Who are we?
Terms used to refer to the Company include “we”, “us” and “our”.
Company: Social Talent Limited
Address: The Liffey Trust, 117 Sheriff St. Upper, Dublin 1, Ireland
VAT Number: 491073
The purpose of this privacy notice
We may update this Privacy Notice from time to time and will post any changes on the Website. You are advised to come back and read through it again, from time to time. This Privacy Notice was last updated on 19 October 2016.
When we provide the Services we act as a processor of personal data on behalf of other companies who subscribe for the Services (referred to here as the “Customer”). We will only process personal data as part of the contract entered into with each Customer or when you provide your details as a visitor to the Website. The Customer controls the purpose and the means of any use made by us of the personal data provided under the Online Agreement.
Who does this privacy notice apply to?
This Privacy Notice applies to any person whose personal data we process on behalf of the Customer and any visitor to the Website. This includes both individual users and employees and contractors of the Customer who have access to the Website and the Services.
What general data do we collect?
We may collect general information about users of the Website/the Services (the “General Data”) including:
- Telephone Number
- Banking Details (if making a purchase)
- Occupation and Industry sector
What technical data do we collect?
We may collect the following technical data about users of the Website/Services (the “Technical Data”) including:
- technical information, including the Internet protocol (IP) address used to connect to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about visits to the Website or use of the Services, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website and the Services (including date and time log); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and
- when you use the Chrome extension element of the Services this will enable certain information to be collected in relation to certain websites that you visit, this includes (but is not limited to) the number and type of searches that you have made and details of the learning and training courses that have been taken and their status. Customers may access further information about the websites that we monitor by accessing the relevant link on the Website.
When do we collect it?
- when you correspond with us by phone, in writing or otherwise
- when you report a problem or receive support in connection with the Website/Services
- when you use the Website/Services
- when you or the Customer provide this information to us
What do we do with it? | How we use general data? | How we use technical data?
We will only use it to provide the Services and to provide you with information about the Services. By using the Services and visiting the Website you consent to our use of the information collected in the following ways, including to:
- carry out our obligations arising from any contracts entered into between us and the Customer, including the Online Agreement, and to provide the products and services requested from us;
- send communications to you about the Website and/or the Services including by SMS and push notifications. You can opt out of receiving such communications by contacting us using the details below or following the opt out process;
- send notifications about changes to the Services; and
- ensure that content from the Website is presented in the most effective manner.
- administer the Website and the Services and for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes;
- provide information to users and Customers;
- to improve the Website and the Services and to ensure that content is presented in the most effective manner for you and for your device;
- to allow you to participate in the interactive features of our Service, when you choose to do so; and
- as part of our efforts to keep the Services and the Website safe and secure.
Use of sensitive personal data
It is not expected that any sensitive personal data would be collected by us as part of the Services (i.e. data relating to racial or ethnic origin, political or religious opinions, membership of a trade union, physical or mental health or condition or sexual life, the commission of any offence or related documentation).
If we do collect such information then you consent to our processing this data in the manner set out in this Privacy Notice for and on behalf of the Customer. We do not control nor do we have any input into the content and information submitted to the Website and the Services, the Customer is responsible for ensuring that all appropriate consents are in place to allow us to process the information on the Customers behalf.
We will take every care to protect your information and use it in accordance with the Customers and users instructions. We do not provide your information to third parties for marketing purposes. In certain circumstances, we may disclose it to certain third parties as follows:
- the Customer;
- business partners and sub-contractors for the performance of any contract relating to the Website and the Services including; payment processors, data aggregators and hosting service providers;
- we may disclose the information relevant to any backup or hosting services to Amazon. You can read more about the measures taken by Amazon to protect the security of their services and the information at: aws.amazon.com/compliance/data-privacy-faq.
- analytics and search engine providers that assist us in the improvement and optimisation of the Website. This consists of aggregated anonymous information only and relates to the web pages visited on the Website and not the information included on those web pages;
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Online Agreement and other agreements; and/or
- to protect our rights, property, or safety, or that of the Customer, you or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
We will take all steps reasonably necessary to ensure that the information is treated securely, in compliance with the instructions of the Customer and in accordance with this Privacy Notice and the relevant law.
In particular, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we manage on behalf of Customers and the information we collect and manage on their behalf.
To protect the privacy and security of the Services, we will also take reasonable steps to verify your identity before granting access to information. We also use secure connections to protect sensitive information during its transmission. Where you have been given (or where you have chosen) a password which enables you to access the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
You should be aware that when you disclose personal information that information is available to the Customer and may be used by the Customer. Customers are solely responsible for the uses made of your information and we have no responsibility for the actions of the Customers in this regard.
If you have provided information you understand that we process that information as an agent of the Customer. We may hold a back-up copy of the information that you submit, but only on behalf of the Customer. We will comply with the Customer’s instructions in respect of that personal information.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
The information processed by us, on behalf of the Customer, may be transferred to, and stored at our hosting centres in the European Union.
Third party websites
The Website and the Services contain links to and from third party websites. A number of third party chrome extensions are referenced. These third party chrome extensions assist Customers in their day-to-day activities when using the Services however they are not required for use of the Website and Services. If you follow a link to any of these websites, please note that these websites have their own Privacy Notices. We do not accept any responsibility or liability for these third party websites nor do we provide support for their services. Please undertake the appropriate due diligence before submitting any personal data to these websites and/or using any chrome extension provided by Google.
Access to information
You have the right to access information held about you.
You have a right to have your information rectified or erased free of charge if it is inaccurate or no longer required for the purpose for which it was collected.
Please contact email@example.com in relation to any such access requests. Where applicable, we will contact the company responsible for the data (the Customer) in relation to access requests.
Retention of information
We will retain your information for:
- the term of the Online Subscription Agreement, plus thirty days; or
- for as long as we need it to provide the services and/or information you have requested; or
- or for as long as we are required under relevant laws.
If you would like your information to be deleted, please contact firstname.lastname@example.org. We will contact the data controller (the Customer), where applicable in relation to such requests.
How to contact us
Please contact us if you have any questions about this Privacy Notice or information we hold about you:
by email at: email@example.com
or write to us at: The Liffey Trust, 117 Sheriff St. Upper, Dublin 1, Ireland
Data protection commissioner
The Data Protection Commissioner in Ireland may be contacted at firstname.lastname@example.org