Privacy Policy
Seal Richards Learning Management Systems Ltd
Seal Richards Learning Management Systems (1921565) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our website and “Sabi Stack” software as a service (Services) or when otherwise interacting with you.
The information we collect
Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
The types of personal information we may collect about you include:
- • your name;
- • your contact details, including email address, street address and/or telephone number;
- • your level of experience in a field;
- • your date of birth;
- • your credit card or other payment details (through our third party payment processor);
- • your preferences and/or opinions;
- • information you provide to us, including through feedback, customer surveys or otherwise;
- • your sensitive information as set out below;
- • details of products and services we have provided to you and/or that you have enquired about, and our response to you;
- • support requests submitted to us and our response to you;
- • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
- • information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
- • additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
- • any other personal information requested by us and/or provided by you or a third party.
Sensitive information: We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.
How we collect personal information
We collect personal information in a variety of ways, including:
- • Directly: We collect personal information which you directly provide to us, including when you register for an account, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
- • Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
- • From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
Why we collect, hold, use and disclose personal information
We process your personal information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent which are described further below:
Personal information: We may collect, hold, use and disclose personal information for the following purposes:
- • to enable you to access and use our Services, including to provide you with a login;
- • your contact details, including email address, street address and/or telephone number;
- • to provide our Services to you, including to provide your details to recruiters with your consent;
- • to enable you to access and use our associated applications and associated social media platforms;
- • to contact and communicate with you about our Services, including in response to any support requests you lodge with us or other enquiries you make with us;
- • for internal record keeping, administrative, invoicing and billing purposes;
- • for analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms;
- • to run promotions, competitions and/or offer additional benefits to you;
- • for advertising and marketing, including to send you promotional information about our products and services and other information that we consider may be of interest to you;
- • to comply with our legal obligations and resolve any disputes that we may have;
- • if you have applied for employment with us; to consider your employment application; and
- • if otherwise required or authorised by law.
Our disclosures of personal information to third parties
We only share and disclose your personal information in the following situations:
- • Contractual. We may share personal information with any third party partners to enable us to provide you with the Services, including providing your personal information to recruiters.
- • Compliance with Legal Obligations. We may disclose your personal information where we are legally required to do so in order to comply with applicable laws, governmental requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to requests from public authorities in order to meet national security or law enforcement requirements).
- • Vital Interests. We may disclose your personal information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, illegal activities or situations involving potential threats to the safety of any person, or where we believe it is necessary for the purpose of providing evidence in connection with litigation proceedings in which we are involved.
- • Third Party Service Providers. We may share your personal information with third party vendors, service providers, credit reference agencies, trade associations of which we are a member, credit card associations, contractors or agents who perform services and require access to such personal information to carry out that work, including without limitation Mailchimp and Microsoft Clarity. Such third parties will only have access to your personal information to the extent that they need to perform those services. They are required to keep your personal information confidential and may not use it other than as we ask them to and always in accordance with this Privacy Policy.
- • Business Transfers. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- • Third Party Advertisers. We may use third party advertising companies to serve ads when you visit our website. These companies may use information about your visits to our website and other websites that are contained in web cookies and other tracking technologies in order to provide personalised advertisements about goods and services that may be of interest to you. See our Cookie section for further information.
- • Business Partners. Provided you have given us consent to do so we may share your personal information with our business partners to offer you certain products, services or promotions.
- • With your consent. We may disclose your personal information for any other purpose with your consent, including with any person who you have named as a person we can contact to discuss your account and any agent or representative of yours.
- • Google Analytics: We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.
Overseas disclosure
We may store personal information overseas. Where we or any third parties that we use transfer your personal information overseas we will take all reasonably practicable measures to protect your personal information in accordance with this Privacy Policy and applicable laws. To the extent that any transfer requires approved safeguards to be in place we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information. Where we use certain service providers, we may use specific contracts approved for use (for example the Standard Model Contractual Clauses). Please contact us if you want further information on the specific mechanism(s) used by us when transferring your personal information overseas.
Consent
You will be required to give consent to certain processing activities before we can process your personal information. Where applicable, we will seek consent from you when you first submit personal information to or through the Services.
If you have previously given your consent you may freely withdraw such consent at any time. You can do this by emailing hello@sabistack.com or, where applicable, clicking the ‘Unsubscribe’ button that appears in mailing list communications.
