Privacy Policy

 

Posted: 4 May 2018
Last updated: 4 May 2018

INTRODUCTION

itslearning (“we”) is committed to keeping your data safe. Any time we collect or process your data, we’ll do so legally. That means that we will only process data with your explicit permission and/or for necessary marketing and sales communication. This page will explain, in some detail:

While you’re on our site, we’ll collect and store information about you in accordance with this policy. If you don’t agree with this, please visit our Cookie Policy for information about how to turn tracking off, or, exit the site entirely – we won’t take it personally.

We are a global company, so when you provide us personal data, that data may be used, processed, or stored anywhere in the world, including in countries that have data protection laws that are different to the country in which you reside. However, itslearning has policies and procedures in place that are constructed to safeguard and ensure an equal level of protection is applied across the entire organization and in accordance with this Policy.

This Privacy Policy (which we’ll refer to as “Policy” going forward), describes practices with regards to our marketing websites (“website” going forward), e-mails, affiliates, virtual and in-person events, offline sales, and additional marketing and sales activities.

WHO COLLECTS THE DATA

All data is collected on behalf of itslearning AS, Solheimsgaten 7D, 5058 Bergen, Norway and its subsidiaries. We can be contacted by email: [email protected] or via phone at +47 55 23 60 70.

Our DPO, John Arthur Berg can be contacted via email at [email protected], or by phone at + 47 55 23 60 70.

WHAT DATA WE COLLECT

We will never collect data about you without clearly stating what information we are requesting and what we will use it for. When we do collect data about you, it will be:

  • Your first and last name, e-mail address, phone number
  • Company information including name, physical address, size
  • Geographical location, IP address, including country, state or province
  • Behavioral or demographical information
  • Data from marketing opt-in lists, campaigns, surveys, or publicly available information
  • Collaboration information

HOW WE COLLECT DATA

Through your interaction with us or use of this website, we may collect the following personal information that identifies you as an individual:

  • Information you provide through form submissions on our websites. This includes when you contact us, subscribe to our marketing communications, download collateral, register or attend an itslearning event or partner event, and purchase products or services.
  • Information you provide when applying for a job.
  • Information that you submit to us or itslearning employees when you want to engage in business or potential business with us.
  • Information you provide us through our website, in-personal conversations or events.
  • Information from surveys, reviews, or inquiries that you voluntarily take part in.
  • Information you submit to us via social media channels.

We don’t intentionally solicit, collect or process data for anybody under the age of 18. If it happens by accident, we delete it immediately.

WHY WE COLLECT DATA

We collect your data to better provide you information and determine whether our LMS would be a good fit for you. In those cases where we use legitimate interest as lawful basis for our data processing, we will always balance our interest with your right to data privacy.

The legitimate interest basis makes processing lawful only if it is necessary of the controller. It requires transparency and the successful outcome of a balancing test between your right to privacy and our interests. Transparency means it shall be clear to you which data is used and how it’s used. A balancing test requires us to take into consideration factors such as:

  • That our interest as controller is significant compared to the impact on your data privacy
  • That we only process what can reasonably be expected by you
  • That we cannot achieve the same by not processing the data

As such, our purposes are always legitimate, and the disadvantages to you are few.

These are our specific purposes for processing your data:

  • Identifying and targeting educational institutions that have an interest and need for a learning management system
  • Promoting our learning management system to interested potential customers
  • Nurturing relationships with interested potential customers, whether we initially encountered them via telephone, web or in-person.
  • Managing customer relationships, to better communicate any updates or changes they might be interested in

HOW WE USE THE DATA

We only collect or process your data we are performing a contract, when we have consent, or when we have a legitimate interest.

Your consent must be clear, unambiguous and freely given. When we request information, we have to tell you what we’d like to know and why. Legitimate interests are uses that are necessary to provide a product or service, or those that could be reasonably expected by the person whose information is being collected.

If no activity, interest, intent or need can be identified within a 2-year period, we delete your data. Please note that third-party sites may retain it. The only time we will retain your personal information for longer than is outlined in this Policy is when it is required by law.

The chart below explains how we use the data collected through each of our channels, the purpose and the legal basis we have for doing so.

 

How we collect data Why we collect data How we use the data The legal basis for our use
You fill out a form on our website, including those from Marketo, LiveChat, Google Forms, Typeform, Survey Monkey and Eventbrite. Identifying and targeting educational institutions that have an interest and need for a learning management system.

Nurturing relationships with interested potential customers.

Managing customer relationships, to better communicate any updates or changes they might be interested in.

When you fill out a form, we let you know why and how we’ll use the data.

This includes requests to contact us, subscribe to our marketing communications or newsletter, download collateral, register or attend an itslearning event or partner event, and purchase products or services, or identify a company’s need for an LMS.

