ClickLearn Docs

Privacy Policy

Version 2 - April 2022

Previous Versions
Version 1 - April 2022

This document has been superseded by Privacy Policy as of April 2022

The purposes of the processing

We collect data through ClickLearn Universe for the purposes of administrating accounts, providing access to exclusive learning content, maintaining course enrollment reports, tracking progress, achievements, and certifications.

The overall objective is to help us understand how the users interacts with the platform and engage with different types of learning content. This data is used to develop the ClickLearn services by improving design, functionality, and learning content quality.

The lawful basis for the processing

As we are located in the EU, the General Data Protection Regulation (GDPR) applies to the collection of personal data irrespective of where the data subject is located.

The basis for our collection and processing are:

Article 6 (1a) of the General Data Protection Regulation (consent)

The categories of personal data collected

The personal data we collect fall under Article 6 of the GDPR.

a) Account information

We collect personal data in relation to the profile such as first name, surname, city, description, profile picture, username, company, possibly an affiliated ClickLearn Community account, log in information, and e-mail.

We also collect personal data the user continually produces when using ClickLearn Universe such as data related to specific courses chosen, course progress and completion, assignment submissions, awarded certifications, points, ranks, and badges.

b) Developing and testing

We collect technical data from the devices being used such as browser, IP address, network location and time zone. We also collect data on the usage of the content as well as information on how the service is being used such as site experiences, when users enter and leave the site and what site features are being used.

c) Security

We use the IP-addresses to detect threats, both proactively and retroactively.

d) Data subject requests

Finally, we also process relevant personal data in connection with possible data subject requests in accordance with Chapter III in the GDPR. This might entail processing personal data to identify and/or authenticate the data subject making the request.

The recipients or categories of recipients of the personal data

Recipients of personal data might include but are not in all cases limited to IT service providers (data processors), public authorities (to the extent we are obligated) and support staff in subsidiaries.

The details of transfers of the personal data to any third countries or international organizations

We transfer personal data to third countries outside EU/EEA that the EU Commission has determined has an adequate level of data protection. In cases of transfer to third countries that do not have an adequate level of data protection we use the EU approved standard contractual clauses to ensure an adequate level of data protection. By request we will provide you with a copy.

The retention periods for the personal data

A user can at all times delete the account. A user can also request deletion by contacting us at DataProtection@clicklearn.com. However, a deletion is requested or initiated, a deletion and anonymization process is activated.

The process includes assessing if we are obligated to store some or all the personal data for a longer period of time according to the GDPR and the applicable local, state, or federal laws. If we are not obligated to store the personal data and we have no other lawful grounds for further processing, we delete or anonymize the personal data. If the user is inactive for 24 months, the deletion and anonymization process is activated.

The source of the personal data

Personal data have been obtained directly from the data subject during the onboarding/sign up process in the system and from the continued use of ClickLearn Universe.

The details of whether individuals are under a statutory or contractual obligation to provide the personal data

If you do not wish to provide us with the personal data, we need to fulfil the purposes, we are not able to provide you with the full services or functions of the system.

The details of the existence of automated decision-making, including profiling

We do not base any automated decision-making, including profiling, referred to in Article 22(1) and (4) of the General Data Protection Regulation on personal data from users. Thus, no decision is based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects concerning the user.

The rights available to individuals in respect of the processing

As we are bound by the GDPR due to our location you have the following rights:

Your right of withdrawal of consent – You can always delete your account.
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the information you gave us to another organization, or to you, in certain circumstances.
Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.

The rights are limited in scope and application. Moreover, the rights are applied on a case-by-case basis to each data subject request.

You are not required to pay any charge for exercising your rights.

If you make a request, we must provide information on actions taken without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, considering the complexity and number of the requests. In that case, we will inform of any such extension within one month of receipt of the request, together with the reasons for the delay.

Please contact us if you wish to make a request. When you make the request, please specify your request as best you can. This will help us process your request more quickly.

The right to lodge a complaint with a supervisory authority

You can lodge a complaint with your local Supervisory Authority in the EU by going to the website of the European Data Protection Board and find the contact information.

If you live outside the EU, please contact the Danish Data Protection Agency:

Danish Data Protection Agency
Carl Jacobsens Vej 35
2500 Valby
Denmark

Tel. +45 33 1932 00
email: dt@datatilsynet.dk
Website: http://www.datatilsynet.dk/

The name and contact details of the organization (data controller)

Changes

We may change the privacy notice from time to time including if we change the purpose of the processing. If we do, we will inform you in the service or via e-mail. The applicable privacy notice will always be available in the service.