- Who we are
- Companies and websites within scope
- Collection of personal data
- Lawful basis for the processing of personal data (6. Storage of personal data
- Security measures
- Your rights as a data subject
- Contact us
We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data. We will also explain what rights you have with regards to your personal data and how you can exercise those rights.
2.Who we are
Skoolkam is the parent company for Skoolkam Skoolkam is the data controller for all the organisations within its group. This means that Skoolkam determines what data is collected by each organisation within the group, how this data is going to be used and how this data is protected.
Our registered office address is:
- 45 Carra Vale
- Ballymahon Road
- Co. Wetmeath
- N91 HR5P
If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at email@example.com
3.Companies and websites within scope
Skoolkam – https://www.skoolkam.com
Unless specifically stated, we consider the above-mentioned website(s) EU-based website(s); see section 6 below for more information on non-EU data processing. This policy also covers any additional personal data collected in online forms via our websites.
It includes personal data that is collected through our websites, by telephone, through LiveChat and through any related social media applications.
4.Personal data and Non-Personal Data
5.Collection of personal data
We collect personal data from you for one or more of the following purposes:
- To provide you with information that you have requested or that we think may be relevant to a subject in which you have demonstrated an interest.
- To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services.
- To fulfil a contract that we have entered into with you or with the entity that you represent. In these circumstances it may be your entity, rather than yourself, that has provided us with your personal data.
- To ensure the security and safe operation of our websites and underlying business infrastructure.
- To manage any communication between you and us.
The table in section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.
In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:
- Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
Your login information, browser type and version, time zone setting, browser plug-in
types and versions.
Operating system and platform.
- Information about your visit, including the URL (Uniform Resource Locators) clickstream to, through, and from our site.
In section 8 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.
6.Lawful basis for the processing of personal data
The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business architecture, accounting and systems infrastructure and compliance organisation means that all personal data is processed on common, groupwide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so.
A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties; where this happens, this is also identified below.
When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:
- The purpose test – is there a legitimate interest behind the processing?
- Necessity test – is the processing necessary for that purpose?
- Balancing test – is the legitimate interest overridden, or not, by the individual’s
- interests, rights or freedoms?
|Purpose of collection||Information Category||Data Collected||Purpose for Collection||Lawful Basis for Processing||Data Shared With ?||Retention Period|
|1. To provide you with information||Subject Matter Information||Name, company name, geographic location, email address, business sector.||To provide appropriate online or email information about products and services that you have requested||Contractual fulfilment||Internally Only||Maximum eight years from the date the information is collected. Six months if a marketing email is left unopened|
|Telephone number.||Follow-up to ensure requested information meets needs and identify further requirements.||Legitimate interest||Internally Only|
|2. Transactional Information||Transaction Details||Name, physical address, email address, telephone number, bank account details (for credit accounts), other medium of content delivery.||To process purchase transactions for products and services with customers, and to ensure any transaction issues can be dealt with. For accounting and taxation purposes Documentation should any contractual legal claim arise||Contractual performance||Internally only||Maximum eight years from the date of the performance of the contract. Six months from the date the data subject has input personal information but has not proceeded with a transaction. Eight years for VAT records from the performance of the contract|
|Payment Card Data||Primary account number (PAN), cardholder name, service code, expiration date||To fulfil purchase requests using payment cards||Contractual performance||Payment card companies, all in line with the PCI DSS||Only retained while authorisation is pending.|
|3. Fulfillment Information||Fulfilment data||Name, dietary requirements||Appropriate catering arrangements for training courses.||Contractual performance||Internally and training venues||Maximum six years from the date of the performance of the contract.|
|Name, contact and identification details.||Access to training courses, attendance registers.||Contractual performance||Internally and training venues|
|Name, contact and identification details.||Exam attendance, exam results and certifications.||Contractual performance||Internally and external examiners, proctors and certification bodies|
|Name, contact details.||Licensing details necessary for allocation and maintenance of a licence purchased for use of software and related products, distance and elearning||Contractual performance||Internally and any third parties whose products or services you may have purchased from us.|
|Name, address(es), email address, contact details.||Actual delivery of products or services, in physical or digital form, that you may have purchased from us.||Contractual performance||Internally and any third party logistics or supplier companies with whom we contract in order to fulfil these requirements|
|4. Security||Security information||Technical information, as described above, plus any other information that may be required for this purpose.||To protect our websites and infrastructure from cyber attack or other threats and to report and deal with any illegal acts.||Legitimate interest||Internally, forensic and other organisations with which we might contract for this purpose.||Relevant statutes of limitation|
|5. Communications||Contact information||Names, contact details, identification details.||To communicate with you about any issue that you raise with us or which follows from an interaction between us.||Legitimate interest||Internally and, as necessary, with professional advisers.||Relevant statutes of limitation.|
|6. Product Development||Survey Data||Names, contact details, identification details.||To develop existing and new products that meet the expectations and requirement of our customers.||Consent||Internally and where additional consent is given for marketing purposes.||If anonymised for statistical research, this data may be kept indefinitely. Where not anonymised, it shall be retained for a maximum of one year.|
7.Storage of personal data
Skoolkam is a EU based organisation whose primary offices are in situated in Co. Westmeath, Ireland.
All of our website(s) and web applications are hosted in the EU and the infrastructure are accessed only by our EU-based staff.
All of our website(s), as identified in section 2 above, are targeted at non-EU customers and are accessed by staff located outside the EU. In all these instances, we have appropriate contractual and security measures in place to ensure that personal data is protected.
Our customer relationship management, marketing and accounting systems for all our businesses are either EU-based or hosted by companies participating in the EU-US Privacy Shield Framework (https://www.privacyshield.gov/welcome).
We use a wide range of CSPs (Cloud service providers) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
Unless we specifically state otherwise, all the CSPs that we use utilise EU-located processing facilities.
Our payment processors and banking arrangements are based in the EU and, for our US/International website(s), in the US.
8. Security measures
Our ISMS (information security management system) is compliant with ISO/IEC 27001. Our EU business is also Cyber Essentials Plus certified and all our payment card processing is in compliance with the PCI DSS (Payment Card Industry Data Security Standard). We have what we believe are appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our ISMS.
We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
9. Your rights as a data subject
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email firstname.lastname@example.org or use the information supplied in the Contact us section below. To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:
The right to be informed
The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
- a) The purposes of the processing
- b) The categories of personal data concerned
- c) The recipients to whom the personal data has been disclosed
- d) The retention period or envisioned retention period for that personal data
- e) When personal data has been collected from a third party, the source of the personal data
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
The right to restrict processing You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
- a) The accuracy of the personal data is contested.
- b) Processing of the personal data is unlawful.
- c) We no longer need the personal data for processing but the personal data is required for part of a legal process.
- d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
The right to data portability
You have the right to object to our processing of your data where
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research; or #Processing involves automated decision-making and profiling.
10. Contact us
- Data Protection Officer
- 45 Carra Vale
- Ballymahon Road
- N91 HR5P
Should you wish to discuss a complaint, please feel free to contact us using the details provided above.
All complaints will be treated in a confidential manner.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union.
For Ireland, this is the Data Protection Commission, Ireland
Its contact information can be found at here. https://www.dataprotection.ie