Privacy Policy – GDPR

PRIVACY POLICY – GDPR

ARC Learning Ltd is a controller of your personal data. We respect your data and your privacy is important to us.

This Privacy Policy explains what personal data we collect and how it is used. This notice also explains what rights you have over your personal data and how you can use those rights.
You have the right to object to some of the processing which ARC carries out. More information about your rights and how to exercise these is set out in the “Your rights” section of this notice.

ARC Learning Ltd’s registered office is Unit 7, Union Mills Industrial Estate, Union Mills, Isle of Man, IM4 4AB.

1. Summary of how we use your data and your rights
2. Information we collect from you
3. Information we receive from third parties
4. How we use information and the legal basis
5. Data sharing
6. Cookies and similar technologies
7. Data retention
8. Your rights
9. Contact details
10. Which ARC entity is the controller?

1. Summary of how we use your data and your rights

We use your data to provide and improve our products and services, including for marketing, research, feedback and enquiries, and for safety and security purposes.

We will use your data to comply with laws and regulations. We may use your data to prevent and detect crime, such as fraud.

You have the right to object to some of the processing ARC carries out. More information about your rights and how to exercise these is set out in the “Your rights” section of this notice.

When you give consent, you are able to withdraw that consent at any time, for instance by emailing info@arclearning.im. You can also email info@arclearning.im to exercise any other data rights, such as obtaining a copy of your data, correcting, deleting or restricting how we use your data. Please see “Your rights” for more information.

2. Information we collect from you

We collect information when you purchase something or use our services. This includes registering for courses and services, using our website, or corresponding with us.

In particular:

• We keep information you give us directly such as contact details (including name, email, address and telephone number), comments, feedback, marketing opinions and competition entries.
• We record and analyse details of your purchases and where you take advantage of our promotions.
• If there is an incident, we may need to log information about it.
• If you post information online about us or provide feedback, we may keep a record.
• If you contact us directly and complain or give feedback, or enter a competition, we will record details and all related information such as emails, letters and phone calls.

3. Information we receive from third parties

We may receive your information from other people. This can happen when:

• Someone buys you a product or service. They give your name and email address, so we can send you the product.
• You participate in market research, such as focus groups or surveys.

4. How we use information and the legal basis

We are allowed to use your data only if we have a proper reason to do so such as:

• To fulfil a contract we have with you;
• When it is in our legitimate interest;
• When you consent to it; or
• To comply with the law.

A legitimate interest is when we have a business or commercial reason to use your data. This involves us making an assessment of when we can rely on our legitimate interests.

We have set out below how and why we may use your personal information and the legal basis we rely on. This is also where we tell you what our legitimate interests are.

When you buy something from us, or enter a competition we run, we use your information to fulfil our contract with you.

We take information to communicate with you, check your identity, take payment, and provide products and services.

To run our business and pursue our legitimate interests, we use your information.

Our legitimate interests include keeping our records up to date, fulfilling our legal, compliance and contractual duties, working out which of our products and services may interest you, improving our site and services, developing new products and services, and telling you about them and conducting market research.

Further details of our legitimate interests:

To run and promote our business, we use your information:

• To provide and improve our products and services, and to respond to you if you contact us.
• When we monitor ARC websites, social media platforms such as Facebook, Linked In, Twitter and responses to email marketing. If you post comments online or in other media we may capture this information, contact you, and use it to improve our products and services.
• To run competitions and promotions and track which offers seem of interest to you.
• To understand you better as a customer by analysing your transactions and other information you provide to us or which we learn through your interactions with us.
• To send you emails including offers tailored to your perceived preferences where your preference settings permit this.
• To contact you where you provide us with market research feedback.

To comply with law, assess and uphold legal or contractual rights and claims, and for monitoring, auditing and training on compliance matters:

• We may verify your identity.
• We keep records to comply with health and safety legislation, including accounting for the number of individuals on our premises and logging accidents.

