses adopted or approved by the European Commission, a copy of which you can
obtain from:
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- 4.3 You acknowledge that personal data that you submit for publication
through our website or services may be available, via the internet, around the world. We cannot prevent
the use (or misuse) of such personal data by others.
5. Retaining and deleting
personal data
- 5.1 This Section 5 sets out our data retention policies and procedure,
which are designed to help ensure that we comply with our legal obligations in relation to the retention
and deletion of personal data.
- 5.2 Personal data that we process for any purpose or purposes shall not be
kept for longer than is necessary for that purpose or those purposes.
- 5.3 We will delete your personal data as follows:
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- (a) Users who cancel their account will have their personal data
(excluding email address) deleted within 48 hours of their request; we will need to retain a record
of the email address for security and spam prevention purposes.
- 5.4In some cases it is not possible for us to specify in advance the
periods for which your personal data will be retained. In such cases, we will determine the period of
retention based on the following criteria:
-
- (a) the period of retention of account data including name and email
address, as well as visitor data and logs will be determined based on the time necessary to carry
out the proper administration of our website and business and communication with users.
- 5.5 Notwithstanding the other provisions of this Section 5, we may retain
your personal data where such retention is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests of another natural
person.
6. Security of personal data
- 6.1 We will take appropriate technical and organisational precautions to
secure your personal data and to prevent the loss, misuse or alteration of your personal data.
- 6.2 We will store all your personal data on secure servers, personal
computers and mobile devices, and in secure manual record-keeping systems.
- 6.3 Access to personal data will be stored by us in encrypted form: your
name, contact information and password(s).
- 6.4 Data relating to your enquiries and financial transactions that is sent
from your web browser to our web server, or from our web server to your web browser, will be protected
using encryption technology.
- 6.5 You acknowledge that the transmission of unencrypted (or inadequately
encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data
sent over the internet.
- 6.6 You should ensure that your password is not susceptible to being
guessed, whether by a person or a computer program. You are responsible for keeping the password you use
for accessing our website confidential and we will not ask you for your password (except when you log in
to our website).
7. Amendments
- 7.1 We may update this policy from time to time by publishing a new version
on our website.
- 7.2 You should check this page occasionally to ensure you are happy with
any changes to this policy.
- 7.3 We may notify you of changes to this policy by email or through the
private messaging system on our website.
8. Your rights
- 8.1 In this Section 8, we have summarised the rights that you have under
data protection law. Some of the rights are complex, and not all of the details have been included in
our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory
authorities for a full explanation of these rights.
- 8.2 Your principal rights under data protection law are:
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- (a) the right to access;
- (b) the right to rectification;
- (c) the right to erasure;
- (d) the right to restrict processing;
- (e) the right to object to processing;
- (f) the right to data portability;
- (g) the right to complain to a supervisory authority; and
- (h) the right to withdraw consent.
- 8.3 You have the right to confirmation as to whether or not we process your
personal data and, where we do, access to the personal data, together with certain additional
information. That additional information includes details of the purposes of the processing, the
categories of personal data concerned and the recipients of the personal data. Providing the rights and
freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy
will be provided free of charge, but additional copies may be subject to a reasonable fee.
- 8.4 You have the right to have any inaccurate personal data about you
rectified and, taking into account the purposes of the processing, to have any incomplete personal data
about you completed.
- 8.5 In some circumstances you have the right to the erasure of your
personal data without undue delay. Those circumstances include: the personal data are no longer
necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw
consent to consent-based processing; you object to the processing under certain rules of applicable data
protection law; the processing is for direct marketing purposes; and the personal data have been
unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions
include where processing is necessary: for exercising the right of freedom of expression and
information; for compliance with a legal obligation; or for the establishment, exercise or defence of
legal claims.
- 8.6 In some circumstances you have the right to restrict the processing of
your personal data. Those circumstances are: you contest the accuracy of the personal data; processing
is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment, exercise or defence of legal claims;
and you have objected to processing, pending the verification of that objection. Where processing has
been restricted on this basis, we may continue to store your personal data. However, we will only
otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for
the protection of the rights of another natural or legal person; or for reasons of important public
interest.
- 8.7 You have the right to object to our processing of your personal data on
grounds relating to your particular situation, but only to the extent that the legal basis for the
processing is that the processing is necessary for: the performance of a task carried out in the public
interest or in the exercise of any official authority vested in us; or the purposes of the legitimate
interests pursued by us or by a third party. If you make such an objection, we will cease to process the
personal information unless we can demonstrate compelling legitimate grounds for the processing which
override your interests, rights and freedoms, or the processing is for the establishment, exercise or
defence of legal claims.
