We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.
Use of our Site as a registered account holder
You may be required to register an account with us in order to gain access to certain features and functionality of the Site, including the ability to make Video Content available to students. Applicants will need to complete the registration form, providing all required Account Registration Data. We will use this data in order to process your registration.
Once the account is registered, we will process your username and password to identify you when you log in to your account and access secure areas of our Site. We will also process your Account Registration Data, Profile Data and certain Technical Data so that we can administer your account and contact you about your account.
We will also collect and process Observed Data and Technical Data when you use certain features and functionality. This data helps us understand which Video Content you make available to students, so that we can assess the popularity of different Video Content. Our legal basis for processing It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to the Site in a secure and effective way and so that we can make improvements to our Site and Video Content.
Our legal basis for processing It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to the Site in a secure and effective way and so that we can make improvements to our Site and Video Content.
If you access our Video Content
When you access Video Content, we will collect and process certain Observed Data and Technical Data in connection with your use of that Video Content in order to compile usage statistics that help us understand how our Video Content is being used. For example, we can see which Video Content has been accessed, how many times it has been accessed by a student and whether it has been viewed in full or has been abandoned part way through.
Our legal basis for processing
It is in our legitimate interest to use personal data in such a way to ensure that we provide access to the Video Content in a secure and effective way and so that we can make improvements to our Site and our Video Content. If you browse our Site
When you browse our Site, we collect and process Observed Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can better understand which parts of our Site are more or less popular and improve the structure and navigation of our Site.
Our legal basis for processing
It is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Platform in a secure and effective way and so that we can make improvements to our Site.
If you link to social media sites and interact with our social media pages
If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Site or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Observed Data and Technical Data. For more information about how we use this personal data, please see the “Insight and analysis” section below.
The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.
Our legal basis for processing
Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data in the ways described to ensure that we are able to help you and others with technical support enquiries and ensure our Site is operating properly.
If you have a general question or need help with any aspect of our Site
Our Site features a “Contact Us” page, which invites you to submit general enquiries about our Site by email or via our Enquiry Form (see the “How to contact us” section above). From time to time, you may also be able to submit specific enquiries on other pages of our Site, including in secure account areas.
When you make an enquiry, we will collect and process your Contact Data and, if applicable, certain Account Registration Data and Profile Data, as well as any other personal data you volunteer that is relevant to your enquiry. We use this information to manage and respond to your enquiry. We may also use such data to help train our staff and improve our customer service generally.
Our legal basis for processing
It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry and provide a good standard of service.
If you complete our surveys or provide feedback on your experience of our Site
From time to time, we will invite you to provide feedback about us, our Site and our Video Content in the form of online surveys. We will collect and process your Contact Data and, if applicable, certain Account Registration Data and Profile Data, and any other personal data you choose to volunteer in your survey response or other feedback.
We use this information to help us to monitor and improve our Site and our Video Content to assist with the selection of future product and service lines, and to train our personnel.
We use this information to help us to monitor and improve our Site and our Video Content to assist with the selection of future product and service lines, and to train our personnel.
You can also voluntarily provide feedback by email or via our Enquiry Form.
Our legal basis for processing
It is in our legitimate interest to use the personal data provided by you so that we can improve our Site and our Video Content and provide them in an effective way.
If you participate in one of our prize draws, competitions or other promotions
From time to time, we may run prize draws, prize competitions and other promotions on our Site and/or on our social media accounts. For the purposes of administering such promotions, we may process your Contact Data, Account Registration Data, Profile Data, Observed Data and/or Technical Data and any other personal data volunteered by you in your promotion entry. Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions) or it is in our legitimate interest to use your personal data to enable us to administer our promotion effectively.
Insight and analysis
If we use cookies to help us understand more about you and your use of our Site and Video Content. We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Site, our Video Content and emails that you receive from us. The data that is collected includes Observed Data and Technical Data, and certain Profile Data. Please see our Cookie Policy for further information, including details of our third-party partners.
We and our third-party partners use this data to analyse how you use our Site and the effectiveness of our Site, including:
- to count users who have visited our Site or opened an email and collect other types of information, including insights about our users’ browsing habits, which helps us to improve our Site and our Video Content and the effectiveness of our emails;
- to learn what Video Content and pages of our Site are most attractive to our users, which parts of our Site are the most interesting and what kind of features and functionalities our users like to see;
- to help us understand the type of marketing content that is most likely to appeal to you; and to help us with the selection of future product and service lines, website design and to remember your preferences.
In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
Our legal basis for processing
Where your data is collected through the use of non-essential cookies, we rely on consent to collect your data. Please see our Cookie Policy for further details.
However, we may rely on another legal basis when we use your personal data collected via the use of essential cookies, because consent is not required to drop cookies that are essential for the operation of our Site. For example, where we use personal data collected through the use of essential cookies to analyse how you use our Site and our Video Content, it is in our legitimate interest to use your personal data in such a way to improve our Site and our Video Content.
Advertising and marketing activities
This section describes how we may use your personal data to send our advertising to you (including to decide what advertising to send you) and how we and our third-party advertising partners may use your personal data to display our advertising to you when you visit or use other websites and/or online services. In some cases, we may be joint controllers with our third-party advertising partners – please see the end of this “Advertising and Marketing” section for more information about our joint controller relationships.
Post, email and SMS/MMS
We use your Contact Data to send you (or the organisation you represent) marketing communications by post and/or email and/or SMS/MMS. Our marketing will include press releases and information about us, our Platform, our Video Content and the offers and promotions we offer from time to time.
Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you and is sent to subscribers generally.
