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What You Agree to by Using Our Site

We consider that the legal bases for using your personal information as set out in this Privacy Notice are as follows:

• our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the Terms of Use of our Site which you accept by browsing our website and/or to comply with our contract to provide Services to you, your academic institution, your employer, or other organization that may be providing you with access to our Services); or

• our use of your personal information is necessary for complying with our legal obligations, or

• use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:

  • run, grow and develop our business;

  • operate our Site and provide our Services;

  • select appropriately skilled and qualified suppliers;

  • build relationships with partners and academic institutions;

  • carry out research and statistical analysis;

  • carry out marketing and business development; and

  • for internal administrative and auditing purposes.

• consent, to send you certain communications, where you submit certain information to us, or were required to rely upon consent by local law.

Which legal basis applies to a specific activity will depend on the type of personal information used and the context in which it is being used.

Suppose we rely on our (or another party’s) legitimate interests for using your personal information. In that case, we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by asking so at efadlearning@efad.org. If you withdraw your consent, this may impact our ability for us to provide some of our Services to you.

What Information We Collect

We gather the following types of information about users through the Site:

1. Information relating to your use of our Site. When users come to our Site, we may track, collect, and aggregate information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system, and browser software used by each user of the Site. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of their point of connectivity. Location data may be used to route your traffic to the nearest regional server to reduce latency and improve your experience. We may also use cookies when you visit our Site.

2. Personal Data provided directly by you. We collect Personal Data that you provide to us when you register for an account, update or change information for your account, complete a course, complete a survey, sign-up for email updates, participate in our webinars, send us email messages, and/or participate in other Services on our Site. We may use the Personal Data that you provide to respond to your questions, provide you with the specific Services you select, send you updates about Courses or other EFAD Learning events, and send you email messages about Site maintenance or updates.

• Account Registration. If you register for an account on our Site, you may be required to provide us with certain Personal Data such as your name and email address. You may also voluntarily provide us with additional Personal Data.

• Updates. EFAD Learning may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these Services, you may be required to provide us with Personal Data such as your name and email address.

• Webinars. EFAD Learning may offer online webinars from time to time. In order to participate in the Webinars, you may be required to register with us and/or provide us with Personal Data such as your name and email address. 

• Participation in Focus Groups. EFAD Learning might offer users the opportunity to participate in Focus Groups on or through the Site. If you desire to participate in a Focus Group, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.

• We also collect course data, such as responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate in or submit such assignments, exams, or surveys.

• Communications with EFAD Learning. We may receive Personal Data when you send us an email message or otherwise contact us.

• Third-Party Sites. We may receive Personal Data when you access or log in to a third-party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personal Data available from the third-party site.

• Surveys. We may receive Personal Data when you provide information in response to a survey operated by us.

How We Use the Information

1. Information relating to your use of our Site. We use information relating to your use of the Site to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behaviour of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our Services and the Site.

2. Personally Identifiable Information provided directly by you or via third parties. Except as set forth in this Privacy Notice or as specifically agreed to by you, EFAD Learning will not disclose any of your Personal Data. In addition to the other uses set forth in this Privacy Notice, we may disclose and otherwise use Personal Data as described below.

• Providing the Site and our Services. We use Personal Data that you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or Services that you request from us.

• Technical support and security. We may use Personal Data to provide technical support to you, where required, and to ensure the security of our Services and the Site.

• Updates. We use Personal Data collected when you sign-up for our various email or update services to send you messages in connection with the Site or Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.

• Participation in Courses. We use the Personal Data that we collect from you when you participate in a Course through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of the Courses. We may also share your Personal Data and your performance in a given Course with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Course, and with the Course(s) with which they are affiliated. We may also use the information generated when taking a Course or using the Services for predictive analysis of your performance in the Course. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.

• Communications with or from EFAD Learning. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Notice. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information to optimise and better tailor our communications to you.

• Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us, for research related to online education.

• Disclosure to EFAD Learning Operations and Maintenance Contractors. We use various service providers, vendors, and contractors (collectively, "Contractors") to assist us in providing our Services to you. Our Contractors may have limited access to your Personal Data in the course of providing their products or services to us so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Content Offerings. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.

• Government Authorities; Legal Rights and Actions. EFAD Learning may share your Personal Data with various government authorities in response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personal Data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of EFAD Learning, the Site, our users, partners, or others; and in connection with our Terms of Use and other agreements.

• Disclosure to Acquirers. EFAD Learning may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of EFAD Learning to which your Personal Data relates.

Updating or Deleting Your Personal Data

You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us, and request that we delete or provide you with a copy of your personal data by contacting us via efadlearning@efad.org.

If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via efadlearning@efad.org. You have the right to request that we:

• provide access to any Personal Data we hold about you;

• prevent the processing of your Personal Data for direct marketing purposes;

• update any Personal Data which is out of date or incorrect;

• delete any Personal Data which we are holding about you;

• delete your account;

• restrict the way that we process your Personal Data;

• provide your Personal Data to a third-party provider of services; or

• provide you with a copy of any Personal Data which we hold about you.

We try to answer every request promptly where possible and provide our response within the time period stated by applicable law. Keep in mind, however, that when deleting your Personal Data there may be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if we need to retain your Personal Data to comply with a legal obligation. When you email us with a request, we may ask that you provide us with the information necessary to confirm your identity.