Privacy Policy

 

Version 2

Last update: 31.01.2019

Section 1 – Introduction

1.1  This Privacy Policy applies to all o99 Training Academy customers, users, partners, learners, awarding bodies and all individuals who are interacting with o99 Training Academy and its websites https://o99.co.uk and its portal https://o99.co.uk/portal.

1.2 This Privacy Policy is put in place to ensure the protection and proper handling of the personal data and the privacy of the users of Eye Safe and its related services.

1.3 The o99 Training Academy platforms (website, e-learning platform and portal) uses cookies, but we will always ask users to give explicit consent for their use when you access the content/register an account for purchasing a course.

1.4 o99 Training Academy reserve the right to amend and review this Privacy Policy as they see fit

1.5 This Policy come along with all our policies and procedures. Please read our Terms and Condition and Cookies Policy

Section 2 – Definitions

2.1 0.99 Ltd, a registered company in England and Wales, trading as o99 Training Academy, is a Training Centre which provides accredited and non-accredited training courses/qualifications in the further education sector to best fit the health, safety, environmental and development training needs of our learners.

2.2 0.99 Ltd, trading as o99 Training Academy is registered to Information Commissioner`s Office (ico.) under the reference number ZA426068.

2.3 This is the official website of our training centre (https://o99.co.uk). We don`t have partnerships with other e-learning websites, our courses can be purchased only from this website.

2.4 If you find other websites which pretend to act on our behalf, please report this matter and we strongly advise you to ignore them.

2.5 o99 Training Academy is the controller and responsible for your personal data (collectively referred to as ”COMPANY”, “we”, “us” or “our” in this Privacy Policy). “you” and “you”: any individual or any business / organisation who creates an account and uses our services via https://o99.co.uk and https://o99.co.uk/portal.

2.6 We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Data Protection Officer using our Contact section (https://o99.co.uk/contact-us/) or e-mail to privacy@o99.co.uk.

The DPO contact details:

Company name: 099 Ltd

Trading name: o99 Training Academy

Name of DPO: Alin Nasser

Position: Centre Manager

Address: Finchley Mews, Finchley Road, Grays, Essex, RM17 6RG.

2.7 The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.

2.8 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

2.8.1 The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;

2.8.2 The purposes for which the Company collects, holds, and processes personal data;

2.8.3 Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;

2.8.4 Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;

2.8.5 Details of how long personal data will be retained by the Company;

2.8.6 Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

2.9 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 in the first instance.

2.10 Where we need to collect personal data by law, or under the terms of a contract we have with you and if you fail to provide that data when requested, we may not be able to perform the contract (deliver the course). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

2.11 Definition of Data Protection Terms

2.11.1 Please access the Information Commissioner`s Office website https://ico.org.uk/for-the-public/ to acknowledge with the Data Protection Terms.

2.11.2 We comply with:

  • The United Kingdom Data Protection Act 1998
  • General Data Protection Regulation (GDPR)

2.12 Account Data: Data collected when you purchase a course or create an account on https://o99.co.uk or https://o99.co.uk/portal. This includes title, first name(s), middle name, surname(s), home address including postcode, employer details/your company details, telephone, mobile, e-mail, gender, occupation, nationality, date of birth, employment status, education, ethnicity details, first language, learning difficulties, learning needs. In order to register you as a learner, some of the data are mandatory and they will be marked with a “*” to let you know that without these mandatory information we cannot proceed your registration or your registration with the certain awarding body that owns the qualification/course.

2.13 Correspondence Data: Data collected from the interactions you have with o99 Training Academy customer service representatives and from any correspondence you have with o99 Training Academy in general and may include the content of the correspondence and the metadata linked to the exchange. The correspondence could be via phone, mobile, e-mail, website, Tidio plugin, private messages, text messages, WhatsApp messages, Facebook, Instagram or any other channel of communication between you and o99 Training Academy staff.

2.14 Enquiry Data: Data submitted to o99 Training Academy during an enquiry about their services

2.15 o99 Training Academy account: There are two types of accounts. One created by the website when you purchase a course/service from https://o99.co.uk and another account created by o99 Training Academy staff on https://o99.co.uk/portal.

2.16 o99 Training Academy website: https://o99.co.uk and https://o99.co.uk/portal, https://o99.co.uk/webmail

2.17 User: any account created via https://o99.co.uk

2.18 Learner: any individual who was successfully register to one of the courses, qualifications or services that o99 Training Academy deliver through the regulatory body that accredited them to deliver.

