OpenLMS, as a brand of the group companies within the Learning Technologies Group (“we” or “us”), is committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, through this website (“our site”) or as otherwise agreed between you and us, or indicated to you by 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.
We are responsible for operation of the site at https://www.openlms.net/(“our site”). Our contact information is: OpenLMS, an LTG Group Company Brand, and our main office address is 15 Fetter Lane, London EC4A 1BW, UK, Tel. +44(0)2074021554.
The main data controller within the Learning Technologies Group (https://ltgplc.com/), which we are a part of, and which shall have access to any of your personal data processed by us, is LEO Learning Limited (company number 02371375), whose registered office address is: 52 Old Steine, Brighton, East Sussex, BN1 1NH, United Kingdom, +44 1273 728 686.
Information we may collect from you
We may collect and process the following data about you:
- Information that you provide. This may be by filling in forms on our site, providing us with your business card or contact details, providing us with your information in registering for our services or to use our client support tools, and/or or by corresponding with us by phone, email or otherwise. This includes information provided at the time of registering to use our site, subscribing to our trial or paid services, posting material or requesting further information and/or services. We may also ask you for information if you report a problem with our site. The information that you provide to us may include name, email address, company and position, address and telephone number and other such information as may be communicated to, or provided by you, as well as the details contained in your query;
For additional details of transactions carried out through our site or other types of information collected by us you may contact us at email@example.com.
Our site may use session and persistent cookies. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on your computer. We may use web beacons alone or in conjunction with cookies to compile information about your usage of our site and interaction with emails from us. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our site, in order to improve our site and email communications.
Our site may contain links to other websites including share and/or “like” buttons. These other websites, services and applications may set their own cookies on users’ computers, collect data or solicit personal information. You should refer to their privacy policies to understand how your information may be collected and/or used by them.
We use preference cookies to collect information about your choices and preferences, and to allow us to remember language or other local settings and customize our site accordingly.
We also use analytics cookies to collect information about your use of our site, and to enable us to improve the way our site works. For example, analytics cookies show us which are the most frequently visited pages on our site, help us record any difficulties you have with our site, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on our site, rather than the usage of a single person. We use the information to analyse the site traffic, but we do not examine this information for individually identifying information.
We use Remarketing with Google Analytics to advertise online. Third party vendors, including Google, may show our ads on sites across the internet.
We, and third party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to our website. Remarketing cookies used by us expire after 30 days. To opt out of Remarketing or to control your ad preferences, please click here.
Most web browsers have a “help” menu where you can review how to prevent your browser from accepting new cookies, how to have your browser alert you when you receive a new cookie or how to fully disable cookies on your browser. You can learn more about cookies at sites like www.aboutcookies.org. If you use your browser settings to block all cookies, you may not be able to access all or parts of our site.
Here are the cookies we use on our site:
|Provider||Name||Type||Expiration||Purpose||Description||Third Party opt-out|
|.freegeoip.net||__cfduid||Persistent||1 year||Preferences||Used to identify visitors’ location in order to serve regional-specific content||Functional cookies – no opt-out|
|WeePie plugins||Wpca_consent, other possible cookies named here||Persistent||1 year||Preferences||These cookies are required to show the cookie notification bar, remember your cookie acceptance choice and apply this choice.||Functional cookies – no opt-out|
|Google Analytics||_ga, _gat, _gid, AMP_TOKEN, _gac_, 1P_JAR, CONSENT, NID, other possible cookies named here||Session and Persistent||End of Session – 20 years||Analytical||Used for the purpose of analytical tracking of behaviour on the website. Not use to collect, store or process personal data.||Google opt-out|
|HotJar||All possible cookies named here||Session and Persistent||End of Session – 1 year||Analytical||Used for the purpose of analytical tracking of behaviour on the website. Not use to collect, store or process personal data||HotJar opt-out|
|StatCounter||__cfduid, .statcounter.com, other possible cookies named here||Persistent||1 year – 5 years||Analytical||Used for the purpose of analytical tracking of behaviour on the website. Not use to collect, store or process personal data||StatCounter opt-out|
|Bcookie, bscookie, BizoData, BizoID, BizoUserMatchHistory, other possible cookies named here||Session and Persistent||End of Session – 3 years||Analytical & Marketing||Used for the purpose of integrating social media features on the website and for tailored advertising.|
|Guest_id, Personalization_id, other possible cookies named here||Session and Persistent||End of Session – 2 years||Analytical & Marketing||Used for the purpose of integrating social media features on the website and for tailored advertising.|
|Pardot||dtCookie, lpv271292, pardot, Visitor_id271292, other possible cookies named here||Session and Persistent||End of Session – 10 years||Analytical & Marketing||Used for the purpose of marketing automation including forms, landing pages, analytics tracking, social media integration and tailored advertising.|
|DoubleClick||IDE, test_cookie, other cookies named here||Session and Persistent||End of Session – 1 year||Marketing||Tailored advertising||Google opt-out|
|Drift||driftt_sid, driftt_aid, DFTT_END_USER_PREV_
||Session and Persistent||End of Session – 2 years||Marketing||Used to enable the Drift chatbot.|
|Mixpanel||mixpanel_distinct_id||Persistent||1 year||Trial – Analytical||Used for the purpose of analytical tracking of behavior on the Open LMS trial site. Not use to collect, store or process personal data.|
|Moodle||MoodleSession, local_plugins_moodle_version||Session||End of session||Trial, essential||User to handle user session in Open LMS trial||Trial opt-out|
Where we store your personal data and how long for
Our site is hosted on servers located in the UK, and support is being provided for our site by our group staff based in the UK and the US. Any personal information that we collect from you is input directly into our Salesforce database, which is hosted and supported in the UK, and our Pardot database, which is hosted and supported in the US. For users based in the EEA, this means that the data that we collect from you will be transferred to, and stored outside the EEA. It may also be processed by staff operating outside the EEA who work for us. We have signed EU Model Clauses with our relevant group entities and with Pardot, which means that such transfers would be lawful transfers of personal data outside the EEA, in accordance with applicable legislation.
