1. About This Privacy Policy

This privacy policy applies when you visit or use our websites, apps and other services, including events, that refer or link to this privacy policy (each, a "Service"). This privacy policy may be supplemented by additional privacy statements, terms or notices provided to you.
Talk Education Limited, UK company number 11769122 with registered office at 18 Binden Road, London, W12 9RJ, is the controller of your personal information provided to, or collected by or for, the Service.
We will indicate within the registration processes of our products and services and other registration forms what types of personal information are required and those that are requested. You may choose not to submit the requested information, but that may limit or prohibit the services that Talk Education is able to provide to you.

2. Information We Collect
We collect information about you in three ways: directly from your input, from third-party sources, and through automated technologies.

2.1 Data You Provide to Us
The types of personal information that we collect directly from you depends on how you interact with us and the Service, which may include:

• Contact details, such as your name, email address, postal address, social media handle, and phone number;
• Account login credentials, such as usernames and passwords, password hints and similar security information; 
• Other account registration and profile information, such as job title, educational and professional background and qualifications, and photo; 
• Comments, feedback and other information you provide to us, including search query data and questions or information you send to customer support; and/or 
• Interests and communication preferences, including preferred language. 

2.2 Data From Your Organisation
We may obtain personal information about you from the organisation with which you are employed or affiliated in order to activate and manage your access to and use of the organisation’s subscription to the Service, including:

• Contact details, such as your name and organisational email address, postal address, and phone number;
• Other account registration information such as job title; and/or 
• Organisational user ID 

2.3 Data From Other Sources
We also may obtain contact details and other information about you from our affiliates and from other third parties, including:

• Social networks when you grant permission to the Service to access your data on one or more networks;
• Service providers that help us determine a location in order to customise certain products to your location; 
• Businesses with which we offer co-branded services or engage in joint marketing activities; and/or 
• Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold. 

2.4 Data From Service Use, Including Cookies
The Service may automatically collect information about how you and your device interact with the Service, including:

• Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data;
• Usage data, such as the features you used, the settings you selected, your URL click stream data, including date and time stamp and referring and exit pages, search terms you used, and pages you visited or searched for on the Service; 
• For educational Services, the course modules and test questions you view, answer or complete; and/or 
• For location-aware Services, the region, city or town where your device is located in order to provide you with more relevant content for where you are in the world. 

We collect this data through our servers and the use of cookies and other technologies. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. We may use cookies and other technologies to store your preferences and settings, help you with signing in, provide targeted ads and analyse site operations. You can control cookies through your browser’s settings and other tools. However, if you block certain cookies, you may not be able to register, login, or access certain parts or make full use of the Service.

3. How We Use Your information
Depending on how you interact with us and the Service, we use your personal information to:

• Provide, activate and manage your access to and use of the Service;
• Process and fulfil a request, order, download, subscription or other transaction; 
• Provide technical, product and other support and to help keep the Service working, safe and secure; 
• Enhance and improve the Service and our other products, events, and services and to develop new products, services and benefits; 
• Offer you customised content and other personalisation to make the Service more relevant to your interests and geography; 
• Respond to your requests, inquiries, comments and concerns; 
• Notify you about changes, updates and other announcements related to the Service and our other products and services; 
• Deliver targeted advertisements, promotional messages, notices and other information related to the Service and your interests; 
• Provide you with promotional messages and other information about products, events and services of ours, our affiliates and third parties such as sponsors; 
• Invite you to participate in user testing, surveys similar promotions; 
• Identify usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations, including determining the effectiveness of our promotional campaigns and evaluating our business performance, or in other ways pursuant to a customer agreement; and/or 
• Comply with our legal obligations, resolve disputes, and enforce our agreements. 

If you are an administrator of an organisation with a subscription to the Service, we will use your details to communicate with you about your organisation’s subscription and related services. If you supply us contact information of your colleagues, we may contact those individuals with communications about the Service that may include reference to you.

4. Sharing of Your Information

4.1 Your Organisation
If you access the Service through a subscription administered by your organisation, your personal information and certain usage data gathered through the Service may be accessed by or shared with the administrators authorised by your organisation for the purposes of usage analysis, subscription management and compliance, training course progress, performance and remediation, cost attribution and departmental budgeting.

