TRILOGY EDUCATION SERVICES UK LIMITED
Last Updated: 23 May 2019
Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is Trilogy Education Services UK Limited whose registered address is 3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT. Our data protection officer may be contacted at firstname.lastname@example.org.
Changes to this Policy: We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will post a notice on our Site prior to such changes(s) taking effect.
Purposes of Processing
What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation 2016/679; and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Site. If you created a profile/registered with us, you will have been asked to tick to agree to provide this information in order to view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Site.
Collecting Your Personal Data
We collect information about you in the following ways:
Information You Give Us. This includes when you:
- create an account (name, email, login and password details, registrations and applications, postal address and telephone number);
- register or apply for a course, either directly or by using your social networking credentials on the Site or a third-party website;
- pay for a course;
- participate in our surveys, promotions and competitions;
- sign up for a newsletter;
- post information to the Site that includes Personal Data; and
- communicate with us, for example to submit queries regarding the Site.
Using the Site. If you post Personal Information in a comment or to a chat room, blog or other public area of the Site, we may collect the information you post. Posted information is also available for viewing and disclosure by other users of the Site, and we have no control over such use. We discourage posting sensitive or Personal Information in comments as they are viewable by the public.
Information We Get from Others. We may also get information about you from other sources, for example, where a third party facilitates your purchase of a course. We may add this to information we get from our Site.
Using Your Personal Data
We may use your personal data as follows:
- to provide you with information about the subject(s) you are interested in and our services and facilities to help you make an informed decision as to whether to apply to study at the University of Birmingham Coding Boot Camp;
- to operate, maintain, and improve our Site, products, and services;
- to manage your account, including to communicate with you regarding your account, if you have an account on our Site;
- to respond to your comments and questions and to provide customer service;
- to send information including technical notices, updates, security alerts, and support and administrative messages;
- with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time by clicking on “unsubscribe” at the bottom of the emails you receive from us. Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
- to process payments you make via our Site;
- to link or combine user information with other personal data;
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
- as described in the “Sharing of your Personal Data” section below.
Sharing Your Personal Data
We may share your personal data as follows:
- University of Birmingham. The University of Birmingham will collect, store, use, share and process your personal data obtained as part of your application and other personal data obtained from you or other sources as explained as part of Online Registration and the student privacy notice: https://www.birmingham.ac.uk/privacy/index.aspx. Your personal data is shared with only those University of Birmingham staff who need access for the processing purposes set out above. If you disclosed to us that you have a disability, our Student Support team will contact you to let you know how you can access the University of Birmingham Learning Support, Disability and Mental Health services. You will be provided with further details about how your personal data will be used for this purpose at the relevant time.
- Displaying to Other Users. If you post content to the Site, it will be displayed on the Site. Other users of the Site may be able to view and use information you post, such as information contained in comments posted in a chat room or on a blog post. We do not have responsibility or liability for information you post. You should exercise caution when using public forums and not disclose your personal data.
- Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
- Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
- Third Party Advertisers. We may share personal data with advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
- We may share some or all of your personal data with our affiliates, including universities, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
- Corporate Restructuring. If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information which we have collected may be used, sold or transferred to third parties such as venture capital or private equity groups, investment banks, or successor companies as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.
- Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
When we use the term “anonymous data”, we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyse usage patterns in order to make improvements to our Site.
Third Party Sites
Our Site may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
International Data Transfer
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We seek to use reasonable organisational, technical and administrative measures to protect personal data within our organisation. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Information section below.
Data required to verify participation and performance in our programs will be retained indefinitely so that we may provide you with records of your completion of, and/or performance in, our programs upon your request. We will retain all other personal data we hold on you for three (3) years after the end of all programs in which you participate so that we may send you emails regarding other product offerings, including programs, unless a longer retention period is required or permitted by law (for example for regulatory purposes). In the event that you have opted out of receiving such emails, we will retain your personal data for three (3) years after the end of all programs in which you participate, to ensure that we record and respect your preferences and opt-out choices..
Our Policy on Children
Our Site is not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Information section below. We will delete such information from our files as soon as reasonably practicable.
Sensitive Personal Data
We ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site.
- Object. You may object to the processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Withdraw consent. You may withdraw your consent to process your personal data. This right only exists where we are relying on consent to process your Personal Data. If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
- You may access the information we hold about you at any time by contacting us directly.
- You can also contact us to update or correct any inaccuracies in your personal data.
- Your data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us using the details in the Contact Information section below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: email@example.com. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
We welcome your comments or questions about this Policy. You may contact us in writing at firstname.lastname@example.org or 3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT.