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PRIVACY AND COOKIES POLICY

This Privacy and Cookies Policy is dated 20 March 2022

About Us

We are Circus Street London Limited, a company registered in England with
registered number 6958392 whose registered office is at 3rd Floor, 1 St
Katharine’s Way, London, E1W 1UN (and we refer to ourselves
as "we", "us" or "our" in this document). We are committed to ensuring that your
privacy is protected. This Privacy Notice describes how we use the personal
information that we collect from you, or that you provide, when you:

 * visit any of our websites, portals or online learning environments (the
   "Website");
 * use the educational services, testing, certification, products, and
   consultancy services (together the "Services") that we provide; or
 * communicate with us.

 

About this Privacy and Cookies Policy

In this Privacy and Cookies Policy, references to "you" means any person
submitting any data to us or to this Website about themself or about any other
living individual in respect of any use of the Website or the products available
through the Website (each being a "Product").

When you use different aspects of the Website, we may ask you to supply us with
various information about you or anyone whom you represent. This Privacy and
Cookies Policy sets out the way in which we may use such information.

We are committed to protecting and respecting your privacy. This Privacy and
Cookies Policy (together with our " Circus Street London Limited eLearning Terms
& Conditions" and any other documents referred to in it) 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 purpose of the
Data Protection Act 1998 (the Act), the data controller is Circus Street London
Limited.

If you do not agree with our policies and practices, your choice is not to use
our Website. By accessing or using this Website, you agree to this Privacy and
Cookies Policy. This policy may change from time to time (see Changes to this
Privacy and Cookies Policy). Your continued use of this Website after we make
changes is deemed to be acceptance of those changes, so please check the policy
periodically for updates.

 

Information we collect

We collect personal information from you:

 * through the use of forms, which may be on paper or on our Websites, such as
   when you login to access our Services, signup to receive our newsletters,
   register for information or commence a course of study;
 * when you communicate with us for any reason, including by email, postal mail
   or telephone, and when you use our Services.

 

Information that we collect automatically

When you visit our Websites, we may collect certain information automatically
from your device. The information we collect automatically may include
information like your IP address, device type, unique device identification
numbers, browser-type, broad geographic location (e.g. country or city-level
location) and other technical information. We may also collect information about
how your device has interacted with our Website, including the pages accessed
and links clicked.

Collecting this information enables us to better understand the visitors who
come to our Website, where they come from, and what content on our Website is of
interest to them. We use this information for our internal analytics purposes
and to improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking
technology, as explained further under the heading 'Cookies', below.

 

Information we obtain from third party sources

We may receive personal information about you from third party sources (such as
your employer or other third party if they enrol you on a course or create an
account on your behalf) but only where we believe that these third parties
either have your consent or are otherwise legally permitted or required to
disclose your personal information to us. We collect only the minimum amount of
information required from these third parties to enable us to provide the
requested service. We only use the information we receive from these third
parties as set out in this Privacy and Cookies Policy.

 

Use of your information

Our legal basis for collecting and using your information to reach out to you is
in our legitimate interests and does not overwrite your data protection
interests or fundamental rights and freedoms. Our legitimate interests in this
case is to offer you content we believe is in line with the theme of your
website and you would want to publish, this is why we need to process your data.
For this purpose we will hold your data for 12 months after engagement.

The information that we collect and store relating to you is primarily used to
enable us to provide our Services to you. In addition, we may use the
information for the following purposes:

 * To provide you with information or Services you request from us;
 * To provide information on other Circus Street products and Services which we
   feel may be of interest to you, in accordance with your communications and
   consent preferences;
 * To meet our contractual commitments to you;
 * To act on your behalf where third party involvement is available and
   appropriate – for example through a third party specialist training provider
   or certification/awarding body;
   * To respond to you over any queries you raise with us.
   * To enable you to have a password resent to you if you tell us or the
     Website that you have forgotten it.
   * To record and track details of transactions you carry out through or via
     the Website and of the fulfilment of your orders.
   * To monitor and analyse trends, usage and activities in connection with our
     Websites/Services; and
   * As necessary to prevent or detect crime.

We may also monitor or record telephone calls for training, customer service and
quality assurance purposes, and to detect or prevent crime. These recordings
will be retained for a maximum of 30 days.

In general, we will use any of the information we collect from you only for the
purposes described in this Privacy and Cookies Policy or for purposes that we
explain to you at the time we collect such information. 

