Effective starting: 1st March 2021.
1. Who We Are
Caledonia Competence Limited: Caledonia Competence Limited (“Caledonia Competence”) provide Competence and Learning & People Development Consultancy specialist services in the area of personnel assessment and development to individuals and organizations worldwide. “Caledonia Competence”, located in the United Kingdom (Westpoint House, Arnhall Business Park, Westhill, Aberdeenshire, AB32 6FJ) also promote and provide eLearning services. Caledonia Competence complies with Data Protection Laws, including the European regulation for data protection 2016/679/EU (General Data Protection Regulation – GDPR). Caledonia Competence will not knowingly do anything or permit anything to be done which might lead to a breach of the Data Protection Laws.
Attain: Attain is a cloud subscription-based eLearning service for businesses to support the competence and training of their personnel. By accessing Attain, our clients (“Customers”) can access e-learning and competence assessment modules. Customers access the Attain service by means of a unique combination of a user identifier and secure password.
2. Collection: The Personally Identifiable Information We Collect
Visitors and Users: In the course of using this App, you may provide us with personally identifiable information. This refers to information about you that can be used to contact or identify you, and information on the user’s use of and activities at our App that may be connected with you (“Personal Information”). Personal Information that we collect may include, but is not limited to, the user’s name and email address. When you visit the App, our servers automatically record information that the user’s browser sends whenever you visit a web App. This information may include, but is not limited to, the user’s Internet Protocol address, browser type, the web page you were visiting before you came to our App and information you search for on our App. Like many web Apps, we may also use “cookies” to collect information. A cookie is a small data file stored by the user’s browser at the user’s Device’s hard disk for record-keeping purposes. We use “session ID cookies” in order to support login and main service functionality. We may also store cookies of third-party providers. In particular, Google stores a Google Analytics cookie in order to be able to differentiate between users and be able to show us how many times people visit the web App on average (not individually) and information on what pages they’ve seen, how long the duration was, and so on; we do not identify who the visitor was, or what is his Attain account (if any). Caledonia Competence does not collect, store or process data from third-party cookies. You can instruct the user’s browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the web Apps you visit. If you do not accept cookies, however, you may not be able to use all portions of the App or all functionality of our services. In some cases another User (such as an administrator) may create an account on the user’s behalf and may provide the user’s information, including Personal Information (most commonly when the user’s company requests that you use our service). We collect Information under the direction of our Customers and often have no direct relationship with the individuals whose personal data we process. If you are an employee of one of our Customers and would no longer like us to process the user’s information, please contact the user’s employer and us at the contact information below.
Customers: In addition to the data we collect for all Users, we also collect data that are required for the user’s contract with us, such as the user’s company affiliation, invoicing data and also service usage data that prove that the service is used in accordance to the user’s subscription terms, We may also acquire additional data through our Customers’ support requests to the extent this is required for us to resolve a technical issue or respond to a request or complaint. We also email to our Customers newsletters, announcements regarding Attain and our products, or marketing material. If you are a Customer and no longer wish to receive such emails you can remove the user from the recipients list at any time by selecting the “unsubscribe” link provided within the e-mail footer. If you are providing information (including Personal Information) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Information.
Content: We collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our “App”. Such Content includes any Personal Information or other sensitive information that you choose to include (“incidentally-collected Personal Information”). Although Caledonia Competence owns the Attain service, Customers retain ownership, control and all rights to their records and data which are their property.
Other submissions: We collect other data that you submit to our “App” or as you participate in any interactive features of Attain, request Customer support, or otherwise communicate with us.
3. How We Use, Process and Retain Personal Information
Personal Information is or may be used for the following purposes:
- to provide and improve our App, services, features and content,
- to administer the user’s use of our App,
- to enable you to enjoy and easily navigate the App,
- to better understand the user’s needs and interests,
- to fulfil requests you may make,
- to personalize the user’s experience,
- to provide or offer software updates and product announcements, and
- to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, including newsletters, marketing or promotional.
We collect and process personal data in a transparent manner, to the extent necessary for specified, explicit and legitimate purposes, and do not process it further in a manner incompatible with those purposes. We take care that the data we collect are accurate and, when necessary, updated. We take all reasonable steps to immediately delete or rectify personal data, if inaccurate. We process data in a way that guarantees their security, including their protection against unauthorized or unlawful processing and accidental loss, destruction or degradation, using appropriate technical or organizational measures. We are ready to prove at any moment how we adhere to the above principles. We take the appropriate technical and organizational measures for the security, confidentiality, integrity and availability of the data. We expressly declare that these measures ensure that, by definition, personal data are not made accessible without the intervention of the natural person to an indeterminate number of natural persons.
Each Customer’s set of data are retained for as long as the Customer’s subscription to the service lasts. Upon contract expiration the data will be deleted or returned to the Customer if the Customer instructs us to.
