1. About us and this privacy policy
1.1 This privacy policy sets out how Attain Learning Limited (“Attain“, “we“, “our“, or “us“) collects, stores, processes, transfers, shares and uses data that identifies or is associated with you (your “personal information“) when you use our website at attain-learning.com (our “Website“) or otherwise interact with us by email, phone or social media.
1.2 Please ensure that you have read and understood our collection, storage, use and disclosure of your personal information as described in this privacy policy.
1.3 If you have any questions about this privacy policy or how we use your personal information, please contact us by emailing us at support@attain-learning.com.
2. What does this privacy policy does not cover
2.1 We operate a platform which allows users to view and interact with customised training materials for individuals working in the financial services industry, and to receive customised virtual face-to-face training (the “Attain Platform”). This privacy policy does not cover how we use personal information in connection with the operation of the Attain Platform.
3. Who is responsible for your personal information
3.1 We are the data controller of the personal information we collect and use as described in this privacy policy. This means that we determine and are responsible for how your personal information is used when you use our Website or otherwise interact with us by email, phone or social media.
4. Personal information we collect about you and how we use it
4.1 We collect personal information that you submit directly to us when you use the Website, or otherwise communicate with us through email, phone or social media. We also collect certain personal information that is available to the public online, such as information published on social media or your organisation’s public-facing personnel profile pages.
4.2 We will collect the following information in this way:
(a) Contact information, such as your name, email address, telephone number and social media profile name, handle or page identifier (such as your LinkedIn profile page URL). We collect this information directly from you, from your social media page (such as LinkedIn) or from your organisation’s website.
(i) How we use this personal information – we use this information to communicate with you about the Attain Platform and Attain.
(ii) Legal basis we rely on – the processing is necessary for our legitimate interests, namely communicating with customers, prospective customers, investors and prospective investors.
(iii) How we obtain this information – directly from you, from your social media page (such as LinkedIn) or from your organisation’s website.
(b) Your professional information, such as the organisation where you work, your role and seniority at that organisation. We collect this information directly from you, from your social media page (such as LinkedIn) or from your organisation’s website.
(i) How we use this personal information – we use this information to ensure that our communications are directed to the appropriate persons within our customers’, prospective customers’, investors and prospective investors’ organisations. We also use this information to tailor the communications we send to you so that they are more relevant to your business.
(ii) Legal basis we rely on – the processing is necessary for our legitimate interests, namely communicating with customers, prospective customers, investors and prospective investors. The processing is necessary for our legitimate interests, namely ensuring that the contents of any communications that we send is relevant to the recipient’s needs and interests.
(c) Comments, queries and feedback that you submit to us when you contact us. We collect this information directly from you.
(i) How we use this personal information – we use this information to respond to your comments, queries and feedback about the Attain Platform and Attain. We also use this information to tailor the communications we send to you so that they are more relevant to your business.
(ii) Legal basis we rely on – the processing is necessary for our legitimate interests, namely communicating with customers, prospective customers, investors and prospective investors. The processing is necessary for our legitimate interests, namely ensuring that the contents of any communications that we send is relevant to the recipient’s needs and interests.
(d) Your communication preferences, such as whether you asked or agreed to receive emails from us promoting Attain and the Attain Platform. We collect this information directly from you.
(i) How we use this personal information – we use this information to ensure that we only send promotional emails to you in accordance with your preferences.
(ii) Legal basis we rely on – the processing is necessary to comply with a legal obligation to which we are subject, namely laws implementing the ePrivacy Directive 2002/58/EC (as amended).
5. Personal information we collect about your use of our website
5.1 We also automatically collect personal information about how you access the Website, including the date and time you access the Website, the IP address you access the Website from, information about the browser you use to access the Website (such as browser version, type and window size).
(i) How we use this personal information – we use this information to present the Website, and to do so in the correct format for your device and browser. We also use this information to manage the number of requests that the Website receives in order to identify and prevent attempts to overload and crash the Website.
