Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data We Gather
Data You Provide To Us
|Account Data||In order to use certain features on our site you need to create a user account. When you create or update your account, we collect and store the data you provide, like your first name, last name, email address and password and assign you a unique identifying number (“Account Data”).|
|Profile Data||Your first name will be publicly viewable by others should you choose to post in our forums.|
|Shared Content||Parts of the Services let you interact with other users or share content publicly, including asking or answering questions in our forums. Such shared content may be publicly viewable by others depending on where it is posted.|
|Course Data||When you enroll in and take courses, we collect certain data including which courses, assignments and quizzes you’ve started and completed; your exchanges with instructors; your progress in a course; your grades; and other items submitted to manage and execute your course experience.|
|Payment Data||If you make purchases, we collect certain data about your purchase (such as your name and zip code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partner, Stripe, including your name, credit card information, and zip code. For security, Learning Markets does not collect or store sensitive cardholder data, such as any part of your credit card number or card authentication data. All of this information is stored with our credit card processing partner.|
|Data About Your Accounts on Other Services||
We use Gravatar to fetch a profile photo of you. This means you provide consent to Gravatar to display your profile photo and we use your email address to identify you and fetch this information from Gravatar.
Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.
If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your shopping cart information, your IP address, your course progress history and grades (if there is any) etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged or collected by automated means, including:
|System Data||Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”).|
|Usage Data||Usage statistics about your interactions with the Services, including courses accessed, time spent on pages or the Service, pages visited, click data, date and time, and other data regarding your use of the Services (“Usage Data”).|
|Approximate Geographic Data||An approximate geographic location, including information like country, calculated based on your IP address.|
Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds. See the list of our partners here.
How We Get Data About You
2.1 Cookies and Data Collection Tools
We use the following types of cookies:
cookies used to enable you to log in and access the Services; protect against fraudulent logins; and help detect and prevent abuse or unauthorized use of your account.
cookies that store functional settings (like the volume level you set for video playback).
cookies that track your interactions with the Services to help us improve the Services and your browsing experience, remember your login details, and enable processing of your course purchases and updating your progress in a course. These are strictly necessary for the Services to work properly, so if you disable them then certain functionalities will break or be unavailable.
We use third-party browser and mobile analytics services like Google Analytics. These services use Data Collection Tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services and usage and performance data. We use this data to improve the Services, better understand how the Services perform on different devices, and provide information that may be of interest to you.
What We Use Your Personal Data For
We use your Personal Data in order to:
- provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- enhance your customer experience;
- fulfill an obligation under law or contract;
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- to identify you;
- to provide you a service or to send or offer you a product;
- to communicate with you about your account by:
- Responding to your questions and concerns;
- Sending you administrative messages and information, including messages from instructors, notifications about changes to our Service, and updates to our agreements;
- Sending you information about your progress in courses, new features, newsletters, and other available courses (which you can opt out of at any time);
- to track your progress in a course;
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
- to send you information and reminders about upcoming webinars and events;
- to administer and analyze our customers (purchasing behavior and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
- to conduct questionnaires concerning client satisfaction;
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters and campaign offers;
- to send you grading and other course notifications;
- for other purposes we have asked your consent for;
We Process your Personal Data in order to fulfill obligations rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymize Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymized.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and
- there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
Who Can Access Your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We share your data with:
Our processing partners:
Our business partners:
During a change in control
- If Learning Markets undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
- We can disclose or use aggregate or de-identified data for any purpose.
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
Embedded content from other websites
Articles or other pages on this site may include embedded content (e.g. charts, help and feedback widgets etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
How We Secure Your Data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use trusted partners such as Amazon S3 for our web data infrastructure. We use anonymizing and pseudonymizing where suitable. We monitor our systems for possible vulnerabilities and attacks. Where applicable, relevant data is not stored on Learning Markets servers but rather is stored on partner servers who are compliant with GDPR. For example, email delivery information is stored with MailChimp’s servers, credit card information is stored with Stripe, survey data is stored with SurveyMonkey, and support information is stored with Zendesk. In all such cases we securely interface with these partners to cause some event to take place, such as the billing of a credit card, but we do not transfer or transmit information from our servers to their servers in any way.
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret. We do not have access to user passwords.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
You have the following rights:
- Right to information – meaning you have the right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
You can access and update your personal data that we collect and maintains as follows:
- To update data you provide directly, log into your account and update your account at any time.
To cancel your subscription:
- If you are a paying subscriber, visit your subscription settings page here and click “cancel.”
- If you have any issues terminating your account, email us at email@example.com or via our Support Center.
To request to access, correct, download or delete your Personal Data, visit our Privacy Tools page here.
If you have any questions about your data, our use of it, or your rights, contact us at firstname.lastname@example.org.
Cookies and Other Technologies We Use
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information. If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalized features possible. For example, if you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
- Analytics cookies – these cookies are used to track the use and performance of our website and services and to help us improve and understand how people use our site.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
Last modification was made May 25, 2018.