2.19 Usage Data: Data collected from bookings, buying courses or any interactions with o99 Training Academy platforms.

2.20 Financial data: any data provided by you when you purchase a course, qualification or service and may include your accounts number, sort code, name, address, card number, card type, CVV and card expiry date.

2.21 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

2.22 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Section 3 – Scope of the policy

3.1 Every learner, customer, partner, awarding body’s staff or any visitors has rights with regards to how we handle their personal information. This policy aim is to give information on how o99 Training Academy collects and processes your personal data when you are using this website, including any data you may provide through this website when you sign up (register as a user/learner), purchase a course (including classroom and e-learning courses), complete a survey or take part in a competition.

3.2 This website is not intended for children and we do not knowingly collect data relating to children. To be our user/learner you must to be 18+, confirming this policy you automatically confirm that you are 18+.

3.3 It is important that you read this privacy notice together with any other policies published in our website (Our Centre Policies https://o99.co.uk/policies/)  or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data and always you will have to agree with it before our future actions.

3.4 This privacy policy supplements the other Centre Policies and is not intended to override them.

3.5 During the course of our activities we will collect, store and process personal information about you and we recognise the need to treat it in an appropriate and lawful manner.

3.6 We have aimed to make this Policy as clear and complete as possible to demonstrate our commitment to keeping secure any information you share with us.

3.7 o99 Training Academy complies with the GDPR rules and Data Protection Act 1998 in all use of personal data.

3.8 This privacy notice sets out most of your rights under the new laws which are changed at 25.05.2018.

Section 4 – How we collect and use your data

4.1 What personal information we collect?

4.1 We collect two main types of information – personal information and anonymous information – and we may use personal and anonymous information to create aggregate information (which does not identify and cannot reasonably be used to identify an individual learner).

4.2 We collect the following categories of data which were defined in Section 2 of this Privacy Policy:

4.2.1 Account Data

4.2.2 Correspondence data

4.2.3 Enquiry Data

4.2.4 Usage Data

4.2.5 Financial Data

4.2.5.1 We use as methods of payment the WooCommerce plugin, before any payment please read their Privacy Policy (https://woocommerce.com/privacy-policy/). Our website will not collect your bank/card details without your approval, basically it`s your choice if you want to save your details for future payments via our platform or not. Your bank details, after processing a payment can be mentioned in our bank statements and we will not share these details. The only persons who have access to our bank statements are the Managing Director and our Accounts Manager (restriction applicable);

4.2.5.2 We use Stripe as a payment terminal. For more information about their Privacy Policy please access https://stripe.com/gb/privacy

4.2.6 Technical Data

4.2.7 Marketing and Communications Data.

4.2.7.1 We will always ask for your explicit consent to send you marketing e-mails regarding our courses, qualifications, services and offers.

4.2.7.2 We use Mailchimp for sending marketing e-mail. More details about their Privacy Policy you can find by clicking this link: https://mailchimp.com/legal/privacy/?_ga=2.152262137.1373359769.1548847189-2122746028.1547634209

4.2.7 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

4.2.8 We do not however collect any unnecessary personal information from Registrants who didn`t buy a course (for instance, date of birth, nationality, information about religious beliefs etc).

4.2.9 It is impractical in most circumstances for you to remain anonymous, and we may not be able to interact with you, provide access to the Website, or answer your enquiry if we are not able to identify you or collect your personal information.

4.2 What we will do with your information?

4.2.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

4.2.2 Where we need to perform the contract we are about to enter or have entered into with you.

4.2.3 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.2.4 Where we need to comply with a legal or regulatory obligation.

4.2.5 Please visit ico.co.uk to find out more about the types of lawful basis that we will rely on to process your personal data.

4.2.6 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.2.7 We will provide your personal information (data) to the Awarding Organisations which accredited us to deliver their courses (you can find our accreditation in the `About Us` section – top menu). They will require your personal information (data) to enrol in their course system and to provide the official certificate.

4.3 What we will not do with your personal information?

4.3.1 We will not provide any of your personal information to other companies or individuals without your permission. However, we may need to provide your name and delivery address to third parties that we use for the purposes of delivering specific services to you such as asset inspections.

4.3.2 We will not sell or pass on your data to anyone not directly related with the delivery of the service we are providing to you.

4.3.3 Unless you or the service being delivered by o99 Training Academy is located outside of the UK, we will not share personal data with any other country or international organisations (if applicable).