Unfortunately, the transmission of information via the internet is almost never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data that is transmitted to our site or otherwise gathered by us; any transmission and supply of personal data to us is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access to it.
We will keep a copy of any personal data obtained from you through our site, or otherwise, for as long as we believe is reasonably required, or such longer period as may be required for legal, audit and compliance purposes. This does not affect your right to opt out from receiving marketing communications, as outlined above and in the section “Your rights” below.
Uses made of the information
We use information held about you in the following ways:
- To provide you with information via post, email or telephone, about our products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
- To carry out our obligations arising from any contracts entered into between you and us or to enable us to provide our services and to deal with any query you have raised;
- To notify you about changes to our services;
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure.
This will include your details being included and processed in our Salesforce and Pardot databases.
Disclosure of your information
Our general policy is not to disclose any personal data to a third party outside of the Learning Technologies Group except with your prior consent. However, we may disclose your personal information to third parties:
- If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of business and other agreements; or to protect our rights, property, or safety, or that of our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Legal basis of our processing of your personal data
We process your personal data on the basis of your consent (in relation to sending you marketing information following your submitted request through our site), (alternatively or additionally) for our legitimate interests of promoting, growing and developing our business and, where you are a customer, in order to perform our obligations under the contract between us.
You have the right to ask us not to process your personal data for marketing purposes. You may also choose not to receive publications or certain other communications from us by explicitly indicating so in the appropriate section of the Registration Form or by opting-out by phone, email or via direct marketing emails sent to you. Please note that under applicable legislation you may be entitled to access any information we hold on you, you may request the rectification of inaccurate data concerning you, you may object to the processing of your personal data, and request that your details are deleted from our Salesforce and Pardot databases at any point of time, however you should be aware that if your details are deleted by us, this will mean we will have no further records of you and that you therefore may receive unsolicited communications in the future.
You can exercise your right to prevent such processing by (un)checking certain boxes on the forms we use to collect your data. You can also exercise any rights you may have at any time by contacting us at firstname.lastname@example.org or by unsubscribing per the method outlined in any emails sent, or during any phone calls with you.
Our site may, from time to time, contain links to and from the websites of our group companies, partner networks, clients, and/or affiliates. If you follow a link to any of these websites, please note that these websites are subject to their own privacy policies and we do not accept any responsibility or liability for these sites and policies. Please check these policies before you submit any personal data to these websites.
Where you are based in the EU you have the right to contact your local data protection authority and you can request details of how to do this by contacting us at email@example.com.
Under California Civil Code sections 1798.83 – 1798.84, California residents who have an established business relationship with us are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for those third parties’ direct marketing purposes and to opt-out of sharing your personal information with third parties for direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties with which it was shared, along with their names and addresses. If you choose to opt-out or would like a copy of this notice, please submit a written request to us at the address stated below. Please allow 30 business days for a response. Any queries concerning your rights or the exercising of them and any complaints concerning the processing of your personal data should be sent to firstname.lastname@example.org.
Access to information
Under Applicable Legislation, where we are the controller of any personal data we hold on you, you also have the right to verify whether we hold your personal data and (have) access your personal data. Any data access request directed at us may be subject to a reasonable fee to meet our costs in dealing with your request.
This policy may be updated by us from time to time, so please check this policy periodically to ensure you are aware of our latest policies.