TLC Online Privacy Statement
Last Updated: March 24, 2018
1. OUR COMMITMENT TO YOUR PRIVACY
TLC Online is the trading name of The Learning Curve (Online) Ltd and is the entity that primarily controls the Web Site and the click-360 platforms. The Learning Curve (Online) Ltd and its subsidiaries and affiliates (“TLC Online”) are committed to protecting and respecting any personal information you share with us.
This statement (the “Privacy Statement”) describes what types of information we collect from you, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us.
We ask that you take time to read it carefully. We may update this Privacy Statement from time to time to reflect new uses, rules, regulations or technologies that impact your privacy. We recommend that users review our Privacy Statement on a routine basis to view any changes. This Privacy Statement will be continuously assessed against new technologies, best business practices and data protection regulations. This Privacy Statement applies to and governs data collection and usage at www.click-360.com and www.click-360selfdrive.com (the “Web Sites”), including the content, features, and any microsites, blogs and discussion groups that are a part of either Web Site. The Web Sites include certain pages hosted by third party service providers, which are branded to look like www.click-360.com and collect personally identifiable information and perform other tasks on behalf of TLC Online (“Branded Sites”). These Branded Sites are governed by this Privacy Statement unless indicated otherwise on the Branded Site. Please read this Privacy Statement in its entirety. IF YOU DO NOT AGREE WITH OUR PRIVACY STATEMENT, THEN DO NOT USE THIS WEB SITE.
In 2015, TLC Online certified that it adhered to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program please visit: https://www.gov.uk/government/publications/safe-harbour-agreements/. Although the U.S.-E.U. Safe Harbor framework is no longer considered a valid data transfer mechanism in the European Union, TLC Online continues to comply with the relevant principles of the its framework and will certify compliance with its successor privacy protection framework by or before the end of the 2018 calendar year.
2. THE INFORMATION WE COLLECT AND HOW IT IS USED
You make the decision whether or not to proceed with any activity that requests personally identifiable information, but please be aware that if you choose not to provide the information requested, you may not be able to complete certain transactions with TLC Online.
Sometimes, such as when you register for a service or log in to a customer extranet site (such as Client Community), order a product, participate in a 360-degree feedback process (either as a participant or a rater) or make other requests or inquiries, we will ask for specific information about you in order to provide that product or service to you or respond to your requests or inquiries. We may collect certain personally identifiable information such as
- Name (including Title)
- Email Address
- Phone number
- The date and time you used our services
- The pages you visited on our website and how long you visited us for
- Your IP address
- The internet browser and devices you are using
- Cookie, Pixels or Beacon information
- The website address from which you accessed our website
- Details of any transactions between you and us
- Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), company details (some of which we may obtain from an online or public business directories)
- Voice recordings of calls you make to us
- Webinar recordings in which you participate
- “Live chat” records, and
- Any information within correspondence you send to us.
We may also collect information regarding your personal or professional interests, demographics, past experience with TLC Online products and services, detailed contact preferences or other personally identifiable information. We may use any information that we collect, including personally identifiable information, to tailor subsequent communications to you, including marketing and promotional communications, to administer and operate the Web Sites and our business and to provide and continually improve TLC Online offerings. In addition, we may use your information to undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in. We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraphs below;
We undertake NOT to share information that we collect, including personally identifiable information, with resellers or other third parties in order to market their products and/or services to you.
We do, however, provide our users a choice as to whether or not they would like to receive marketing or promotional communications. Users may from time to time receive up-to-date information on products and services via our content marketing emails. Users may opt-out at any time from receiving these communications. Please see Section 3, Choice.
We may also periodically conduct business and individual user surveys because they provide us with important information that helps us to improve our products and services. Participation in such surveys is completely voluntary and you, therefore, have a choice whether or not to disclose this information.
Data you submit online may also be combined with other information you provide through other means of communication, such as postal mail.
As is true of most web sites, we gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, referring pages, date/time stamp and click stream data. We use this information, which does not identify individual users, to analyse trends, to administer the Web Sites, to track users’ movements around the Web Sites and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.