Legitimate Interest
We collect your information from a publicly available source (e.g. you have your contact information listed on your website.) Identifying and targeting educational institutions that have an interest and need for a learning management system. We use this information to ensure that the data we are processing of yours is correct and up to date, as well as to correctly profile whether you have potential, intent or a need to purchase an LMS. Legitimate Interest
You contact us via our LiveChat form. Nurturing relationships with interested potential customers

Managing customer relationships, to better communicate any updates or changes they might be interested in

We track your on-site behavior to better answer your questions, as well as to notify you that a representative is available should you wish to engage, make product inquiries or further a purchase. Legitimate Interest
We’ve partnered with a related company to create a cross-promotional opportunity. Identifying and targeting educational institutions that have an interest and need for a learning management system. We use this data to better identify customers who might have a potential need or interest in an LMS. Legitimate Interest
We talk to you at an event or tradeshow. Nurturing relationships with interested potential customers.

Managing customer relationships, to better communicate any updates or changes they might be interested in.

We use your information to build relationships, determine whether you may have a need or intent to purchase an LMS, and to obtain explicit consent to be added to our marketing distribution email list for further nurturing. Legitimate Interest
We communicate with you via our social media channels. Nurturing relationships with interested potential customers.

Managing customer relationships, to better communicate any updates or changes they might be interested in.

We build brand awareness, and link you to information on our website that we believe may prove useful. Legitimate Interest
You sign up for a particular piece of email marketing. Promoting our learning management system to interested potential customers.

Managing customer relationships, to better communicate any updates or changes they might be interested in.

itslearning has a legitimate interest to send singular emails for one intended purpose, or at the request, or knowledge of the recipient. Legitimate Interest
You sign up to be on our marketing distribution list. Promoting our learning management system to interested potential customers.

Managing customer relationships, to better.

itslearning will explicitly ask if a prospect would like to be added to the distribution list to receive marketing communication on products, services, topics that may be of interest to them. Consent
One of our representatives talks to you in person, via drop-in or at a networking event. Nurturing relationships with interested potential customers

Managing customer relationships, to better communicate any updates or changes they might be interested in

We follow up on high-level marketing activity and buyer behavior in order to reach out, establish contact, create or foster a relationship, and follow up for the purposes of driving sales and revenue. Legitimate Interest

DATA PROCESSORS

Data processors are third parties with whom we have contracted to assist in our communication to users, customers, partners and prospects. They are not allowed to process your personal information unless we instruct them to do so. They will not share your personal information with any other organization. They will secure and retain your data for the period we specify. In those cases where the data resides in a non-EU country, we indicate the location next to the processor’s name.

Salesforce (US)
We use Salesforce as our CRM system and our main tool for communication with our partners, customers and prospects. We have Binding Corporate Rules that ensure that any data transfer has an adequate level of data protection.

Salesforce Data Processing Addendum

Marketo (US)
Marketo is our Marketing automation software and is used to communicate to prospects, users and customers. We have Standard Contractual Clauses with Marketo, which ensure that any data transfer has an adequate level of data protection.

Marketo GDPR Addendum and Data Processing Addendum

Live Chat (US)
LiveChat powers the chatting service on our websites. Information collected by LiveChat will be retained for 24 months. We have signed Standard Contractual Clauses which ensure that any data transfer has an adequate level of data protection.

Live Chat Privacy Policy

Survey Monkey (US)
Survey Monkey is used as our survey tool. We use this for general surveys and to plan and evaluate events. We have signed Standard Contractual Clauses which ensure that any data transfer has an adequate level of data protection.

Survey Monkey Privacy Policy

Adobe Sign (US)
Adobe Sign is used to digitally sign documents. Adobe will store some information about the signed documents or signature/the signing and the event in addition to an audit trail. We have signed Standard Contractual Clauses which ensure that any data transfer has an adequate level of data protection.

Adobe Sign

Consultants
We use several consulting companies in our day-to-day operations. They have all signed a confidentiality and non-disclosure agreement and a data processing agreement.

  • Pedowitz Group (US), a marketing technology consultancy
  • Jaroop (US), a web development consultancy
  • Amesto, a translation service provider

YOUR DATA RIGHTS

When it comes to your personal data, you have rights:

  • You have the right to know whether we have your information.
  • You have the right to access any information we have about you.
  • You have the right to correct or update your information.
  • You have the right to unsubscribe from our marketing materials, whenever you choose.
  • You have the right to tell us not to process your data for marketing.
  • You have the right to withdraw consent to use your information. (This withdrawal does not retroactively affect the lawfulness of any processing, nor does it affect processing that does not rely on consent.)
  • You have the right to talk about your personal data with our Data Protection Officer.
  • You have the right to lodge a complaint if you think we’ve mishandled your data.
  • You have the right to make us delete any information you’ve consented to share.

In some cases these rights are subject to certain conditions and limitations. If you would like to learn more about these rights please contact our Data Protection Officer.

If you want to exercise any of these rights, you have a number of different ways to do so. You can:

All requests will be processed within one month.

Click here to read the privacy policy for the itslearning App

Previous version(s):
Privacy Policy September 2016