Where we are sending you personalised marketing, we may also use Account Registration Data, Profile Data and Observed Data to help us decide what sort of personalised marketing to send you (please see the “Insight and analysis” section above for more details).
Our legal basis for processing
It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you and to send that content to you by post. However, we will only send you marketing by email where you have consented to receive such content by those communication channels, or where we have another lawful right to send marketing to you using such channels. For example, we may rely on our legitimate interest to send marketing by email to certain business users of our Platform.
Online advertising through third-party tools
Our third-party advertising partners may provide tools that we can use to display our advertisements to people who we think are more likely to be interested in our Platform.
For example, an advertising partner may have determined that you are someone of a particular age from a particular geographic location who has certain interests, using data that they have collected about you (which we do not receive). If we want to display our advertising to people who meet those criteria on third-party websites that use the services of our advertising partner, we may ask our advertising partner to display our advertising to you.
Our legal basis for processing
If you are someone who has seen this type of advertising, it is in our legitimate interests that the relevant third-party advertising partner uses the data that you have provided to it to advertise our Site, although please note that we do not receive this data and you should exercise your rights in respect of such data in accordance with the privacy notice of the relevant online service that displays our advertising to you.
Online advertising through Observed Data
We and our third-party partners may use Observed Data that is collected through your interactions with our Site to provide you with, and analyse the effectiveness of, our personalised and non-personalised advertising that you see when you visit or use other websites and/or services. For example, we use the Facebook Pixel (or Meta Pixel, as it is now known) on our Site, so that Facebook can collect Observed Data about your use of our Site and then display our advertising to you on Facebook.
By “personalised” ads, we mean ads for products and services that you have shown an interest in when you have used our Platform or which we or our third-party partners think you otherwise might be interested in based on Observed Data. Our third-party partners may use the data that is collected to show personalised ads for products and services offered by third parties. Non-personalised ads are not tailored to you.
Our legal basis for processing
Please see the “Insight and Analysis” section above to learn about the legal basis that we rely on to collect data via the use of Cookies.
Where we use your personal data to display personalised online advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interest to promote our Platform to you.
Our third-party partners may rely on a different lawful basis in respect of their use of your personal data. Please read the privacy notice of the relevant third-party provider (see our Cookie Notice for details.)
Online “lookalike” advertising on social media platforms
We may share the Contact Data of our registered users (your email address, in an encrypted or ‘hashed’ form) with social media platforms such as Facebook, LinkedIn and Twitter (“Social Media Platforms”), so that the Social Media Platform can “match” our registered user data with the data of their registered users.
If you are a user of those Social Media Platforms and a “match” occurs, we may ask those Social Media Platforms to find other registered users of their services who share similar interests and characteristics to you, which will be based on information that the Social Media Platform holds about you and its other registered users (which we do not receive).
This is known as “lookalike” advertising because we are trying to show our advertising to people who “look like” you and other existing users of our Platform. We do not currently advertise to our existing registered users on Social Media Platforms using “lookalike” advertising, but you may still see our advertising on Social Media Platforms where we use other online advertising tools (for more information, please see the two online advertising sections immediately above this one).
If you are someone who has seen our “lookalike” advertising on a Social Media Platform, this is because the Social Media Platform has determined that you “look like” our registered users. Please note that this activity is based on data that you have provided to the relevant Social Media Platform (which we do not receive) and is also subject to the privacy choices you have elected to make on such third-party services. If you wish to opt out of receiving this form of advertising, you will need to update your preferences on the relevant Social Media Platform.
Our legal basis for processing
It is in our legitimate interests to share your personal data with the Social Media Platforms so that we can advertise our Platform to other individuals that use those Social Media Platforms and share similar interests and characteristics with you. You can opt-out of our sharing of your personal data with the Social Media Platform by exercising your rights as a data subject as explained in the “Your rights as a data subject” section below.
If you are someone who has seen our “lookalike” advertising on a Social Media Platform, it is in our legitimate interest that the Social Media Platform uses the data that you have provided to it to advertise our Platform, although please note that we do not receive this data and you should exercise your rights in respect of the processing of such data in accordance with the privacy notice of the relevant Social Media Platform that displays our advertising to you.
How Social Media Platforms process your personal data when we undertake online advertising
Facebook
We are joint controllers with Facebook Ireland Limited (“Facebook”) in respect of some of the activities described in this section, where these activities involve advertising on Facebook. We and Facebook have entered into Facebook’s Controller Addendum (available here) to determine our and Facebook’s respective responsibilities for compliance with data protection obligations in respect of these activities. In particular, we are each responsible for providing information about how your data might be processed in connection with these activities in our respective privacy notices. Where a party has a direct relationship with the data subject, that party will be responsible for complying with any rights requests from the relevant data subject. However if you are not a user of our Platform, Facebook will take primary responsibility for giving effect to your data subject rights in respect of these activities. For further information about how we and Facebook use your personal data in connection with these activities, including the legal basis Facebook relies on and the ways to exercise your data subject rights against Facebook, please see Facebook’s Data Policy at https://www.facebook.com/about/privacy.
Twitter
Twitter has published information about how it uses your personal information in connection with its advertising services, including how you can opt-out of Twitter’s interest-based advertising, here: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads.
LinkedIn
LinkedIn has published information about how it uses your personal information in connection with its advertising services, including how you can opt-out of LinkedIn’s interest-based advertising, here: https://www.linkedin.com/psettings/advertising-data and here: https://www.linkedin.com/help/linkedin/answer/a421454.
Business administration and legal compliance
If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business. We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
Our legal basis for processing
Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.