Nikkei FT Learning Limited (“NFTL”) respects your privacy and is committed to protecting your personal data.
It is important that the personal data we hold about you is accurate and current. Please use the product features we provide and keep us informed if your personal data changes during your use of our website and products.
If you have any questions about how we use your personal information, or want to request access to, change, or erase the personal information we hold about you, please contact our Data Protection Officer at firstname.lastname@example.org or write to us at Nikkei FT Learning, Królewska 65A, 30-081 Kraków, Poland.
The website and products are not intended for individuals aged under 16 and we do not knowingly collect data relating to individuals aged under 16.
The controller of the data we collect is Nikkei FT Learning Limited, (referred to as NFTL, “we”, “us” or “our” in this privacy notice). Our registered office is at: One Southwark Bridge, London, England SE1 9HL. Our Company number is; 10796408
This version was last updated on 20 June 2018.
INFORMATION WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of data about you including;
- Identity Data including first name, last name, username or similar identifier for use within our services, title, date of birth and gender, email address, avatar, employer contact data, department of employment, manager contact data.
- Operational Data (information generated during your use of our services) including but not limited to activity state and test scores, attendance data, the content of messages exchanged by email or messaging feature within our product, the results of surveys, customer service contact history and English language proficiency level.
- Technical Data including internet protocol (IP) address, your login data, device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our product and services.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data is anonymised and does not directly or indirectly reveal your identity.
If you refuse permission for us to collect your personal data we may not be able to provide you with access to our products and our services.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect personally identifiable information about you in different ways, including:
- the provision of your contact details to us either online or offline
- when you request marketing materials to be sent to you or for one of our team to contact you
- when you purchase our products or services or they are purchased for you by your employer
- when you download and use our app
- when you give us some feedback
HOW WE USE YOUR PERSONAL DATA
We only use your Data for lawful purposes which include:
- Our legitimate business purposes – This is where we have a legitimate interest, as a business, to process personal information. For example, we ask for your contact name and phone number when requesting further information about our products and services via the contact form on this website, so that we know who we are dealing with when responding to your request.
- Contractual necessity – This is where we have to process personal information to meet our contractual obligations. For example, we need your email address in order to grant you access to use our products and services.
- Legal obligation – This is where we have to process personal information in order to comply with the law. For example, we process and retain purchase information to comply with financial regulations.
We only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose we will notify you to explain the legal basis which allows us to do so. In some instances we may use your personal data without your knowledge or consent, in compliance with the above rules, only where this is required by law.
We collect your personal information for five main reasons:
- delivering you our products and services, including directing you to make best use of our product, and from time to time informing you or the party who has purchased the product on your behalf about your use of the product
- administering, improving, and protecting our products and services, involving troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
- delivering relevant product content, website content and advertisements to you, including measuring the effectiveness of our advertising, product features and content
- for marketing purposes, including using the personal data you have provided us with to define what we think you may want or need, and from time to time making suggestions to you about products or services that may be of interest to you if you have not opted out of receiving that type of marketing
You can ask us to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of any other transactions.
We ask for your express opt-in consent before we share your personal data with any other company for marketing purposes.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We may not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
WHO WE SHARE YOUR PERSONAL DATA WITH
We disclose personal information to facilitate the running of our business or to provide specific services you have requested. Commonly, we will disclose information to:
Service providers – We engage service providers who help to support our business and improve our products. These service providers include, for example, fulfilment providers for delivery of our digital content and marketing; customer service agencies; organisations that host our Sites or databases; and providers of online surveys. We have contracts in place with these data processors and they can only use your personal information under our instruction.
Corporate customers – If your subscription is provided by your employer we may provide your employer with information about your level of activity within our product. We may also provide prospective corporate clients with high level information about the use of our product by the employees of other corporate customers, however we will ensure that this information is always Aggregated Data which does not directly or indirectly reveal your identity.
Nikkei group – We may share your information within the Nikkei group to provide our services and to better understand the relationship between our products.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We ensure your personal data is protected by requiring all our employees follow the same rules when
processing your personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know.
We require all third parties acting as our service providers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We will notify you and any applicable regulator of any breach where we are legally required to do so.
We operate a global business, so your personal data may be processed and stored outside the European Economic Area (EEA). We put in place safeguards, such as EU standard contractual clauses, to protect information that is transferred in this way.
HOW LONG WE USE YOUR PERSONAL DATA FOR
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any service delivery, legal, accounting, or reporting requirements. By law we have to keep basic information about our customers (including identity, financial and operational data) for six years after they cease being customers for tax purposes. In some cases we will anonymise all personal data gathered about you (so that it can no longer directly or indirectly reveal your identity, and will continue to use this anonymised form of your data for research or statistical purposes indefinitely without further notice to you.
Under data protection laws, you have rights as an individual in relation to the personal data we hold about you. These rights include:
- The right to object to direct marketing – your preferences, including in relation to direct marketing, can be found in your account;
- The right to access the personal data that we process about you;
- The right to request the deletion of your personal data;
- The right to request the rectification of your personal data – you can manage some of this information using the product features we provide.
You can exercise these rights by contacting our Customer Service team at email@example.com
You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office(ICO).