Revised privacy policy reviewed: 7th June 2024
Welcome to the Learn Amp's privacy policy.
Learn Amp respects your privacy and is committed to protecting your personal data. This privacy policy is designed to inform you about how we manage and protect your personal data, your privacy rights, and how the law protects you when you interact with us. It applies to your use of our Services, which include our website, products, or services, referred to collectively as “Services” in this policy.
As part of our commitment to privacy, it’s important to note that Learn Amp operates in two distinct roles when it comes to handling personal data:
By accessing or using our Services, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal data as described in this privacy policy. We are dedicated to ensuring that your information is handled with the utmost care and in compliance with applicable data protection laws.
This privacy policy aims to give you information on how Learn Amp collects and processes your personal data. As a provider of a leading people development hub, we acknowledge our responsibilities under data protection regulations both when we act as a data controller for the personal data you provide directly to us through your use of our Services, including the website at https://learnamp.com and its associated sub-domains, and when we operate as a data processor on behalf of our customers who use our Services.
When you interact with our Services—whether as a user signing up for an account, a visitor browsing our platform, or when you submit support queries—we take on the role of a data controller. This entails having control over the means and purposes of processing your personal data. Our responsibilities include not only the initial collection of your data but also overseeing your interactions with our platform features, analysing usage for system enhancements, and ensuring continuous system functionality. All our actions as a controller are guided by this privacy policy.
When providing services to our customers, Learn Amp acts as a data processor, meaning we handle personal data strictly in accordance with the instructions provided by our customers, who are the data controllers. Our role includes collecting data directly from users of our platform as per the controllers’ specifications.
While the data controllers are primarily responsible for the data and have their own privacy policies governing the purposes and means of processing, we ensure that our data collection methods are transparent and fully compliant with the controllers’ directives and applicable data protection legislation.
The data we collect may include, but is not limited to, Identity Data, Contact Data, and Usage Data. We process this data for the purposes established by our customers, and as outlined in the contracts and agreements we have with them.
Our responsibilities as a data processor are to:
Data subjects should refer to the privacy policies of the data controller for detailed information on how their personal data is being used. If data subjects have any questions regarding the processing of their data, they should contact the data controller directly. In instances where Learn Amp is authorized by the data controller to address such inquiries, we will do so in accordance with our established procedures and legal obligations.
It is crucial that you read this privacy policy alongside any other privacy notice or fair processing notice we may provide on specific occasions when we collect or process personal data about you. This privacy policy supplements—and does not override—those other notices.
If you have any questions about this privacy policy, including any requests to exercise your legal rights as a data subject, please contact the privacy team using the details set out below.
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). However, we take your concerns seriously and would appreciate the opportunity to address them, so please reach out to us before you approach the ICO.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links 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 the Website, we encourage you to read the privacy policy of every website you visit.
In our capacity as a data controller, Learn Amp is responsible for determining the purposes and means of the processing of your personal data. We are committed to handling your data transparently, fairly, and securely. The personal data we collect from you is utilised to provide and improve our Services and to communicate effectively with you. Below are the categories of personal data we collect:
In addition to the personal data mentioned above, we collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. While Aggregated Data is derived from your personal data, it cannot be used to identify you and thus is not considered "personal data" under the law. However, if we ever combine Aggregated Data with your personal data in a way that it can identify you, we treat it as personal data and will handle it in accordance with this privacy policy.
Please note that we do not collect any Special Categories of Personal Data about you, which includes sensitive details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, and genetic or biometric data. Additionally, we do not collect any information about criminal convictions and offences.
By engaging with our Services and providing this personal data, you help us to refine and enhance the experiences we provide, and we ensure that such data is processed in accordance with applicable data protection laws and our internal policies.
When operating as a data processor, Learn Amp collects and manages personal data strictly in accordance with the instructions and purposes defined by our customers, who act as data controllers. Although we collect the same categories of personal data as mentioned above, our use of this data is not determined by us but by the data controllers. The specific types of personal data we process on behalf of a data controller may include:
While we collect this data directly, it is processed on behalf of the data controller and in line with their privacy policy and practices. We do not use this data for our own purposes and only act upon the documented instructions provided by the data controller. Our role includes implementing appropriate technical and organisational measures to ensure the data's security and confidentiality.
In instances where aggregated data is collected, such as statistical or demographic information, it is used to support the services provided to our customers and is not utilised for Learn Amp’s independent purposes. It remains non-identifiable and is not considered personal data.
We are committed to ensuring that all personal data processed by Learn Amp as a data processor is handled in compliance with data protection laws and the specific instructions of our customers. If users have any queries or wish to exercise their rights in respect to their personal data, they should direct their inquiries to the respective data controller, as they hold the primary authority over their personal data.
We collect personal data through various methods, both as a data processor on behalf of our customers and as a data controller for our own purposes:
Through Direct Interactions: You may directly provide us with your Identity, Contact, and Financial Data, for instance, when you:
Through Automated Interactions: As you utilise our Services, we may collect Technical Data about your devices and interaction patterns automatically. This is done through the use of cookies, server logs, and other similar technologies. Moreover, if you visit other websites that use our cookies, we may also capture Technical Data. You can find more details in our cookie policy.
From Third Parties and Public Domains: We may obtain personal data about you from various external parties and publicly accessible resources, including:
In both our roles as a data processor and controller, we are dedicated to adhering to data protection laws and principles, ensuring that your data is gathered with respect and used appropriately. As a data processor, we follow the specific directions of our customers —the data controllers—regarding how this data is handled and for what purposes. As a data controller, we determine these aspects ourselves and inform you through this privacy policy.
