Sungate Enterprises Ltd ('we' or 'us') (trading as OTM Learning) collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data protection Regulations which apply across the European Union (including the United Kingdom) and we are responsible as 'controller' of that personal information for the purposes of those laws.
We collect the following personal information that you provide to us:
Name; Email; Address; Image; IP Address; Hardware & Software Details; Accounts Logged In To;
Some examples of when we collect this information include:
If you give us information about another person, you confirm that the other person has appointed you to act on their behalf and agreed that you:
shall consent on their behalf to the processing of their personal data;
shall receive any data protection notices on their behalf; and
shall consent on their behalf to the transfer of their personal data abroad.
A cookie is a small text file which is placed onto your computer or electronic device when you access our website. Similar technologies include web beacons, action tags, local shared objects ('flash cookies') and single-pixel gifs. Such technologies can be used to track users' actions and activities, and to store information about them. We use these cookies and/or similar technologies on this website.
Visits to websites, traffic data;
This information helps us to build a profile of our users. Some of this information may be aggregated or statistical, which means that we will not be able to identify you individually.
We collect information about our users for the following purposes:
Optimisation of user experience
We may share your information with:
Law enforcement agencies in connection with any investigation to help prevent unlawful activity
We will not share you personal information with any other 3rd parties.
We would like to send you information about products, services, offers, competitions and our business which may be of interest to you. Such information could be sent by post, email, telephone, text message or automated call.
We will ask whether you would like us to send you marketing messages on the first occasion that you provide any relevant contact information (i.e. on purchase, signing up to a newsletter, entering a competition etc). If you do opt in to receive such marketing from us you can opt out at any time (see 'What rights do you have?' below for further information). If you have any queries about how to opt out, or if you are receiving messages you do not want you can contact us using the details provided below.
The provision of the following information is required from you:
Name; Address; Email; Image
This is to enable us to do the following:
Account creation; User Verification
We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
We will hold your personal information for the following periods:
These periods are no longer than necessary in each case.
We rely on the following as the lawful basis on which we collect and use your personal information:
The legitimate interests relied upon are as follows:
(a) the data subject has given consent to the processing of their personal data for one or more specific purposes;
(b) processing is necessary for compliance with a legal obligation to which the controller is subject;
(c) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We will also use technological and organisation measures to keep your information secure. These measures may include the following examples:
User accounts are controlled by unique username and password; all data is stored on secure servers encrypted using SSL
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Indeed, while we will use all reasonable efforts to secure your personal data, in using the site you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using the details below.
We will not transfer your personal information outside of the EEA at any time.
Where we obtain consent from any user we will take reasonable steps to ascertain whether the user is over 13 years of age and whether the child is sufficiently informed to give valid consent. If the user is not, parental consent will be required to provide consent for the processing of any personal information.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individual's rights under the General Data Protection Regulations (http://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)
If you would like to exercise any of these rights please:
From time to time we may also have other methods to unsubscribe (opt-out) from any direct marketing including for example, unsubscribe buttons or web links. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed.
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Notice on website
If you have any questions about this policy or the information we hold about you, please contact us by:
Email: [email protected]
Office 9, 28-30 Fowler Road, Hainault Business Park, Hainault, IG6 3UT