220 Soft Ltd Privacy 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    By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

  1. How we use your personal data

2.1    In this Section 2 we have set out:

(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, length of visit, page views and progress, as well as information about the timing and frequency of your service use. The source of the usage data is our progress tracking system and your response to questions (within assessment programs). This usage data may be processed for the purposes of analysing the use of the website and services and to give you feedback of your progress. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services and keeping you and your supplier informed of your progress.

2.3    Online program use: We may process the personal details that you input (“account data“). The account data may include your name, date of birth, email address and library card or other reference number given to you by your supplier. The source of the account data is you entering it at the login stage. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services and maintaining back-ups of our databases. Any details stored from the login process will never be used for any purpose other than mentioned above such as sales or marketing. The legal basis for this processing is our legitimate interests, namely the proper administration of our website.

        Sales and marketing use (business contacts only): We may process data needed for sales and marketing of our products (“account data“). The account data may include your name, telephone number, record of calls and email address. The source of the account data is your contact with us or from public sources such as websites and directories. The account data may be processed for the purposes of 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 the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. These practises are only carried out from verbal or written (email) consent from the company’s business contacts; they are not conditional of usage of any of the company’s programs.

2.4    We may process your progress through courses and/or assessment results (“service data“). The source of the service data is from your use of the online programs. 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 giving you and your service provider feedback on your use of the software. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.5    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 your request.

2.6    We may process information relating to transactions, including purchases of goods and services that you enter into with us and (“transaction data“). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and future updates and renewals of licences 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 our interest in the proper administration of our business.

2.7    Sales and marketing use: 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 the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. These practises are only carried out from verbal or written (email) consent from the company’s business contacts; they are not conditional of usage of any of the company’s programs.

2.8    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. 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.

2.9    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.

2.10  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.

 

  1. Providing your personal data to others

3.1    Online program use: We may disclose your personal data to your supplier of the software insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2    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.

3.3    We may disclose course progress data and assessment results to the supplier of the course (as identified in the login URL) insofar as reasonably necessary for their monitoring of the usage and benefits of the package.

3.4    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.

 

  1. Retaining and deleting personal data

4.1    This Section [4] 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.

4.2    All personal information of end users accessing the company’s programs are deleted either (a) if the user has not used any of the programs after three years of last date of usage or (b) will delete the information of a user after seven years of accessing the company’s program.

4.3    We will retain the minimum amount of data necessary to ensure the efficient functioning of the programs is recorded. The particular data recorded will be by agreement with your supplier but may include Learner name, Learner Identity Number, Date of Birth, Date of testing and test results.

4.4    In 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 course data will be determined based on the time needed to ensure that users have a good experience of using it.

(b)    The period of retention of sales and marketing data will be determined based on the time it is updated due to change or removed by request of the client.

4.5    Notwithstanding the other provisions of this Section [4] we may retain the user’s personal data where such retention is necessary for compliance with a contractural/legal obligation to which we are subject, or in order to protect the client’s vital interests (usage details) or the vital interests of the end user to be informed of which program’s topics have been accessed by them so they can choose whether to duplicate their reading process.

  1. Amendments

5.1    We may update this policy from time to time by publishing a new version on our website.

5.2    You should check this document occasionally to ensure you are happy with any changes to this policy.

5.3    We may notify you of changes to this policy by email.

 

  1. Your rights

6.1    You may [request] us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)   the supply of appropriate evidence of your identity. For this purpose, for course data, we will usually accept a letter from your supplier stating your needs.

(b)    For data held, this will be supplied, on request, to an authorised person at the licensed organisation, such as supplying a client with the usage details to determine whether to purchase a further licence.

6.2    We may withhold personal information that you request to the extent permitted by law.

6.3    [a] Online end user program use:  The company’s policy is never to use your details for marketing purposes. You may view or request that any data from your use of the company’s on-line programs is removed at any time.

[b]Sales and marketing use (business contacts only): You may request us at any time not to process your personal information for marketing purposes and to delete any data that we hold.

6.4    In practice, can either agree after the initial contact by telephone by the company’s employees to our use of your personal information for marketing purposes of the company’s programs and are able to use the demos. You will or we will provide you with an opportunity to opt out of the use of your personal information for the company’s marketing purposes and you and your colleagues will still have access to the programs that may be of interest.

 

  1. About cookies

7.1    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.

7.2    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.

7.3    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.

 

  1. Cookies that we use

8.1    We use cookies for the following purposes:

(a)   status – we use session cookies to help us to determine if you are logged into our website;

(b)    personalisation – we use session cookies to store information about your preferences and to personalise the website for you;

(c)    security – we use session 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 by our service providers

9.1    Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

9.2    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/.

9.4    We use Google Translate to display pages in different languages. This service uses cookies for storing preferences. You can view the privacy policy of this service provider at https://www.google.com/policies/privacy/.

 

  1. Managing cookies

10.1  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:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

10.2  Blocking all cookies will have a negative impact upon the usability of many websites.

10.3  If you block cookies, you will not be able to use all the features on our website.

 

  1. Our details

11.1  This website is owned and operated by 220 Soft Ltd. Email: info@220soft.co.uk

11.2  You can contact the Data Protection Officer – Peter Davidson: by email, either using [a] peter@220soft.co.uk or [b] info@220soft.co.uk