- 8.8 You have the right to object to our processing of your personal data
for direct marketing purposes (including profiling for direct marketing purposes). If you make such an
objection, we will cease to process your personal data for this purpose.
- 8.9 You have the right to object to our processing of your personal data
for scientific or historical research purposes or statistical purposes on grounds relating to your
particular situation, unless the processing is necessary for the performance of a task carried out for
reasons of public interest.
- 8.10 To the extent that the legal basis for our processing of your personal
data is:
-
- (a) consent; or
- (b) that the processing is necessary for the performance of a contract
to which you are party or in order to take steps at your request prior to entering into a contract,
- and such processing is carried out by automated means, you have the right to receive your personal
data from us in a structured, commonly used and machine-readable format. However, this right does
not apply where it would adversely affect the rights and freedoms of others.
- 8.11 If you consider that our processing of your personal information
infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of your habitual residence, your
place of work or the place of the alleged infringement.
- 8.12 To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at any time. Withdrawal will not
affect the lawfulness of processing before the withdrawal.
- 8.13 You may exercise any of your rights in relation to your personal data
by written notice to us, in addition to the other methods specified in this Section 8.
9. Third party websites
- 9.1 Our website includes hyperlinks to, and details of, third party
websites.
- 9.2 We have no control over, and are not responsible for, the privacy
policies and practices of third parties.
10. Personal data of
children
- 10.1 Our website and services are targeted at persons over the age of 16.
- 10.2 If we have reason to believe that we hold personal data of a person
under that age in our databases, we will delete that personal data.
11. Updating information
- 11.1 Please let us know if the personal information that we hold about you
needs to be corrected or updated.
12. Acting as a data
processor
- 12.1 In respect of May 25th 2018, we may sometimes act as a data processor
rather than a data controller.
- 12.2 Insofar as we act as a data processor rather than a data controller,
this policy shall not apply. Our legal obligations as a data processor are instead set out in the
contract between us and the relevant data controller.
13. About cookies
- 13.1 A cookie is a file containing an identifier (a string of letters and
numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is
then sent back to the server each time the browser requests a page from the server.
- 13.2 Cookies may be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until its set expiry date,
unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at
the end of the user session, when the web browser is closed.
- 13.3 Cookies do not typically contain any information that personally
identifies a user, but personal information that we store about you may be linked to the information
stored in and obtained from cookies.
14. Cookies that we use
- 14.1 We use cookies for the following purposes:
-
- (a) personalisation - we use cookies to store information about your
preferences and to personalise our website for you. Cookies used for this purpose are:
digib: Used to recognise a computer when a user visits our website,
improve the website's usability;
rv: Used to recognise a computer when a user visits our website, improve
the website's usability;
- (b) security - we use cookies as an element of the security measures
used to protect user accounts, including preventing fraudulent use of login credentials, and to
protect our website and services generally. Cookies used for this purpose are:
__cfdid: Cloudflare cookie, used to identify individual clients behind a
shared IP address and apply security settings on a per-client basis;
- (c) analysis - we use cookies to help us to analyse the use and
performance of our website and services. Cookies used for this purpose are: _ga,
_gid, ai_session, ai_user; and
- (f) cookie consent - we use cookies to store your preferences in
relation to the use of cookies more generally. Cookies used for this purpose are:
digib-cookiebanner-accepted.
15.
Cookies used by our service providers
- 15.1 Our service providers use cookies and those cookies may be stored on
your computer when you visit our website.
- 15.2 We use Google Analytics to analyse the use of our website. Google
Analytics gathers information about website use by means of cookies. The information gathered relating
to our website is used to create reports about the use of our website. Google's privacy policy is
available at: https://www.google.com/policies/privacy/. The relevant cookies
are: _ga, _gid.
16. Managing cookies
- 16.1 Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and from version to version. You can
however obtain up-to-date information about blocking and deleting cookies via these links:
-
- 16.2 Blocking all cookies will have a negative impact upon the usability of
many websites.
- 16.3 If you block cookies, you will not be able to use all the features on
our website.
17. Our details
- 17.1 This website is owned and operated by DigiBright Ltd.
- 17.2 You can contact us at [email protected]
18.
Data protection registration
- 18.1We are registered as a data controller with the UK Information
Commissioner's Office.
- 18.2 Our data protection registration number is ZA779058.
19. Representative
within the European Union
- 19.1 Our representative within the European Union with respect to our
obligations under data protection law is Ms Efua Akumanyi and you can contact our representative by
emailing [email protected].
20. Data
protection officer
- 20.1 Our data protection officer's contact details are:
[email protected]. Any such queries are passed to Ms Efua Akumanyi.