4.2 Third Party Provider
If you access a third-party content on the Service, personal information relevant to that third-party content may be shared with the content provider so that it can provide you access to the content, subject to the terms of its privacy policy.

4.3 Your Choices
We may share your personal information with our affiliates and with sponsors, joint venture entities and other third parties, including entities for which we are acting as an agent, licensee, application host or publisher, that wish to send you information about their products and services that may be of interest to you, as determined by your choices when you inform us of your communications preferences.
The Service may let you post and share personal information, comments, materials and other content. Any such contributions that you disclose publicly may be collected and used by others. Please be careful when disclosing personal information in these public areas.

4.4 For Legal Reasons
We also will disclose your personal information if we have a good faith belief that such disclosure is necessary to:

• meet any applicable law, regulation, legal process or other legal obligation;
• detect, investigate and help prevent security, fraud or technical issues; and/or 
• protect the rights, property or safety of Talk Education, our users, employees or others; and 
• as part of a corporate transaction, such as a transfer of assets to or an acquisition by or merger with another company. 

5. Grounds for Processing

When we collect or otherwise process any personal information within the scope of European data protection laws, we do so:

• where necessary to provide the Service, fulfil a transaction or otherwise perform a contract with you or at your request prior to entering into a contract;
• where necessary for our compliance with applicable law or other legal obligation; 
• where necessary for the performance of a task carried out in the public interest; 
• where necessary to enable our customers to comply with their legal obligations; 
• where applicable, with your consent; and/or 
• where necessary to operate our business, protect the security of our systems, customers and users, detect or prevent fraud, or fulfil our other legitimate interests as described in sections 2-4 above, except where our interests are overridden by your privacy rights. 

Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.

6. Data Retention

We retain your personal information for as long as necessary to provide the Service and fulfil the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. If you access the Service through a subscription administered or sponsored by your organisation, we retain your organisational contact details after the termination of your organisation’s subscription to continue to communicate with you.

7. Locations of Processing

Your personal information may be stored and processed in your region or another country where Talk Education Limited, its affiliates and their service providers maintain servers and facilities, including Australia, France, Germany, Singapore, the United Kingdom and the United States. We take steps, including through contracts, intended to ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of protection required under applicable law.
Where personal information is transferred from the European Economic Area (“EEA”) or Switzerland to a country that has not received an adequacy decision by the European Commission, we rely on appropriate safeguards, such as the European Commission-approved Standard Contractual Clauses and the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, to transfer the data.
To learn more about the Privacy Shield program, and to view these entities’ certification, please visit www.privacyshield.gov.

8. Data Security

We implement technical and organisational measures to seek to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the integrity, confidentiality, and availability of personal information.

9. Children’s Privacy
We do not knowingly collect information from children under the age of 16 or target the Service to children under 16.

10. Your Communications Preferences

You can customise and manage your communications preferences and other settings when you register with the Service, by updating your account features and preferences, by using the "opt-out" mechanisms such as "unsubscribe" or other means provided within the
communications that you receive, or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.

11. Accessing and Updating Your Information

11.1 Your Account
The Service may allow registered users to directly access and review their account information and make corrections or updates upon login at any time. Keeping such information up to date is the responsibility of the user. Registered users may also close their account directly through the Service or by contacting the Service’s customer support.

11.2 Your Rights
You have the right under European and certain other privacy and data protection laws, as may be applicable, to request free of charge:

• access to your personal information;
• rectification or erasure of your personal information; 
• restriction of our processing of your personal information, or to object to our processing; and 
• portability of your personal information. 

You have the right to object to the processing of your personal data on the basis of legitimate interests. You have the right to withdraw your consent for the usage of your data by us at any time. You have the right to raise concerns about the treatment of your personal data by us to the UK Information Commissioner’s Office (www.ico.org.uk).
If you wish to exercise these rights, please submit your request in writing via talk@talkeducation.com. We will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity.

12. Changes

We will update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. If we make any material changes, we will provide notice through the Service or by other means.

13. Contact
If you have any questions, comments, complaints or requests regarding this privacy policy or our processing of your information, please contact us via talk@talkeducation.com If you feel that a complaint has not been dealt with by us in a satisfactory manner, you have the right to lodge a complaint with the UK Information Commissioner’s Office (www.ico.org.uk).

Talk Education Limited
1st August 2020
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