Privacy Notice

Learning Technologies Group (UK) Limited trading as Leo Learning and its group companies ("we", "us", “LEO Learning” or "LEO GRC (formerly Eukleia)") are committed to protecting and respecting your privacy.

Please read this Privacy Notice to understand our views and practices regarding your personal data and how we will collect and use it.

We are responsible for the operation of our website at https://leolearning.com ("our site"). Our corporate details are: Learning Technologies Group (UK) Limited trading as LEO Learning, Projects The Lanes, Nile House, Nile St, Brighton, BN1 1HW, UK, Tel. +44(0) 20 7832 3440.  We are part of the Learning Technologies group of companies (https://www.ltgplc.com/).

If you have any questions relating to our use of your personal data, please contact us by email at privacy@ltgplc.com or by mail addressed to our Privacy Team at one of the following addresses:

Information we may collect from you

We may collect and process the following data about you:

• Information that you provide.  This may be by filling in forms on our website, filling in our contact forms at events, providing us with your business card or contact details, providing us with your information in registering to use our client support tools, and/or or by corresponding with us by phone, email or otherwise.  The information that you provide to us may include name, email address, company and position, address and telephone number, and such other information as may be communicated to, or provided by you as well as the details contained in your query;
• Browsing and Cookies.  No personal information - such as your name, address, contact phone numbers or email address - will be collected if you are only browsing our site, but we use cookies on our site as specified in our cookie policy. Some of our Cookies may collect your IP address, but if you are only browsing and provide no additional personal information, we would not be able to identify you from that information.

Where we store your personal data and how long for

Our website is hosted on servers located in the UK and support being provided from the UK and the US. Any personal information that we collect from you is input directly into our Salesforce database, which is hosted and supported in the European Economic Area (EEA), and our Pardot database, which is hosted and supported in the US. For individuals based in the EEA, this means that the data that we collect from you will be transferred to, and stored outside the EEA.  It may also be processed by staff operating outside the EEA who work for us. LEO Learning and LEO GRC (formerly Eukleia) has signed EU Model Clauses with our relevant group companies and with Pardot, which means that such transfers would be lawful transfers of personal data outside the EEA, in accordance with EU Data Protection legislation.

Unfortunately, the transmission of information via the internet is almost never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data transmitted to our site or otherwise gathered by us; any transmission and supply of personal data to us is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

We will keep a copy of any personal data obtained from you through our site or otherwise for as long as we believe is reasonably required, or such longer period as may be required for legal, audit and compliance purposes.  This does not affect your right to opt out from receiving marketing communications, as outlined above and in the section “Your rights” below. Please note that you may request that your details are deleted from our CRM system at any point of time, however you should be aware that if your details are deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future.

Uses made of the information

We use information held about you in the following ways:

• To provide you with information via post, email or telephone, about our products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
• To carry out our obligations arising from any contracts entered into between you and us or to enable us to deal with any query you have raised;
• To allow you to participate in interactive features of our service, when you choose to do so;
• To notify you about changes to our service;
• To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure.

This will include your details being included in our Salesforce and Pardot databases.

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, provided however that LEO Learning and LEO GRC (formerly Eukleia) shall remain responsible for the treatment of such group members of your personal data in accordance with this policy. As stated above, where such disclosure involves the transfer of data outside of the EEA LEO Learning and LEO GRC (formerly Eukleia) has entered into EU Model Clauses with its group entities to ensure any such disclosure is on a legal basis.

Our general policy is not to disclose any personal data to a third party except with your prior consent. However, we may disclose your personal information to third parties:

• If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If LEO Learning and LEO GRC (formerly Eukleia) or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers 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 our terms of business and other agreements; or to protect the rights, property, or safety of LEO Learning and LEO GRC (formerly Eukleia), our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Legal basis of our processing of your personal data.

We process your personal data for the following purposes, on the following legal bases:

Data Subject rights – EU and UK residents

You have the right to ask us not to process your personal data for marketing purposes. You may also choose not to receive publications or certain other communications from us at any time by opting-out by phone, email or via direct marketing emails sent to you.

You have the right to verify whether we hold your personal data and access your personal data. You can made a request to access your data by submitting a written request to the contact addresses below. We may need to verify your identity before we are able to respond.

You also have the right to ask us to amend inaccurate personal data or to delete it. However you should be aware that if you request your details to be deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future.  If you send us any personal information in digital format, such as photographs, you are entitled to ask for a copy of this to be sent to you.

Any queries concerning your rights or the exercising of them and any complaints concerning the processing of your personal data should be sent to the contact addresses listed below.

Our site may, from time to time, contain links to and from the websites of our group companies, partner networks, clients, and/or affiliates. If you follow a link to any of these websites, please note that these websites are subject to their own privacy policies and that we do not accept any responsibility or liability for these sites and policies. Please check these policies before you submit any personal data to these websites.

Consumer Rights – California Residents

Where we collect your personal data via our website, we will provide notice at or before the point of collection so that you are aware of how your data is being used. Any data collected through our website will be used for marketing and/or sales purposes as appropriate. We will not sell your personal data to a third party.

You have the right to request that we provide you with a list of the categories of your personal data we hold, the categories of sources from which we have obtained this data, and the categories of third parties that we may share this data with. You may also request that we provide you with a copy of any of your data that we have collected. You can made a request to access your data at any time by submitting a written request to the contact addresses below. We may need to verify your identity before we are able to respond.

You also have the right to ask us to delete your personal data. However you should be aware that if you request your details to be deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future. You can exercise this right at any time by submitting a written request to the contact addresses below.

We will never deny you goods or services, charge you a different price or rate for goods or services, provide you with a different level or quality of goods or services, or suggest any of the aforementioned actions based upon you exorcizing your rights to your data.

Our site may, from time to time, contain links to and from the websites of our group companies, partner networks, clients, and/or affiliates. If you follow a link to any of these websites, please note that these websites are subject to their own privacy policies and that we do not accept any responsibility or liability for these sites and policies. Please check these policies before you submit any personal data to these websites.

Art. 27 GDPR – EU representative

All LEO Learning and LEO GRC (formerly Eukleia) entities based outside of EEA have, to the extent the GDPR is applicable to them in regard to any data processing performed by them, appointed Learning Technologies Group (UK) Limited trading as Leo Learning, (with address details as stated above) to act as their designated representative within the EEA for the purposes of Art. 27 of the GDPR.  Learning Technologies Group (UK) Limited trading as Leo Learning and LEO GRC (formerly Eukleia) is mandated to be addressed in addition to, or instead of such LEO Learning and LEO GRC (formerly Eukleia) entities based outside the EEA, by supervisory authorities and data subjects with any issues related to our processing of personal data.

COPPA

In accordance with the Children’s Online Privacy Protection Act (“COPPA”) and the GDPR, our Services are not intended to be used by children and we do not knowingly request, solicit, access or receive personal information (as defined in COPPA and the GDPR, as applicable) from anyone under the age of 13 and 16 respectively. Where we are aware that any personal information submitted through our sites or our Services belongs to a child, we will delete this personal information from our records.

Whilst this is not our intention, our Services could be used to collect personal information from children under the age of 16. Where you make use of our Services to collect such personal information, you become an “operator” under COPPA and it becomes your obligation as our customer to comply with the relevant requirements of the COPPA and/or the GDPR, as applicable (and any other applicable laws and regulations).

While it is your responsibility, not ours, to ensure compliance with COPPA and the GDPR where you act as our customer and are the account owner and determine the data collection and processing, in the event we have actual notice that you have collected personal information in violation of COPPA and/or the GDPR, we will require you to comply with COPPA and/or the GDPR, and we may delete any violating personal information you are processing without notice.

Complaints

Where you are based in the EU you have the right to complain to your local data protection authority although we would ask that you contact us first in order that we can try to resolve the issue.

Changes to our privacy notice

This notice is kept under review and may be updated by us from time to time.  Updated versions will be made available on our site.

Last updated: February 2020

Where we store your personal data and how long for

Our site is hosted on servers located in the UK and support being provided from the UK and the US. Any personal information that we collect from you is input directly into our Salesforce database, which is hosted and supported in the European Economic Area (EEA), and our Pardot database, which is hosted and supported in the US. For data subjects based in the EEA, this means that the data that we collect from you will be transferred to, and stored outside the EEA. It may also be processed by staff operating outside the EEA who work for us. LEO Learning and LEO GRC (formerly Eukleia) has signed EU Model Clauses with our relevant group companies and with Pardot, which means that such transfers would be lawful transfers of personal data outside the EEA, in accordance with EU Data Protection legislation.

