Updated: 22 May 2018
Digital Training Solutions Ltd (”DTS” / “we” / “our”/ “us”) is committed to protecting and respecting your privacy. We are committed to maintaining the trust and confidence of our users. In particular, we want you to know that we are not in the business of selling, renting or trading email lists with other companies and businesses for marketing purposes.
- The information we collect about you
- How we use the information we collect
- Who we give your information to
- Control of your information
- Your access to your information and how long we keep it
- How we protect your information
- Where we store your information
- Links to other websites
- Payment processing
- Information about enforcement and dispute resolution
- Contact us
Data protection laws require companies to describe their role and responsibility when handling personal information.
When you access and interact with our Platform, register for a course, communicate with us, etc. we are the data controller.
When you engage with the Platform because your employer or member organisation has paid for your access to our content, then;
- your employer or member organisation is the data controller with respect to the user information it provides to us. This information typically includes first name, last name, and email address. Where your employer/member organisation is data controller in this way, we act as a data processor under data protection laws, meaning we use the information to provide a service to your employer.
- DTS is the data controller for information provided directly by you or as a result of interacting with the Platform, including assessment data, and demographic information such as your gender, year of birth, and your work sector.
When you register as a user of the Platform via an Individual account, DTS is the data controller for all personal information provided by you and collected by the Platform as you access and use the Platform.
The information we collect about you
We value your trust. In order to honour that trust, DTS adheres to ethical standards in gathering, using, and safeguarding any information you provide.
We collect and process the following personal information from you:
Information you give to us:
This is information about you that you give us directly when you interact with us. You may give it to us by filling out a form on our Site, corresponding with us by phone or email. It includes information necessary to register and pay for a course or place an order for courses and other services we may provide. It also includes information shared when you submit a query, report feedback about or a problem within our Site.
When you create an account for our Platform, we require you provide first name, last name, and email address. When you purchase a course licence online, you are redirected to PayPal where your purchase is fulfilled. We do not keep or store any credit/debit card or PayPal account details.
Additionally, you may provide additional personal information to complete your learner profile within our system. To be clear, none of these additional profile details are required to use our Site, but we can offer you an enhanced experience if you provide it.
Information we collect about you from your use of the Platform:
We will automatically collect information from you each time you visit the Platform. This includes technical information, information about your visit, and information about your activity on the Platform such as courses searched and viewed, page response times, download errors, length of visit to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods to browse to and away from a page, and methods used to contact our sales and support teams. Technical information may also include the Internet protocol address (“IP Address”) used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating systems, and device platform.
Information we receive from other sources:
This is information we receive about you from third parties that we work closely with to provide, promote, and improve our services. Where your access to our content is paid for by your employer or member organisation, we may also receive information (name and email address) about you from them in order to create your learner account.
Third parties include business partners, vendors who assist in technical and payment services (PayPal), advertising networks, analytics providers (Google Analytics), and search information providers.
How we use the information we collect
Information you give to us:
We use your personal information together with other personally non-identifiable information to help us better understand our users, to personalize and improve your experience with our Site, and to improve the content and functionality of the Platform.
This may include providing information about our goods and services that we feel may interest you and enhance your interaction with our Site. We will communicate with you about these goods and services via email or on our Site. These communications may include newsletters, promotional emails, or product updates. We will use your information for this purpose only if you have given your consent to receive marketing material from us at the point we collected your information, where required by law, or otherwise in our legitimate interests, provided these interests do not override your right to object to such communications.
When you register on the HostileWorld platform, you will be asked to provide us with personal and employment information such as name, year of birth, email address, country location, the organisation you work for and other similar information. We will use this information to allow you to use the Platform, including to purchase courses.
You may also choose to enter personal data relating to your race or ethnicity, gender and sexual orientation when using the Platform. This type of information is considered to be a part of the “Special Categories of Personal Data” under Article 9 of the GDPR. By choosing to enter the above categories of personal data, you are giving explicit consent to the processing of this personal data for purposes referenced in this Policy.
If you purchase a course, we will record details related to that course including whether you start and/or complete the course, the scores you achieve in quizzes, your responses to interactive scenarios, certificates you earn, your responses to evaluation and feedback surveys, and other information relating to your learning. We use this information for the management and provision of courses.
If your access to the Platform is paid for by an employer or member organisation, we also share this information with them.
Information we collect about you from your use of the Platform:
We will use this information in our legitimate interests (where we have considered these are not overridden by your rights), to administer the Platform, and for internal operations, including troubleshooting, data analysis, testing, research, and statistical survey purposes. We will also use this information to keep HostileWorld safe and secure, for measuring the effectiveness of how we present content and how we market and advertise.
We use non-personally identifiable information in our log files to analyse trends, to administer the Platform, to track users’ movements in and around the Platform, and to gather demographic information about our user base as a whole.
We also utilise unstructured machine learning technologies to understand user behaviours and to provide user-specific recommendations and other personalisation of our Site experience.