4.4 How we collect and process your information?

4.4.1 We use different methods to collect data from and about you including:

4.4.1.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in the checkout form. This includes personal data you provide when you purchase a course, subscribe to our website (newsletter), enter a competition, promotion or survey, give us feedback, request marketing to be sent to you or by corresponding with us by post, phone, email or otherwise

4.4.1.2 If you want to create an account to our website, without purchasing a course/service we will not need to collect any personal information about you, if you want to fill the forms it`s your choice.

4.4.1.3 Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

4.4.1.4 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.

Technical Data from the following parties:

  • analytics providers such as Google based outside the EU;
  • advertising networks Google Adwords based outside the EU; and
  • search information providers Google or Bing based outside the EU.5
  • UK Awarding Organisations/Body regulators (such as CITB, TQUK or any governmental authority). Please see on our website the complete list of the Awarding Organisations o99 Training Academy is accredited to deliver their courses/qualifications.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services as PayPal or any other WooCommerce method payments we use based outside the EU/UK or inside EU/UK.

Identity and Contact Data from publicly available sources such as Companies House based inside the UK/EU.

4.4.4 In the below table we have set out a description of all the ways we use (intend to use) your personal data and which legal basis we rely to do it. Also, we will process your data not just based on GDPR laws, it depends on the specific purpose for what we are using your personal data, but all the data is complying with GDPR regulations.

Purpose Type of data Lawful basis/legitimate interest
To register as a user (without purchase a course) Username

Nickname

Establish a connection between you and us as a future/possible learner
To register you as a learner and to process your order

To contact you

Account Data, Correspondence Data, Enquiry Data, Financial Data Performance of a contract

Company`s legitimate interest (an example can be when we are trying to recover debts due to us)

To notify you

Including:

– partake in a prize draw, competition or a survey

– notifying you about changes to our terms and conditions or policies

– to ask you for making suggestions or providing feedback

– to deliver relevant website content such as e-learning platform

Account Data Correspondence data

Marketing and Communication Data

Performance of a contract

Company`s legitimate interest

4.4.5 We may use your Identity, Contact, Technical, Usage and Profile Data 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.

4.4.6 You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. Also, you will receive notification for your Wishlist’s courses.

4.5. Transfer the information into our servers:

4.5.1 Once enrolled in one of our courses and registered as a learner, your personal details will be downloaded in our OneDrive server, into the special folder for keeping the personal information about our learners.

4.5.2 Who has access to view your information and which level they have?

Position CAN VIEW CAN EDIT OWNER
Managing Director X X X
Centre Manager

(Head of Learning)

X X X
Administration staff X X
Receptionist X
Teacher/Tutor/Trainer X

 

4.5.3 Once you purchase the course/qualification we will send you via e-mail the “Learner registration form”. You must fill it and send it back to us. We will share the personal information and attachments included in the form to register you to our Awarding Organisation for the course/qualification you want to enrol.

4.5.4 The Learner Registration Form will collect form you account data, correspondence data, enquiry data and marketing and communication data.

4.5.5 The Learner Registration Form will be saved in our server and will be kept secured.  The form will not be uploaded on the website and you can not access it from your profile for security reasons.

4.5.6 Based on the information you provide and if the course/qualification that you bought require you to create an account on our Portal (https://o99.co.uk/portal), one on our representatives will open the account for you and you will receive the login credentials on the e-mail you provided us when you created the account on our website (https://o99.co.uk).

4.5.7 We will share your information with those providing services on our behalf; Awarding Bodies; and Compliance Registers related to the course(s) you attend e.g. TQUK, CITB, CPD etc. Every course/qualification has mentioned in the description which Awarding Organisation provide it. Please visit our website for more information or e-mail us at privacy@o99.co.uk.

4.6. How long we hold your information?

4.6.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

4.6.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

4.6.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

4.6.4 In some circumstances you can ask us to delete your data: see request erasure below for further information.

4.6.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

4.7. Updating and accessing your personal information

4.7.1 You have the right to:

4.7.1.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

4.7.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

4.7.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

4.7.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

4.7.1 5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

4.7.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

4.7.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

4.8. Keeping your personal information secure

4.8.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties with whom have a business interest and thus need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

4.8.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

4.8.3 We have a SSL certificate and we force all the payments to be made through the SSL certificate.

4.8.4 You can suspend/delete your account by filling a request form and we will process your application in maximum 24 hours.