4. Information Sharing and Disclosure
Users: We will display Personal Information in the user’s profile page and elsewhere on the App according to the preferences you set in the user’s account. Any information you choose to provide should reflect how much you want other Attain Users to know about you. We recommend that you guard the user’s anonymity and sensitive information, and we encourage you to think carefully about what information you disclose in the user’s profile pages. Users can review and revise the user’s profile information at any time. Users should be aware that the administrator, as well as specially designated support personnel in order to provide support for technical issues users may face, may be able to: access information in and about the user’s account; access communications history, including file attachments, for the user’s account; disclose, restrict, or access information that users have provided or that is made available to users when using the user’s account, including the user’s Content; and control how the user’s account may be accessed or deleted.
Third Parties: We do not sell the user’s Personal Information or Content and will not share or disclose any of the user’s Personal Information or Content with third parties except as described in this policy. We do not share Personal Information about users with third parties for their marketing purposes (including direct marketing purposes). Service Providers, Business Partners and Others: For security, service operation and management purposes, Attain also uses third-party services that provide the same level of protection as Caledonia Competence. Epignosis LLC supply the hardware, software, networking and storage to run the Attain App and as such have access to the user’s Personal Information only for purposes of performing these tasks on our behalf.
Compliance with Laws and Law Enforcement: Caledonia Competence cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about users to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal, to protect the property and rights of Caledonia Competence, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
Children: Our services are not directed to children. We do not knowingly collect Personal Information from children. If we become aware that a child has provided us with Personal Information, we will take steps to delete such information. If users become aware that a child has provided us with Personal Information, please contact us at the contact information below.
Business Transfers: We may share or transfer the user’s Information (including Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Users will be notified on any change in ownership or uses of Personal Information, as well as any choices users may have regarding the user’s Personal Information.
5. The user’s Rights
Caledonia Competence respects the user’s rights as a data subject. When Caledonia Competence processes personal data on behalf of and as instructed by its Customers, our Customers are responsible towards the data subjects and users should contact the respective Customer to which the content of the user’s service belongs for exercising the user’s rights. In this case, Caledonia Competence does not respond directly to the user’s requests for the exercise of the user’s rights that come to our knowledge, but we inform the Customer without delay and provide all reasonable and reasonable assistance to satisfy the user’s requests in accordance with instructions of the Customer. The service has all the necessary features to enable our Customers to exercise the rights of the data subjects on their behalf. For example, the service provides the ability to obtain and manage consent, and to implement strict and secure password policies as well as to exercise the right to be forgotten.
A synopsis of the user’s rights as a data subject is provided below.
Transparency, information and answers to requests: Caledonia Competence adheres to the principle of transparency in processing. For any question regarding this policy users may contact us at privacy at firstname.lastname@example.org. We will respond without delay and in any case within one month upon receipt of the request.
Access: Users have the right to receive from Caledonia Competence confirmation on whether the user’s personal data are processed and in case this happens all required information thereof (processing means, goal, records etc.).
Rectification: Users have the right to require the rectification of inaccurate data relating to users without undue delay, as well as to fill in incomplete data if necessary for processing. If users have an account on our App users can update the user’s account data through the user’s profile by selecting “My information” from the options menu at the top of the screen.
Erasure: Users have the right to ask for the erasure of personal data concerning users without undue delay. Caledonia Competence by means of its designated personnel will erase the data where one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes of processing; or b) the person requesting the erasure withdraws consent on which the processing is based and there is no other legal ground for the processing; or c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing or the data subject objects to processing for direct marketing; or d) the personal data have to be erased for compliance with a legal obligation. Caledonia Competence will not proceed to the erasure of the personal data if the data must be maintained for compliance with a legal obligation or in cases where the processing is required for the establishment, exercise or defence of legal claims. If users receive marketing emails, users can remove themself from the recipients list by selecting the “unsubscribe” link within the e-mail.
Restriction of processing: Users have the right to request restriction of processing if the accuracy of personal data is disputed, for that period of time that allows Caledonia Competence to verify the accuracy of personal data or based on any other legitimate reason specified in applicable Data Protection Laws.
Data Portability: Users have the right to receive the user’s personal data in a structured, commonly used and machine-readable format as well as the right to request the direct transmission of personal data by Caledonia Competence to another, if this is technically feasible.
Right to Object: Users may oppose the processing of personal data which takes place without the user’s consent. In this case, Caledonia Competence no longer submits the personal data unless it demonstrates imperative and legitimate reasons for the processing that outweigh the interests, rights and freedoms of users as a data subject or for the foundation, exercise or support of legal claims. If users receive promotional emails, users can remove themself from the recipients list by selecting the “unsubscribe” link within the e-mail content. Users may also oppose processing at any time by contacting us at the email provided at the end of this Policy.
Complaint to Supervisory Authority: Users have the right to lodge a complaint with a supervisory authority, in particular in the Member State of the user’s habitual residence, place of work or place of the alleged infringement if users consider that the processing of the user’s personal data infringes Data Privacy Laws.
Caledonia Competence is very concerned with safeguarding the user’s information. We employ reasonable measures designed to protect the user’s information from unauthorized access.
7. Data Ownership
Customers retain ownership, control and all rights to their records and data which are their property.
8. Cooperation With Supervisory Authority
Caledonia Competence commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the ICO in the UK and comply with the advice given with regard to data transferred from the EU and the UK.
9. Contacting Us