As a data controller, we will only use your personal data where the law permits us to do so. Most commonly, we will use your personal data under the following circumstances:
Additionally, we may collect Technical Data from the following parties:
When acting as a data controller, we do not generally rely on consent as the legal basis for processing your personal data, with the exception of sending third-party direct marketing communications to you via email. In such instances, you are entitled to withdraw your consent at any time by reaching out to us.
As a data processor, we adhere to the instructions provided by the data controller when handling personal data. There are certain scenarios where we may perform tasks that necessitate us to act as a data controller, such as responding to support queries, ensuring the maintenance and security of our platform, and analysing how features and the platform are used. These tasks are conducted within the bounds of our data processing agreement with the data controller and under the premise that such activities are aligned with the original purpose for which the data was collected.
Furthermore, we may receive Identity and Contact Data from data brokers or aggregators, as well as Identity and Contact Data from publicly available sources such as Companies House.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer | (a) Identity (b) Contact |
Performance of a contract with you |
To perform and deliver our contract with you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a competition, promotion, interactive feature, event or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and our Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver our Services, including content, marketing communications and advertisements to you. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics for research and development to improve the Services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Services updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may withdraw any consent given to receive direct marketing communications from us by contacting us.
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 of our Services and offers may be relevant for you. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may withdraw any consent given to receive direct marketing communications from us by contacting us.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion, completed a survey or shared your feedback and, in each case, you have not opted out of receiving that marketing.
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you purchasing services from us.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. Please see our cookie policy for further details.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
In our role as a Data Controller, it may become necessary to share your personal data with various third parties. The categories of third parties with whom we might share your data include:
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.
For a comprehensive understanding of how your data is shared with third parties, please refer to our Third-Party Policy.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
With the extension of the EU-US Data Privacy Framework to include the United Kingdom, Learn Amp is committed to ensuring the highest standards of data privacy and security. This extension provides a robust mechanism for the lawful transfer of personal data from the EU and the UK to the United States.
Under this framework, Learn Amp adheres to stringent data protection principles, ensuring that any data transferred is subject to adequate safeguards and consistent with EU and UK data protection laws. Our commitment extends to working with third-party processors who are also compliant with these regulations.
The security of your personal information is important to us. 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 who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 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.
Learn Amp uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology. Although Learn Amp owns the code, databases, and all rights to the Learn Amp application, you retain all rights to your personal data.
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.
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.
Details of retention periods for different aspects of your personal data are available in our data retention policy – Article 30 which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see Erasure Request below for further information.
Additionally, if we receive instructions from a data controller to destroy data we process on their behalf, we will do so in accordance with their directions and applicable legal requirements. This is part of our commitment to uphold the data protection principles and to ensure that personal data is not kept longer than necessary.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Our Services are not intended for children and we do not knowingly collect data relating to children. If we learn that any personal information has been collected from a child under 18, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 18, please contact us at compliance@learnamp.com.
We reserve the right to amend all or part of our privacy policy. The version published on our website is the most up-to-date version. Changes to our privacy policy are communicated by placing a 'Revised Privacy Policy' date at the top of the document.
If we make any material changes, we will notify you by email or by a notice on this website.
The Learn Amp application offers the flexibility to integrate with various third-party services to meet our users' requirements. While we provide the capability for these integrations, it's important to note that when an admin of your organisation opts to enable third-party integrations, your data may be shared with these external services. These services are not listed on our official sub-processor list. Therefore, we encourage all users, particularly admins, to review the privacy policies and data handling practices of these third-party services before enabling any integrations. Please be aware that our privacy policy does not cover the data handling practices of these third-party services. Our commitment to data privacy applies only to the data processed within our own service and the sub-processors with whom we officially partner.
The Learn Amp application is designed to offer advanced features, some of which include the use of Generative Artificial Intelligence (AI). However, the activation and use of AI-powered features within our core functionalities are entirely under admin choice and control. These AI capabilities are not utilised by default; they are engaged only when an admin within your organisation decides to enable them. Additionally, the option for integrations with third-party services, some employing AI technologies, is provided. It is crucial for users, especially admins, to understand that enabling AI features within our application or activating third-party integrations that use AI can result in their data being processed using AI technologies. We maintain transparency and user control over these AI functionalities and encourage a thorough understanding of the specific AI aspects of any features or third-party services prior to their activation. While we uphold strict privacy standards for our in-house AI functionalities, the data processing practices of third-party AI services are governed by their respective privacy policies.
As a data processor, our primary role is to securely and effectively manage the data entrusted to us. It is imperative for users to understand that the obligation to update and maintain the custom privacy policy within each organisation lies with the account administrators, not with us. The privacy policy specific to a user's account is provided during the sign-up process and is also accessible in the footer of our platform. However, we do not bear the responsibility for managing, updating, or communicating changes to these account-specific privacy policies. Each account’s administrators are expected to regularly review, update, and communicate their privacy policies in compliance with relevant data protection laws. Users are encouraged to refer to these policies for detailed information on data processing activities and practices specific to their organisation.
A data processing agreement is a signed document that dictates how your data should be handled by us. This sets out terms that are compliant with GDPR. To make this easy for you, we include a signed and dated version in our SaaS Agreement.
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