 

Storing and Retaining your personal data

The personal information you provided to us is stored within secure servers. We
use appropriate technical and organisational measures to protect the personal
information that we collect and process about you. The measures we use are
designed to provide a level of security appropriate to the risk of processing
your personal information.

Where we have given you (or where you have chosen) a password so that you can
access certain parts of our sites and portals, you are responsible for keeping
these passwords confidential.

Please note that the transmission of information via the internet (including
email) is not completely secure and therefore, although we endeavour to protect
the personal information you provide to us, we cannot guarantee the security of
data sent to us electronically and the transmission of such data is therefore
entirely at your own risk. We retain personal information we collect from you
where we have an ongoing legitimate business need to do so (for example, to
provide you with a service you have requested or to comply with applicable
legal, tax or accounting requirements).

When we have no ongoing legitimate business or statutory need to process your
personal information, we will either delete or anonymise it.

 

Disclosing your information

We will disclose, where required, your personal information with:

 * Third party service providers and partners who provide data processing
   services to us (for example, to support the delivery of Services), or who
   otherwise process personal information for purposes that are described in
   this Privacy Notice;
 * Your employer, where they have instructed us or funded the goods or services
   provided to you. This may include progression, assessment, attainment or exam
   results as well as other personal data as and when required;
 * Any product evaluation or feedback comments you provide may be shared with
   the purchasing organisation or course vendor;
 * Any third party in connection with, or during negotiations of, any merger,
   sales of company assets, financing or acquisition of all or a portion of our
   business by another company;
 * Any law enforcement agency, court, regulator, government authority or other
   third party where we believe this is necessary to comply with a legal or
   regulatory obligation (and may not be able to inform you so as not to
   compromise any investigation or other proceedings), or otherwise to protect
   our rights or the rights of any third party; and to
 * Any other person with your consent to the disclosure.

 

Third party links

You might find links to third party websites on our Websites or within
documentation we provide.

If you access other websites using the links provided, the operators of these
sites may collect information from you which will be used by them in accordance
with their own Privacy Notices which you should review.

We do not accept any responsibility or liability for their policies whatsoever
as we have no control over them.

 

Social Networking

The Website may offer you the opportunity to share or follow information about
us (or the Website or our Services) using third party social networking
functionality (such as through "share this", "like" or "follow" buttons).

We offer this functionality in order to generate interest in us, the Website and
our Services among the members of your social networks, and to permit you to
share and follow opinions, news and recommendations about us with your friends.
However, you should be aware that sharing personal or non-personal information
with a social network may result in that information being collected by the
social network provider or result in that information being made
publicly-available, including through Internet search engines.

Please note that we do not exercise, endorse, secure or control the policies or
practices of any third party social network whose functionality you may access
through the Website.

You should always carefully read the Privacy Notice of any social network
through which you share information in order to understand their specific
privacy and information usage practices.

 

International data transfers

For some of our Services, your personal information may be transferred to, and
processed in, countries outside of the EEA. However, we have taken appropriate
safeguards to require that your personal information will remain protected in
accordance with this Privacy and Cookies Policy. These measures include
transferring your personal data to third parties who are located in a country
which the European Commission has determined has data protection laws that are
at least as protective as those in Europe and transferring your personal data to
third parties who have entered into standard contractual clauses with us. For
more information about these safeguards please contact us using the contact
details provided below.

 

Lawful basis (EEA visitors only)

Our lawful bases for collecting and using personal information will depend on
the personal information being collected and the specific context in which we
collect it.

However, we will normally collect personal information from you only:

 * where we need the personal information to perform a contract with you (for
   example, to enrol you into a course or provide you with learning materials);
 * where the processing is undertaken on the grounds of legitimate interest and
   is not overridden by your rights; or
 * where we have your consent to do so.

In some cases, we may also have a legal obligation to collect personal
information from you.

If we collect and use your personal information in reliance on our legitimate
interests (or those of any third party), this interest will normally be to
operate our platform and communicating with you as necessary to provide our
services to you and for our legitimate commercial interest, for instance, when
responding to your queries, improving our platform, undertaking marketing, or
for the purposes of detecting or preventing illegal activities. We may have
other legitimate interests and if appropriate we will make clear to you at the
relevant time what those legitimate interests are.

If you have questions about or need further information concerning the lawful
bases on which we collect and use your personal information, please contact us
using the contact details provided below. 