Information we receive from other sources:
We will combine this information with information you give to us and information we collect about you in our legitimate business interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Who we share your information with
We consider your personal information to be a vital part of our relationship with you and do not sell your personal information to third parties. There are, however, certain circumstances in which we may share your personal information with certain third parties, as follows:
Agents, Consultants and Related Third Parties:
We sometimes hire other companies to perform certain business-related functions, such as sending email on our behalf, payment processing, or conducting market research. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These companies are not permitted to use any personal information that we share with them for any other purpose aside from providing services to us.
Business Plans and Company Partnership Subscriptions:
We partner with certain third parties to provide our services to their employees or their community members. As part of such partnerships, a third party may pay for the subscription for its employees or community members or otherwise contract with DTS to make your subscription available to you, and DTS may share information about your use of our services with the third party. If your subscription was provided by your employer or a member organisation, we may share information you provide, or information we may otherwise collect through your registration and use of our services, with such third party. This information may include course viewing history, course viewing time, course or assessment completion, course quality ratings and feedback, certifications, performance-related metrics, and other personal information.
As we develop our business, we might sell or buy businesses or assets. Your personal information may be transferred to a buyer or other successor in the event of a corporate sale, merger, reorganization, dissolution, or similar event in which personal information held by us about our Platform users is among the assets transferred.
In certain situations, DTS may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or similar legal process served on us or HostileWorld.
We will take reasonable steps to ensure that we only collect that personal information that is relevant for the purposes for which it is to be used. Furthermore, we will not process your personal information in a way that is incompatible with these purposes.
Control of your information
When DTS is acting as a data processor, we will only process personal information in accordance with the instructions given by the data controller.
When DTS is acting as a data controller, we will act in accordance with your permission to offer you our services and as otherwise instructed by you. We will also give you the ability to opt out before we use your personal information for purposes that are fundamentally different than the purpose for which it was originally created.
If you would like to discontinue receiving communications from us, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us at firstname.lastname@example.org.
If you have questions or concerns regarding a transactional email, please contact email@example.com.
Your access to your information and how long we keep it
Upon request, DTS will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us firstname.lastname@example.org.
We will provide you with the means to ensure that your personal information is correct and current. If you have registered to use the Platform, you can access and change your profile on our Platform via your account dashboard. If you want to delete your profile along with all personal information associated with that profile, you may request deletion by contacting us and instructing us to do so via: email@example.com.
We will respond to your request within a reasonable timeframe. Requesting deletion of your account means your personal information is permanently deleted and cannot be retrieved. Your learning account will be erased from servers. Access to your learning journey, certificates and past courses will also be deleted.
We retain your information while your account is active or as needed to provide services to you and your employer or member organisation, if your access to our content is paid for by an employer or member organisation. Thereafter, we may retain certain personal information indefinitely as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain aggregate information for research purposes and to help us develop and improve our Site and services.
How we protect your information
The security of your personal information is important to us.
We store your personal information only on servers with limited access that are located in controlled facilities, and use a variety of technologies and procedures intended to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Nonetheless, no communication via the Internet can ever be 100% secure, and no security measures can ever be assured to be effective. Accordingly, you are advised to use caution and discretion when determining what personal information to disclose to us.
If you have any questions about security on our Site, contact us: firstname.lastname@example.org
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 support our legitimate business interests (where we have considered that these are not overridden by your rights). This is statistical data about our users' demographic data, browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies allow us to create a unique device ID, enable you to be remembered when using that computer or device to interact with websites and online services, and can be used to manage a range of features and content, including storing searches and presenting personalized content. They help us to improve our site and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences, and so allow us to customise our site according to your individual interests.
- To speed up your searches.
- To recognise you when you return to our site.
A number of cookies we use last only while you are on our Site and expire when you close your browser or exit the Platform. Others are used to remember you when you return to our Site and will last for longer. We use these cookies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate business interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.
We use the following types of cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of -billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests. We may also share this information with third parties for this purpose.
The effect of disabling cookies depends on which cookies you disable but, in general, our Site may not operate properly if all cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our Site. If you disable all cookies, you may be unable to complete a purchase on our Site.
If you want to disable cookies on HostileWorld, you need to change your website browser settings to reject cookies. How you do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below:
For Microsoft Internet Explorer:
- Choose the menu “tools” then “Internet Options”
- Click on the “privacy” tab
- Select the setting the appropriate setting
For Google Chrome:
- Choose Settings> Advanced
- Under “Privacy and security,” click “Content settings”.
- Click “Cookies”
- Choose Preferences > Privacy
- Click on “Remove all Website Data”
For Mozilla Firefox:
- Choose the menu “tools” then “Options”
- Click on the icon “privacy”
- Find the menu “cookie” and select the relevant options
Links to other websites
HostileWorld may make chat rooms, message boards, news groups, or other public forums available to its users, whether by way of our own services or by way of the services or features of a third party. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these areas and avoid posting any personal or sensitive information. If a separate login is required to use these areas, please be aware that you may need to also log out separately.
Information about enforcement and dispute resolution
We have appointed a Data Protection Officer to oversee all aspects of our privacy and data security policies. If you would like to contact our Data Protection Officer, please send an email to DPO@dtslimited.net.