4.9. Data transfers, storage and processing globally

4.9.1 We may have to share your personal data with some parties set out below for the purposes set out in the table in paragraph 4 above.

  • Selected external third parties for the purpose of fulfilling the terms of contract with you.
  • Specific third parties such as the Awarding Organisations/Regulatory bodies who accredited o99 Training Academy to deliver their courses/qualifications.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

4.9.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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 and in accordance with our instructions.

Section 5 – Cookies Policy

5.1 Cookies are small text files that our website(s) or services provided for us by other companies put on your computer. The information in them helps us to improve your experience when using our website and learning with us. Many of our cookies are deleted when you log out of your learning or close your web browser. None of our cookies contain any of your personally identifiable information.

5.2 Because you are using our website(s) we assume that you are happy for us to use cookies in this way.

5.3 If you are not happy, then you should either not use our website(s), set your web browser to not accept cookies from o99 Training Academy or use your web browser’s anonymous browsing setting (this is called ‘Incognito’ in Google Chrome, ‘InPrivate’ in Internet Explorer and ‘Private Browsing’ in Firefox).

5.4 For more information on cookies, how to control the use of them in your browser and how to browse the internet anonymously visit the All About Cookies website.

5.5 Because our learning systems rely on cookies to deliver your courses effectively you give us consent to use cookies as outlined below when you purchase or enroll on a block. We will not provide technical support to learners who choose to cookies and then encounter issues with their learning.

5.6 You may will not be able to purchase courses from the o99 Training Academy website if you set your browser to not accept cookies as our ecommerce system uses them to process transactions.

5.7 Please contact us if you need advice or help after deactivating your cookies.

5.8 What cookies O99 Training Academy uses:

5.8.1 Session Cookies

We use a number of session cookies to provide functionality including, but not limited to, remembering who you are when you have logged into our website(s) or learning systems, to identify you when you move from one O99 Training Academy system to another, to greet you by name on screen, to optimise the effectiveness of our web servers and to remember the items you have put into our shopping basket.

We consider these cookies to be strictly necessary for the secure and efficient operation of our website(s) and learning systems and make your experience of using them easier and quicker.

If these cookies are blocked or disabled then much of the functionality of our systems will be broken.

5.8.2 Persistent Cookies

We use a number of persistent cookies to provide functionality including, but not limited to, returning you back to the point in your learning you had reached the last time you logged out, to show you content you had looked at on a previous visit to make it easier to find it again, to make sure you are only invited to complete a web survey occasionally and that you don’t see alerts or messages repeatedly during a single web visit.

If these cookies are blocked or disabled then our systems will still be usable, but the user experience will be severely degraded.

5.8.3 DoubleClick (Google)

This cookie is used on a small number of pages on the O99 Training Academy website to track the effectiveness of our Google Adwords and Google Sponsored Link advertising.

For more information on how to permanently opt-out of DoubleClick placing this cookie on your computer visithttp://www.google.com/policies/privacy/ads/#toc-optout or install the Google Advertising Cookie Plugin for your browser http://www.google.com/ads/preferences/plugin/

5.8.4 Social network cookies

Some pages on our website(s) contain social network ‘share’ or ‘like’ buttons. The social network may set a cookie (or cookies) on your PC when you click on one of these buttons.

In order to implement these buttons on our website(s) we use code which is hosted by the relevant social network. If you are a member of some of these networks they may use this code to track that you have visited our website(s) whether you click the buttons or not.

5.9 o99 Training Academy does not control these cookies or the underlying code. You should check the privacy statement of the relevant social network before clicking them and/or to find out how they track their members’ behaviour using these elements and how to opt out of this functionality

5.10 To see the full version of our Cookies Policy please click here.

Section 6 Third-party links

6.1 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.

6.2 Usually our third-party links will be the website of the body regulators who accredited us to provide courses/qualifications/services, but we still can have advertised links or link of our website plugins.

Section 7 Contact us

7.1 You can contact us by using the “Contact Us” section on our website https://o99.co.uk/contact-us/ .

Our registered office:

Finchley Mews

Finchley Road

Grays

Essex

RM17 6RG

Emails:

info@o99.co.uk

privacy@o99.co.uk

bookings@o99.co.uk

enquiries@o99.co.uk

accounts@o99.co.uk

assessments@o99.co.uk

DATE: 25.06.2018

REVIEW:

25.06.2018 (Dacian Keran and Alin Nasser)

31.01.2019 (Dacian Keran and Alin Nasser)

 

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