1. CognAssist is a trading arm of e-Quality Learning Limited. E-Quality Learning Limited (We) are committed to protecting and respecting your privacy.
2. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purposes of the Data Protection Act and the GDPR, sensitive information includes what is defined as your ‘personal data’.
4. If you are a registered user of e-Quality Learning then we will process your personal data on the lawful basis of the performance of a contract between us and you.
5. For the purpose of the Data Protection Act 2018 (the ‘DPA’) and in-line with the European Union General Data Protection Regulations (the ‘GDPR’), the data controller is e-Quality Learning Limited. We are a company registered in England and Wales with registration number 07401627 and our registered office is at 9 Apollo Court, Koppers Way, Monkton Business Park South, Hebburn, Tyne & Wear, England, NE31 2ES.
6. For the purposes of the GDPR, our Data Protection Officer is Sean Dotchin (Company Secretary).
8. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
8.1. information that you provide by filling in forms on our Website, speaking with our representatives or writing to us. This includes information provided at the time of registering to use our site, subscribing to our service, providing feedback, signing forms, compliments and complaints, undertaking training sessions, posting material or requesting further services. We may also ask you for information when you enter a competition or promotion sponsored by us, and when you report a problem with our site;
8.2. if you contact us, we may keep a record of that correspondence;
8.3. if we contact you, we may keep a record of that correspondence;
8.4. we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
8.5. details of transactions you carry out through our site and of the fulfilment of your orders;
8.6. details of your visits to our site including, but not limited to, traffic data, location data, content viewed, content interacted with, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access; and
8.7. details of services received from us including dates and times of training sessions, persons involved, topics discussed communicated or trained upon, opinions thoughts and actions of our representatives.
9. TECHNICAL INFORMATION
9.1. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
10.3. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
10.4. The cookies we use are “analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
11. We may use Google Analytics or similar, to understand general trends and traffic sources; for example, where users come from, which pages are most popular, which sites provide most traffic and how our marketing efforts impact the amount of visits we receive. You can find out more about Googles statement of privacy by reading their policy in full here.
12. We also use social media buttons to allow you to easily interact with us and follow our content on social media. We have integration for Facebook, Twitter, LinkedIn and YouTube and you can find out more information about how they handle your personal data by clicking the hyperlinks in their name.
13. By using our Website you consent to receive the cookies referred to above.
14. WHERE WE STORE YOUR PERSONAL DATA
14.2. All of the data processors that we work with that are based outside of the EU either conform to the EU-US Privacy Shield Framework or have entered into Data Processing Agreements with us.
14.3. All of the data processors that we work with within the EU have confirmed their GDPR compliance.
14.4. All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology and all remote internet enabled training will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential.
14.5. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
15. USES MADE OF YOUR INFORMATION
We use information held about you in the following ways:
15.1. to ensure that content from our site is presented in the most effective manner for you and for your computer;
15.2. to remind you of training session appointments by electronic means (email and SMS);
15.3. to improve our service and communications, including through feedback requests that may be used for our marketing purposes;
15.4. to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
15.5. to carry out our obligations arising from any contracts entered into between you and us;
15.6. with your disability assessor, trainer or other such support worker and disability assessment organisation, training provider, education institution or other such organisation;
15.7. to improve your experience of disability support within educational institutions and DSA-QAG and any registered ATSPs or NMH’s approved on the DSA-QAG website;
15.8. to provide software and hardware insurance companies providing goods and services as part of your interaction with us;
15.9. to engage with our contractors or other trusted organisations who will be providing services as part of your interaction with us;
15.10. to provide stakeholders in your support with the opportunity to improve their service to you, information will be provided to the DSA-QAG registered Access Centre you were assessed by, your educational institution, and or your employer this may include but is not exclusive of dates and times of sessions, missed sessions, topics covered, names and comments of trainers working with you, feedback you provide to us, contact details, difficulties you experience, disability related difficulties and study skills related advice;
15.11. to allow you to participate in interactive features of our service, when you choose to do so; and
15.12. to notify you about changes to our service.
15.13. We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by email or telephone.
15.14. If you are an existing User (as defined in our Terms and Conditions), we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.
15.15. If you are a new User, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
15.16. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please write to us at firstname.lastname@example.org.
15.17. To transfer/share of personal information or documentation relating to your NMH support (Non-Medical Help Support), to the Disabled Students Allowance Quality Assurance Group so that they can audit the organisations internal processes for dealing with the delivery of NMH support services.
15.18. To transfer/share of personal information or documentation relating to you to our associated companies Invate Limited and Learning Labs (UK) Limited.
16. DISCLOSURE OF YOUR INFORMATION
16.1. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
16.2. We may disclose your personal information to third parties:
16.2.1. to deliver our services to you and for any of the permitted reason outlined in clause 14 above;
16.2.2. in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
16.2.3. if substantially all of the assets of either e-Quality Learning Limited or any parent company of e-Quality Learning Limited are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
16.2.4. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions of Supply and other agreements; or to protect the rights, property, or safety of e-Quality Learning Limited or any parent company of e-Quality Learning Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
16.3. We may disclose your personal information to the Disabled Students Allowance Quality Assurance Group, if chosen as a student sample, so that the auditor can audit the organisations internal processes for dealing with the delivery of NMH support services. These audits play an important part of ensuring that the organisation is complying with all relevant legislation, internal and external guidance. Such compliance is vital to the organisation so it can properly provide NMH support services as recommended in your needs assessment report.
16.4. The information that the organisation is proposing to share with the auditor is a copy of documentation such as your timesheet, invoice to the funding body relating to the delivery of your NMH support. The personal data provided to the auditor would only be processed for the specific purpose of carrying out the audit of the organisation. The data or NMH support information would not be retained by the auditor once the audit of the organisation had been completed and accredited by DSA-QAG.
17. YOUR RIGHTS
17.1. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
17.2. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at e-Quality Learning Limited, 9 Apollo Court, Koppers Way, Monkton Business Park South, Hebburn, South Tyneside, NE31 2ES.
17.3. The GDPR grants you the right to be forgotten and to have all personal data held by you deleted within a reasonable timeframe. If you’d like to exercise this rights then please contact us at email@example.com. We will aim to respond to all requests within 20 working days. Please note than in having your personal data deleted you will no longer be able to access any of the services that we provide without first re-registering as a new User again.
17.4. Our site may, from time to time, contain links to and from the websites of other organisations. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
18. ACCESS TO INFORMATION AND RECTIFICATION
18.1. The GDPR gives you the right to access information held about you, within a reasonable timeframe and in a readable electronic format. It also gives you the right to rectify and incorrect data that we hold too. Any request can be made by emailing us at firstname.lastname@example.org and we will aim to respond within 20 working days.
21. JURISDICTION AND APPLICABLE LAW
21.1. The English courts will have exclusive jurisdiction over any claim arising from, or related to, a visit to our site although we retain the right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country.