Our Web Sites include social media features, such as the Facebook “Like” button Widgets and the “Share” button. These features may collect your IP address, which page you are visiting on our Web Sites, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Web Sites. Your interactions with these features are governed by the Privacy Statement of the company providing it.
We provide virtual (online) and physical (face-to-face) training services to employers and their individual employees through our TLC Online training programmes. This Privacy Statement does not apply to information collected through those programmes, which is instead governed by a separate TLC Online Privacy Statement that will be made available at that time.
We do not retain personal information in an identifiable format for longer than is necessary.
A SPECIAL NOTE ABOUT TRACKING TECHNOLOGIES
Technologies such as: cookies, beacons, tags, and scripts may be used on the Web Sites by TLC Online and our marketing and analytics partners. These technologies are used for operation of the Web Sites or services that you request as a user of the Web Sites, such as to remember text you may have entered when you navigate back to the page in the same session. We also use technologies to provide optional features and functionality that you may access on the Web Sites.
For example, a cookie can help us identify whether you have downloaded materials in the past so that you won’t have to download them again. We use tracking technologies to customize and personalise the Web Sites based on preferences you may have expressed either directly by selecting an option or setting or indirectly by your prior use. We also use tracking technologies that collect information about how you use the Web Sites to analyse and optimise the performance of the Web Sites in order to give you a better user experience. In some cases, particularly with respect to measuring and analysing performance of the Web Sites, tracking technologies may be placed by our third party service providers. We and our third-party marketing and analytics providers may use beacons to help better manage content on the Web Sites. Beacons also may be used to understand and monitor online movements of users so that we may better understand and improve their experiences on the Web Sites.
When you click on a link to an external web site or third party resource (including embedded widgets similar those provided by Facebook and Twitter), the third party may place a cookie from its own site. TLC Online does not control the dissemination of these cookies. You should check the relevant third party web site for more information about these cookies. Like other aggregated information from the Web Sites that does not identify individual users, we may analyse and share non-personally identifiable information collected through cookies with TLC Online subsidiaries, affiliates, and third parties, including our business partners and service providers, and in marketing materials and public disclosures.
We may use your personally identifiable information for purposes not directly related to products and/or services you have requested or other requests or inquiries you have made, such as to send you email communications, information about our discussion forums and user groups and customer service communications information on new products or offers and information from TLC Online’s partners unless you direct us not to do so by opting-out at the point where the information is collected. Additionally, you may opt-out from use of your personally identifiable information collected online for the purpose of sending such marketing or promotional communications at any time by clicking on the Unsubscribe button clearly marked in the footer of such communications. Alternatively, you can send an email to firstname.lastname@example.org.
We will retain your information for as long as needed for the purposes for which it was collected, and in accordance with our retention policies, as applicable. We will retain and use your information as appropriate to comply with our legal obligations, resolve disputes, and enforce our agreements.
4. SHARING OF INFORMATION
Unless TLC Online has your permission or is required by law, or except as otherwise set forth in this Privacy Statement, TLC Online will not sell, rent or lease your personally identifiable information to others, except in order to provide you with the products and services you request. TLC Online will only share the personally identifiable information you provide online with other TLC Online affiliates, resellers or other marketers of TLC Online’s products, TLC Online’s partners and/or service providers who may be used to ship products, provide technical support, handle order processing, or otherwise act on TLC Online’s behalf for the purpose of marketing and providing TLC Online products and services, administering and operating the Web Sites and our business and sending marketing and promotional communications. TLC Online may also share your information with its affiliates so that they may provide you with information about their own products and services and for other marketing and promotional purposes.
Please remember that when you submit information to a discussion group or some other public or online forum, the information submitted will be deemed public information and will not be considered confidential or treated by TLC Online as other personally identifiable information you specifically provide to TLC Online, which is subject to this Privacy Statement. On our Client Community site, you may remove information you posted to the “Collaborate With Others” section of the site. In some cases, we may not be able to remove your personally identifiable information, in which case we will let you know if we are unable to do so and why.
We may share or disclose your personally identifiable information if such disclosure is necessary to: (a) comply with legal process (such as a court order) or other legal requirements of any governmental authority; (b) protect our rights or property; (c) protect the interest of users of the Web Sites, other than you, or any other person; or (d) operate or conduct maintenance and repair of our services or equipment, as authorised by law.
