Privacy Notice

This is the internet privacy notice for

(the “Websites”)

This is the privacy notice of Inclusive Learning Ltd, trading as Skill Boosters. In this document, “we”, “our”, or “us” refer to Inclusive Learning Ltd and our websites at www.skillboosters.com and www.skillboostersvideo.com (the “Websites”).

We are company number 07307261 registered in the UK. Our registered office is at The Gables, Currant Hill, South Bank, Westerham, Kent, TN16 1EN.

We welcome any queries, comments or requests you may have regarding your privacy and this policy. Please do not hesitate to contact us at accounts@inclusivelearning.co.uk.

Introduction

1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave the Websites immediately.
3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to the Websites are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through the websites.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1. Information we process because we have a contractual obligation with you

When you create an account on the Websites, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

• verify your identity for security purposes
• sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most from using the Websites

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

2. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse the Websites or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to opt in to a newsletter.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on the Websites.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us. However, if you do so, you may not be able to use the Websites or our services further.

3. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• record-keeping for the proper and necessary administration of our business.
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage business risk
• protecting your interests where we believe we have a duty to do so

4. Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us

5. Information provided on the understanding that it will be shared with a third party

The Websites allow you to post information with a view to that information being read, copied, downloaded, or used by other people.

Examples include:

5.1.     posting a message our forum

5.2.     tagging an image

5.3.     clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted.

6. Complaints regarding content on the Websites

The Websites are a publishing medium. Anyone may register and then publish information about himself, herself or some other person.

We do not moderate or control what is posted.

If you complain about any of the content on the Websites, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

7. Information relating to your method of payment

Payment information is never taken by us or transferred to us either through the Websites or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of PayPal or some other reputable payment service provider. That page may be branded to look like a page on the Websites, but it is not controlled by us.

8. Sending a message to our support team

When you contact us, whether by telephone, through the Websites or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

9. Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

10. Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

Use of information we collect through automated systems when you visit the Websites

11. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

The Websites use cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

We use cookies in the following ways:

• to track how you use the Websites
• to record whether you have seen specific messages we display on the Websites
• to keep you signed in our site
• to record your answers to surveys and questionnaires on our site while you complete them

For more information on cookies you can read the guidance at All About Cookies.

12. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on the Websites are recorded.

We record reported information such as your geographical location and your IP address. We also record reported information about the software you are using to browse the Websites, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on the Websites and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to the Websites.

Disclosure and sharing of your information

13. Storing your personal data

We may transfer data that we collect from you to locations outside of the European Economic area for processing and storing. In addition, it may be processed by staff operating outside the European Economic area who works for us or for one of our suppliers. For example, such staff may be engaged in the processing and concluding of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps to make sure that your data is treated securely and in agreement with this privacy policy.

We use safeguards with respect to data transferred outside the EU. Staff that are employed by us abide by the same binding rules that are in place across our organisation. We use contracts with our suppliers that include terms that safeguard your information.

Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into via our site are encrypted to ensure safety.

The transmission of information via the Internet is not always completely secure, and therefore we cannot guarantee the security of all data sent to us electronically. Transmission of such data is entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential.

14. Disclosing your information

Where applicable, we may disclose your personal information to any member of our group. This includes, where applicable, our subsidiaries, our holding company and its other subsidiaries.

We may also disclose your personal information to third parties:

• Where we sell any or all of our business and/or our assets to a third party.
• Where we are legally required to disclose your information.
• To assist fraud protection and minimise credit risk.

15. Third party links

You might find links to third party websites on the Websites. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Access to your own information

16. Access to your personal information

• At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on the websites.
• Please note that any onerous demand for access may be subject to payment.

17. Removal of your information

If you wish us to remove personally identifiable information from the Websites, you may contact us.

This may limit the service we can provide to you.

18. Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

19. Use of site by children

We do not sell products or provide services for purchase by children, nor do we market to children.

20. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

21. How you can complain

• If you are not happy with our privacy policy or if you have any complaint then you should tell us.
• If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
• If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

22. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities;
• to support a claim or defence in court.

23. Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use the Websites.

24. Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on the Websites on the day you use the Websites. We advise you to print a copy for your records.