If you withdraw your consent, and if we do not have another legal basis for processing your personal information, then we will stop processing your personal information. If we do have another legal basis for processing your personal information, then we may continue to do so subject to your legal rights.
Please note that if we need to process your personal information in order for you to use the Services and you object or do not provide consent to us processing your personal information, you accept that the Services will no longer be available to you.
Your rights and controlling your personal information
You have certain rights in relation to the personal information that we hold about you depending on where you are located or from. For EU and UK citizens and residents you have a number of specific rights, details of these rights and how to exercise them are set out below. If you are based in another country and request to exercise one of the rights below or any other right you may have, we will do our best to fulfil such a request and will always fulfil the request if legally required. Please note that we will require evidence of your identity before we are able to respond to any requests. This is a security measure to ensure that your personal information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. To exercise or discuss any of your rights, please contact us via hello@sabistack.com
- • Right of Access. You have the right at any time to ask us for a copy of the personal information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason(s) for doing so.
- • Right of Correction or Completion. If the personal information we hold about you is not accurate or is out of date and requires amendment or correction, you have a right to have the data rectified or completed.
- • Right of Erasure. In certain circumstances, you have the right to request that the personal information we hold about you is erased (for example, if the personal information is no longer necessary for the purposes for which it was collected or processed or our processing of the personal information is based only on your consent and there are no other legal grounds on which we may process the personal information).
- • Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information (for example, if we are processing your personal information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests).
You may also have the right to restrict our use of your personal information, for example during a period in which we are verifying the accuracy of your personal information in circumstances where you have challenged the accuracy of that personal information.
- • Right of Data Portability. In certain instances, you have a right to receive the personal information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format.
In such circumstances, you can ask us to transmit your personal information to you or directly to a third-party organisation on your behalf.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
If we are relying on consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing that occurred before the withdrawal of such consent.
Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.
Cookies
We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.
We use the following cookies:
- • Essential cookies. These cookies are required for the operation of the Services. They include, for example, cookies that enable you to log in to secure areas of the Services, use a shopping cart or make use of e-billing services.
- • Analytical/performance cookies. These cookies allow us to recognise, and count the number of, visitors and to see how visitors move around the Services when they are using it. This helps us to improve the way the Services works, for example by ensuring that users are finding what they are looking for easily.
- • Functionality cookies. These cookies enable us to recognise you when you return to the Services. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- • Targeting cookies. These cookies record your visit to the Services, the pages you have visited and the links you have followed. We will use this information to make the Services and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for related purposes.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Services.
If you would like more information about these third-party cookies, it is available from www.youronlinechoices.com/uk.
Note that when third parties are collecting information about you, those third parties are acting as controllers in their own right (i.e. they are not acting on our behalf).
Links to other websites
Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
Personal information from social network accounts
If you connect your account with us to a social network account, such as Google, we will collect your personal information from the social network. We will do this in accordance with the privacy settings you have chosen on that social network.
The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows and any other personal information you choose to share.
We use the personal information we receive from the social network to create a profile for you on our platform and connect you to your submissions.
If you agree, we may also use your personal information to give you updates on the social network which might interest you. We will not post to your social network without your permission.
Individuals under 18
The Services are not directed to individuals who are under the age of 18 and we do not solicit or knowingly collect personal information from children under the age of 18. If you believe that we have unknowingly collected any personal information from someone under the age of 18, please contact us immediately.
Use of Google API Services (this section applies to personal information accessed through Google API Services)
We use Google’s Application Programming Interface (API) Service to grow our digital brand, process payments for you, store data securely and helps us build and develop our platform.
Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements (set out in the Google API Services User Data Policy).
We limit our use of the personal information that we collect to providing or improving our Services. We do not use the personal information for any other purposes.
We only transfer the personal information to others if it is necessary to provide or improve our Services or as necessary to comply with applicable law or as part of a merger, acquisition or sale of assets where we notify you of this.
We do not use or transfer the personal information for serving ads, including retargeting, personalised or interest-based advertising.
These restrictions apply to the raw data we obtain from the restricted scopes and data that is aggregated, anonymised or derived from them.
We have policies and procedures in place setting out appropriate safeguards for protecting your personal information obtained with the Google APIs. We will also ensure that our employees, agents, contractors and successors comply with the Google API Services Data Policy.
Contact Us
We welcome your feedback and questions on this Privacy Policy. If you wish to contact us about this Privacy Policy or have any other questions, please email us via hello@sabistack.com