We may, if you give us consent

• Send you electronic marketing, including promotions and offers, in relation to our products, courses and services
• Use cookies or similar technologies on the website, app and in marketing emails, including analytic cookies.
• Use data for other purposes where we explain that purpose when we ask for your consent.

When you give consent, you are able to withdraw that consent at any time by contacting us, for instance by emailing info@arclearning.im. If you do so we can only continue to use your data if another legal basis applies, such as when we’re required to do something by law.

Nevertheless, you have an absolute right to opt-out of direct marketing, including profiling for direct marketing purposes, at any time.

When the law requires us to process your data we will do so. This can include:

• Legal, compliance, regulatory and investigative purposes, including for government agencies and law enforcement.
• When you exercise your rights under data protection legislation, including when you ask to subscribe or unsubscribe from our marketing communications.

5. Data sharing

ARC Learning Ltd will not share your data with a third party, unless for safety and security, including CCTV, and other services.

For some activities ARC uses third party service providers, for instance Sure and Manx Telecom who provide Wifi in our office. We use third party providers for the following services:

• Wifi (Sure, Manx Telecom)
• Sending promotional offers
• Customer feedback surveys
• Insurance
• IT development, support, maintenance and hosting, including the provision of applications and website hosting

If our business is to be integrated with another business or sold, your details would be shared with our advisers and any prospective purchaser’s advisers. Your information will be passed to the new owners and you would be notified.

Personal data may be shared with government authorities and/or law enforcement officials for the prevention or detection of crime, if required by law or if required for a legal or contractual claim.

6. Cookies and similar technologies

Our website, apps and marketing emails may use cookies and similar technology in the future. Full information is will be made available in our Cookie Notice when it is created in the future. This will include information on how to adjust your browser settings to accept or reject cookies.

7. Data retention

We keep your data to enable us to fulfil our contract with you or to provide services, whilst you are an active user of our site, office and learning centres, where required by law or to protect legal rights.

We always look to keep your data for the minimum time in line with data protection principles and our processes. For example, we keep:

• Information on all customers and learners
• Records of payment information in line with tax law and audit requirements.
• Customer feedback and correspondence for up to 7 years afterwards, depending on the nature of the interaction and any applicable law, such as health and safety. This enables us to respond to any questions or complaints.
• Information to maintain records according to rules that apply to us.

If you unsubscribe from marketing communications we keep a record of this request indefinitely to ensure we do not send you direct marketing again.

We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons.

8. Your rights

You have rights over your personal data.

You can:

• ask for a copy of your information;
• ask for information to be corrected;
• ask for information to be erased or deleted;
• ask for us to limit or restrict processing;
• object to us processing your data, in particular where we use the data for direct marketing, including profiling for direct marketing purposes. The right to object does not apply if we must process the data to meet a contractual or legal requirement;
• ask us to send you a copy in a structured digital format or ask for us to send it to another party.

Some rights, however, may be limited. We may be obliged by law or regulation to keep information. We must respect other people’s privacy as well, which means we may need to redact or remove information where it includes personal data about someone else, even if it is connected to your data. On occasion there may be a compelling legitimate interest to keep processing data.

If you want a copy of your data, to object to how we use your data, or ask us to delete it or restrict how we use it or, please see ‘Contact details’ below. To process a request from you, we may need to confirm your identity to ensure we’re accessing the right data.

You have a right to complain to an EU data protection authority. This can be where you live, work or where the matter occurred. In the UK, the authority is the Information Commissioner’s Office (the “ICO”).

9. Contact details

To exercise any of your rights or to withdraw consent you can email: info@arclearning.im.

For any queries relating to data protection please contact info@arclearning.im or by writing to them at ARC Learning Ltd. Unit 7 Union Mills industrial Estate, Union Mills, IOM, IM4 4AB.

If we make any changes or updates to this notice we will communicate these.

10. Which ARC entity is the controller?

The controller for your information is ARC Learning Ltd, Unit 7 Union Mills industrial Estate, Union Mills, IOM, IM4 4AB.