Unfortunately, the transmission of information via the internet is almost never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data transmitted to our site or otherwise gathered by us; any transmission and supply of personal data to us is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

We will keep a copy of any personal data obtained from you through our site or otherwise for as long as we believe is reasonably required, or such longer period as may be required for legal, audit and compliance purposes. This does not affect your right to opt out from receiving marketing communications, as outlined above and in the section “Your rights” below. Please note that you may request that your details are deleted from our CRM system at any point of time, however you should be aware that if your details are deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future.

Uses made of the information

We use information held about you in the following ways:

• To provide you with information via post, email or telephone, about our products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
• To carry out our obligations arising from any contracts entered into between you and us or to enable us to deal with any query you have raised;
• To allow you to participate in interactive features of our service, when you choose to do so;
• To notify you about changes to our service;
• To administer our site and for internal operations, including trouble shooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure.

This will include your details being included in our Salesforce and Pardot databases.

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, provided however that LEO Learning and LEO GRC (formerly Eukleia) shall remain responsible for the treatment of such group members of your personal data in accordance with this policy. As stated above, where such disclosure involves the transfer of data outside of the LEO Learning and LEO GRC (formerly Eukleia) has entered into EU Model Clauses with its group entities to ensure any such disclosure is on a legal basis.
Our general policy is not to disclose any personal data to a third party except with your prior consent. However, we may disclose your personal information to third parties:

• If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If LEO Learning and LEO GRC (formerly Eukleia) or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers 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 our terms of business and other agreements; or to protect the rights, property, or safety of LEO Learning and LEO GRC (formerly Eukleia), our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Legal basis of our processing of your personal data.

We process your personal data on the basis of your consent (in relation to sending you marketing information following your submitted request through our site) and (alternatively or additionally) for our legitimate interests of promoting, growing and developing our business and, where you are a customer, in order to perform our obligations under the contract between us.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. You may also choose not to receive publications or certain other communications from us by explicitly indicating so in the appropriate section of the Registration Form or by opting-out by phone, email or via direct marketing emails sent to you.

We will inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to, or may disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by (un)checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at privacy@ltgplc.com or by unsubscribing per the method outlined in any emails sent or during any phone calls with you.

Our site may, from time to time, contain links to and from the websites of our group companies, partner networks, clients, and/or affiliates. If you follow a link to any of these websites, please note that these websites are subject to their own privacy policies and that we do not accept any responsibility or liability for these sites and policies. Please check these policies before you submit any personal data to these websites.

You also have the right to ask us to amend inaccurate personal data or to delete it. However you should be aware that if you request your details to be deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future. If you send us any personal information in digital format, such as photographs, you are entitled to ask for a copy of this to be sent to you.

Where you are based in the EU you have the right to contact your local data protection authority and you can request details of how to do this by contacting us at privacy@ltgplc.com.

Any queries concerning your rights or the exercising of them and any complaints concerning the processing of your personal data should be sent to privacy@ltgplc.com.

Access to information

We are subject to the Data Protection Act in the UK and, for our processing activities in Europe, the Data Protection Directive 95/46/EC and e-Privacy Directive 2002/58/EC (together with national implementing legislation), and, effective May 25, 2018, the General Data Protection Regulation 2016/670 (“GDPR”) (together referred to as “Applicable Legislation”), all as may be updated or replaced over time. The Applicable Legislation gives you the right to verify whether we hold your personal data and (have) access your personal data. Any data access request may be subject to a reasonable fee to meet our costs in dealing with your request.

Art. 27 GDPR – EU representative

All LEO Learning and LEO GRC (formerly Eukleia) entities based outside of EEA have, to the extent the GDPR is applicable to them in regard to any data processing performed by them, appointed Leo Learning Limited (with address details as stated above) to act as their designated representative within the EEA for the purposes of Art. 27 of the GDPR. Leo Learning Limited is mandated to be addressed in addition to, or instead of such LEO Learning and LEO GRC (formerly Eukleia) entities based outside the EEA, by supervisory authorities and data subjects with any issues related to our processing of personal data.

Changes to our privacy policy

This policy may be updated by us from time to time, so please check this policy periodically to ensure you are aware of our latest policies.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@ltgplc.com. Complaints should be sent to the same address.