Processing of personal data in ClickLearn Studio and in the content cloud environment

1. GENERAL

1.1 This policy describes how ClickLearn ApS collects personal data and processes set data about our customers.

1.2 The policy applies to information provided by our customers to us or that we collect from our customers through our IT application ClickLearn.

1.3 ClickLearn is obligated as controller of your personal data on behalf of our customers. All queries related to that obligation may be addressed according to section 7 in this document.


2. What personal data we collect, its purpose and legal basis for the processing.


2.1. When you are using our ClickLearn application or associated cloud services, we automatically collect information about the browser used, your IP-address and network location and information about your usage of ClickLearn; when you start and stop the application and what general application features you are using.

2.1.1 The purpose is to optimize the user experience, track completion of content created by you, track identity of users using the content, created by you and to ensure license compliance of your installation. This processing is necessary to maintain our interests in improving the application design and providing data for your analysis of content consumption.

2.1.2 The legal basis for this process is the EU General Data Protection Regulation article 6, paragraph. 1, letter f.

2.2 When a user logs in to our Content cloud platform, we will collect information about the user’s behavior on the website. We will collect information about completed courses, read materials and locational information about the user (IP and location).

2.2.1 The purpose is to deliver aggregated and detailed statistics on content consumption for you as a customer.

2.2.2 The legal basis for this process is the EU General Data Protection Regulation article 6, paragraph. 1, letter c and f.

2.3 When you register as a ClickLearn author, we will collect your e-mail address, name and behavior on our self-service platform.

2.3.1 The purpose is to deliver proactive support based on your behavior, streamline our self-service deliverables to you and maintain our interest in delivering our author community newsletters.

2.3.2 The legal basis for this process is the EU General Data Protection Regulation article 6, paragraph. 1, letter f.

2.4 When you join our ClickLearn community as a member, we will collect your name, address, e-mail address and phone-number. At that time, you will also make the choice, if you want to sign up for our newsletter. We will relate the information with other information, we have about your usage of ClickLearn.

2.4.1 The purpose is to administer your membership, deliver services and offer advantages associated with the membership and maintain our interest in sending you our newsletters and targeted marketing.

2.4.2 The legal basis for this process is the EU General Data Protection Regulation article 6, paragraph. 1, letter b and f. You will be asked specifically to opt in to any electronic marketing.

3. RECIPIENT OF PERSONAL INFORMATION

3.1. Information regarding names, addresses, e-mails, phone-numbers and order-numbers may be transfered to The Danish National Post, DHL, UPS, GLS or the transported responsible for delivering a shipment to you.

3.2 Information may be transferred to external parties, processing data on our behalf. We are using external parties for technical IT-related hosting (Microsoft on Azure), design improvement on content, newsletter shipment and targeted marketing, including retargeting. Among others e-mail addresses and names provided to us by you may be transferred to Campaign Monitor, who on our behalf is responsible for shipping e-mails. These companies are data processors under our instructions and process information for which we are data controllers. The data processors are legal bound not to use any data for any other purpose than the fulfillment of our agreement with set company.

Written data processor agreements have been established with all data processors, processing personal data on our behalf.

3.3 One of these data processors, Google Analytics v/Google LLC. The necessary guarantees for transferring data to the Unite States are stated under the EU-U.S. Privacy Shield (with reference to EU General Data Protection Regulation article. 45).

3.3.1 Copy of the certification of Google LLC may be found here:
       https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI

YOUR RIGHTS

4.1 In order to create openness around the processing of your personal data, we as a data controller must inform you of your rights.

4.2 The right to subject access

4.2.1 You are at any time allowed to request information from us, specifically as to what data we have registered on individuals relating to your installation of ClickLearn, what purpose the registration serves and what category of personal data, source of registration and transfer of that data exists or has taken place.

4.2.2 You have the right to receive a copy of the personal information, we are processing for you. If you want a copy of your personal information, please send a written request to DataProtection@clicklearn.dk.

4.3 The right to correction

4.3.1 You have the right to have false personal data about you or individuals related to your ClickLearn installation corrected by us. If you are made aware of any false information we have registered about you or related to your ClickLearn installation, we encourage you to write us in order for us to correct that information.

4.4 The right to deletion

4.4.1 in some cases you have the right to have personal data about you or individuals related to your ClickLearn installation deleted by us. F.ex, when revoking your consent and when we have no legal basis for continuing the data processing. If it is necessary for us to continue data processing in order for us to comply with our legal obligations, we are not obligated to delete the personal data.

4.5 The right to limit the processing to storing

4.5.1 In some cases you have the right to limit the processing of your legal information to only apply to storing. F.eks. if you think the information we are processing about you are incorrect.

4.6 The right to data portability

4.6.1 In some cases you have the right to receive the data you have provided to us in a structure and machine-readable format and the right to transfer that information to another data controller.

4.7 The right to object

4.7.1 At any time you have the right to object to our processing of personal data about you or individuals related to your ClickLearn installation with regards to direct marketing, including the profiling made by us to target our direct marketing.

4.7.2 Furthermore you have the right to object at any time for personal reasons against our processing of personal data about you or individuals related to your ClickLearn installation made by us on grounds of our legitimate interests (ref. section 2.1 and 2.2).

4.8 The right to revoke consent

4.8.1 You have the right to revoke consent given by you in the processing of data about you or individuals relating to your ClickLearn installation as a member of the ClickLearn community for authors. If you want to revoke you consent, please contact us at  DataProtection@clicklearn.dk.

4.9 The right to complain

4.9.1 At any time you have the right to complain to Datatilsynet, Borgergade 28, 5, 1300 København K about our procsessing of personal data about you or individuals related to your ClickLearn installation. The complaint may be forwarded to dt@datatilsynet.dk or phone +45 33 19 32 00.

DELETION OF PERSONAL DATA

5.1 Information collected about usage of the ClickLearn application (section 2.1) will be deleted when you have not used the application for 1 year.

5.2 Information about newsletter sign-ups is deleted when you revoke your consent unless we have other legal basis for maintaining that information.

5.3 Processing of information about acquired licenses, will be deleted five years after termination of maintenance. Data may be stored for a longer period time if a legitimate need requires a longer storage time.

5.4 Information collected when you joined our ClickLearn community (section 2.4), will be automatically deleted: a) if you have not logged on to your user profile for 3 years, b) if you suspend your membership to our ClickLearn community  and do not activate it within a 3 year period or c) if you revoke your membership of our ClickLearn community.

SECURITY

6.1 We have established suitable technical and security measures against personal data being involuntarily or illegally deleted, lost, changed or transferred to 3rd party and misused.

6.2 Only employees with a real need to access your personal data in their work processes have access to set personal data.

CONTACT INFORMATION

7.1 ClickLearn ApS is data controller for the personal data collected from you as a customer.

7.2 If you have any questions or remarks to this personal data collection policy or want to use one or more of your rights in section 4, please contact:

ClickLearn ApS
Sjaeleboderne 2 ,1. Th.
1122 Copenhagen K
DenmarkTlf. nr.: +45 88 77 47 35
E-mail:  DataProtection@clicklearn.com

CHANGES IN PERSONAL DATA COLLECTION POLICY

8.1 Any changes to this policy will be displayed to the end-users as they a) start the ClickLearn application or b) visit our content cloud environment.

VERSIONS

9.1 This is version 1 dated on 28th of May 2018.