(ii) Legal basis we rely on – the processing is necessary for the performance of a contract, namely the terms and conditions applicable to your use of the Website. The processing is necessary for our legitimate interests, namely ensuring the security and integrity of the Website.
5.2 We collect the above information through log files. Log files are a record of resource requests that our Website has received – i.e. a list of browsers and devices that has asked to load a page from our Website.
6. How long we keep your personal information
6.1 Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the following periods:
(a) We will store Personal information (contact information, professional information, comments, queries and feedback and communication preferences) for no longer than necessary for the purposes set out above and in accordance with our legal obligations and legitimate business interests.
(b) We will store information about how you access the Website information for 8 weeks.
6.2 We may, however, need to retain your personal information for longer where required under applicable laws.
7. Recipients
7.1 As required in accordance with how we use your personal information, we may share your personal information as follows:
(a) Service Providers – we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, such as providing hosting, or email services. These service providers will use your personal information as processors on our instructions.
(b) Social media – when we interact with you through a social media platform, that social media platform will receive and process the personal information contained in such communications. The social media platform we predominantly use in this way is LinkedIn. LinkedIn will use the personal information they collect in accordance with their privacy notice. The lawful basis we rely on for transferring this personal information is that the processing is necessary for our legitimate interests, namely communicating with you through LinkedIn.
(c) Purchasers and third parties in connection with a business transaction. Your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business. These recipients will use your personal information to assess the potential transaction with us, and otherwise only as disclosed in this privacy policy. The lawful basis we rely on for transferring this personal information is that the processing is necessary for our and the third party’s legitimate interests, namely assessing and executing a potential transaction with us.
(d) Law enforcement, regulators and other parties for legal reasons. We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Attain, its users or others. These recipients will use your personal information to assess the potential transaction with us, and otherwise only as disclosed in this privacy policy. The lawful basis we rely on for sharing personal information with these recipients is that the processing is either necessary to comply with a legal obligation to which we are subject or is necessary for our legitimate interests, namely enforcing our rights or complying with requests from regulatory authorities.
8. Storing and transferring your personal information
8.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your credit or debit card information or national identification numbers.
8.2 International Transfers of your personal information. Your personal information is primarily processed within the UK and EEA, but we may transfer personal information from the EEA or the UK to the United States where our customer relationship management service is located.
8.3 These transfers are made pursuant to Standard Contractual Clauses issued by the European Commission.
8.4 We also continually monitor the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the UK GDPR and EU GDPR.
8.5 If you wish to enquire further about the safeguards we use, including obtaining a copy of any Standard Contractual Clauses we have in place with recipients outside the EEA or UK, please contact us using the details in the “About us” section above.
9. Your rights in respect of your personal information
9.1 In accordance with applicable privacy law you may have the following rights in respect of your personal information that we hold:
(a) Right of access. The right to obtain:
(i) confirmation of whether, and where, we are processing your personal information;
(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
(iii) information about the categories of recipients with whom we may share your personal information; and
(iv) a copy of the personal information we hold about you.
(b) Right of portability. The right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
(c) Right to rectification. The right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
(d) Right to erasure. The right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
(e) Right to restriction. The right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
9.2 You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case.
9.3 You may also have the right to withdraw your consent to our processing of your personal information, where our processing is solely based on your consent.
9.4 If you wish to exercise one of these rights, please contact us using the contact details in the “About us” section above.
9.5 You may also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK, information about how to contact your local data protection authority is available here.
10. Links to third party sites
The Website may, from time to time, contain links to and from third party websites, including those of our partners, advertisers, news publications, social media platforms and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
11. Our policy towards children
The Website is not directed at persons under 18 and we do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details in the “About us” section above so that we can take steps to remove such information as quickly as possible.
12. Changes to this policy
We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
13. Notice to you
If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Website.