 

Data protection rights

You have the following data protection rights:

 * If you wish to access, correct, update or request deletion of your personal
   information, you can do so at any time by contacting us using the contact
   details provided below.
 * In addition, you can object to processing of your personal information, ask
   us to restrict processing of your personal information or request portability
   of your personal information. Again, you can exercise these rights by
   contacting us using the contact details provided below.
 * You have the right to opt-out of marketing and telemarketing communications
   we send you at any time. You can exercise this right by clicking on the
   "Manage your Marketing Preferences" link in the marketing e-mails we send
   you.
 * Similarly, if we have collected and process your personal information with
   your consent, then you can withdraw your consent at any time. Withdrawing
   your consent will not affect the lawfulness of any processing we conducted
   prior to your withdrawal, nor will it affect processing of your personal
   information conducted in reliance on lawful processing grounds other than
   consent.
 * You have the right to complain to a data protection authority about our
   collection and use of your personal information. For more information, please
   contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their
data protection rights in accordance with applicable data protection laws.

 

Cookies

What are cookies?

Cookies are small data files that are placed on your computer or mobile device
when you visit a website. Cookies are widely used by website owners in order to
make their websites work, or to work more efficiently, as well as to provide
reporting information.

Cookies set by us are called "first party cookies". Cookies set by parties other
than us are called "third party cookies". Third party cookies enable third party
features or functionality to be provided on or through the Website (e.g. like
advertising, interactive content and analytics). The parties that set these
third party cookies can recognise your computer both when it visits the website
in question and also when it visits certain other websites.

 

Why do we use cookies?

We use cookies to provide easier navigation around the sites and gather
anonymous analytics information. In some cases, cookies are used to provide
functionality within sessions, such as within portals or learning environments.
Some cookies are required for technical reasons in order for our Websites to
operate, and we refer to these as "essential" or "strictly necessary" cookies.
Other cookies also enable us to track and target the interests of our users to
enhance the experience on our Websites. For example, we may use Google Analytics
(a third party cookie) within our Websites to monitor how visitors have landed
on our Website, and how they consequently navigate it. This is done so that we
can see aggregated (not individual) statistics about which content our users
access most frequently.

We categorise cookies as follows:

 * Necessary cookies help make a website usable by enabling basic functions like
   page navigation and access to secure areas of the website. The website cannot
   function properly without these cookies.
 * Preference cookies enable a website to remember information that changes the
   way the website behaves or looks, like your preferred language or the region
   that you are in.
 * Statistic cookies help website owners to understand how visitors interact
   with websites by collecting and reporting information anonymously.
 * Marketing cookies are used by publishers and third party advertisers to track
   visitors across websites based on your browser and device, to build a profile
   of your interests and provide adverts that are more relevant and engaging.
   Disabling these cookies will not prevent or reduce advertising, just make it
   less relevant.
 * Unclassified cookies are cookies that we are in the process of classifying,
   together with the providers of individual cookies.

From time to time we may have links to other services such as social media or
video services on our Website. These third party services may set cookies on
your device when you use them. Due to the nature of how cookies work, we cannot
access these cookies nor control their use. Likewise, these third party services
cannot access our session or analytics cookies.

 

How can you control cookies?

The law states that we can store cookies on your device if they are strictly
necessary for the operation of this site. For all other types of cookies we need
your permission. You have the right, therefore, to choose whether or not to
accept non-essential cookies and to set your own cookie preferences on your
device.

Circus Street has implemented a cookie management tool on its websites that
allows you to select which of the optional cookie classifications can be set. By
choosing not to set some of these cookies certain features of the Website cannot
be provided and you may not be able to enjoy the Website to its fullest. When
cookie retention settings expire, you will be presented with the cookie
management interface to refresh your selection.

Where you wish to review the settings of the cookies on subsequent visits, you
can clear the cookies from your browser and the management tool will reappear to
allow you to review and select appropriate cookies. All web browsers are
different and to learn how to change your cookie preferences, check the "Help"
menu of your browser.

For more information about cookies, cookie management and how to control cookies
within your browser, please see the allaboutcookies.org website.

Unless the user's browser has been configured so that it will refuse cookies,
our Websites notify the user that the site makes use of cookies and allows the
user to customise their browser to configure their preferences.

 

Updates to this Privacy and Cookies Policy

We may update this Privacy and Cookies Policy from time to time to reflect, for
example, changes to the cookies we use or for other operational, legal or
regulatory reasons. Please therefore re-visit this Cookie Notice regularly to
stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Notice indicates when it was last updated.

 

Contacting Us

If you have any questions about our use of cookies, please do not hesitate to
contact us, via email at privacy@circusstreet.com.

 

 * Contact Us
 * System Requirements
 * Terms & Conditions
 * Privacy Policy
 * Modern Slavery Statement

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