Notwithstanding the foregoing, as a result of the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of TLC Online, we may transfer, sell or assign information concerning your use of these Web Sites, including without limitation, personally identifiable information, to third parties involved in the transactions listed above. In the event of such transfer, sale or assignment, notice will be given in accordance with Section 8, Notification of Changes, below.
TLC Online may provide you with links to other websites that may be operated by companies not affiliated with TLC Online. Please be aware that TLC Online is not responsible for the privacy practices or the content of such websites. TLC Online does not endorse them or make any representations about them or any information, services, products or materials found on them. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with TLC Online, any use of those websites, or the privacy practices of those websites.
6. DATA TRANSFER AND SECURITY
We may transfer the personally identifiable information we collect about you to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Statement and in accordance with applicable law.
We will take steps intended to safeguard personally identifiable information stored on our systems from unauthorised access or disclosure. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot ensure or warrant the security of any information you transmit to us or from our online services, and you do so at your own risk.
7. HOW TO ACCESS AND CORRECT YOUR INFORMATION
TLC Online strives to keep your personally identifiable information accurate and up-to-date. Should you find inaccuracies in your personally identifiable information and wish to amend, correct or delete the same, please contact us through one of the communication methods described below in Section 12, Contacting Us. To the extent required by applicable law, TLC Online will respond to requests to update personally identifiable information within 30 days of the reception of the request.
You have the right to:
- Ask for a copy of the information that we hold about you
- Correct and update your information
- Withdraw your consent (where we rely on it). Object to our use of your information (where we rely on our legitimate interests to use your personal information)
- provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object
- Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information
- Transfer your information in a structured data file (in a commonly used and machine readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.
You can exercise the above rights and/or manage your information by contacting us using the details in Paragraph 12 below.
To opt out of all future marketing and promotional correspondence from TLC Online, please email us at email@example.com or follow the unsubscribe instructions contained in the email communications you receive. To the extent required by applicable law, your request will be met within 10 business days.
8. NOTIFICATION OF CHANGES
TLC Online reserves the right to make changes to this Privacy Statement. If we make a material change to this Privacy Statement that results in the use of personally identifiable information that is inconsistent in material respects with the practices described at the time of collection, we will notify you and provide you with the choice as to whether or not you will allow us to use your information in this different manner. In the event there is a material change in our privacy practices that does not affect user information already stored in our database, a notice will be posted on our Web Site notifying all users of the change.
TLC Online does not knowingly collect personally identifiable information from users under the age of 13. Children under 13 should not send any information about themselves to TLC Online. If a child under 13 submits information through any part of the Web Sites, and TLC Online becomes aware that the person submitting the information is a child, we will attempt to delete this information as soon as possible.
10. (FOR CALIFORNIA RESIDENTS) CALIFORNIA PRIVACY RIGHTS
California law gives California residents the right to ask us for a notice describing the categories of personally identifiable information we share with third parties or affiliates for their direct marketing purposes. The notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it has been shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please contact us through one of the communication methods described below in Section 12, Contacting Us. Please allow 30 days for a response.
11. ACCEPTANCE OF PRIVACY STATEMENT
By using the Web Sites, you signify your assent to our Privacy Statement. If you do not agree with this Privacy Statement, please do not use our Web Sites. Your continued use of this Web Sites following posting of changes to these terms will mean you accept those changes.
12. CONTACTING US WITH COMMENTS AND CONCERNS
Policy, please contact us: via email at +44 845 313 3357, or by mail to: TLC Online, The Long Barn, Mouseden Farm, Halls Hole Road, Tunbridge Wells, TN2 4RF. If you have any questions or concerns about personally identifiable information with regards to employment applications please ask to speak with our CEO, Colin Newbold, by telephone at +44 845 313 3357.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our CEO at firstname.lastname@example.org or by telephone at +44 845 313 3357.
If you are still unhappy, you have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:
Information Commissioner's Office
0303 123 1113
Last Updated: March 24, 2018