LearnWorlds (“Us”, “We”, or “Our”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.learnworlds.com (“Our Site”) and the LearnWorlds platform (“Our Platform”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site and/or Platform;|
|“Cookie”||means a small text file placed on your computer or device by Our Site or Platform when you visit certain parts of Our Site or Platform and/or when you use certain features of Our Site or Platform. Details of the Cookies used by Our Site and Platform are set out in Part 14, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
Information About Us
Our Site and Our Platform are owned and operated by LearnWorlds (CY) Ltd, a limited company registered in Cyprus under company number HE380294.
Registered address: Gladstonos 120, Foloune Building, 2nd Floor, B1, Limassol, 3032, Cyprus.
VAT number: CY10380294R
Registered with Information Commissioner’s Office with Reference Number: ZA372094.
Email address: email@example.com
Telephone number: +357 22000504
What Does This Policy Cover?
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- b)The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- c)The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- d)The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
- e)The right to restrict (i.e. prevent) the processing of your personal data.
- f)The right to object to us using your personal data for a particular purpose or purposes.
- g)The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- h)Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Data Do We Collect?
Depending upon your use of Our Site and Platform, we may collect some or all of the
- Email address;
- Telephone number;
- Business name;
- Payment information;
- Information about your preferences and interests;
- IP address;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your Account on Our Platform;
- Providing and managing your access to Our Site and Platform;
- Personalising and tailoring your experience on Our Site and Platform;
- Supplying Our Platform for your usage and services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring Our Platform and services for you.
- Communicating with you. This may include responding to emails, support tickets or calls from you.
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by submitting a ticket to our Help Center (https://support.learnworlds.com) or sending an email to firstname.lastname@example.org).
- Analysing your use of Our Site and Platform and gathering feedback to enable us to continually improve Our Site and Platform your overall user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message with information, news, and offers on Our Platform and Services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose digital tools we use on Our Site and Platform may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- For as long as you keep a paid or trial account with Our Platform.
- For as long as you remain subscribed (have positively opted-in) in our emailing list and wish to receive news and offers from us.
- If none of the above is, then we will keep your data for maximum period of two years following your initial communication or signup/personal data submission.
How and Where Do You Store or Transfer My Personal Data?
We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards are applied to such transfers:
We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.
Additionally, we use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
Do You Share My Personal Data?
We may sometimes contract with the following third parties to supply certain features of Our Site, Platform and services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
- Chargebee.com (subscription management and invoicing)
- Braintreepayments.com (online credit card payments)
- PayPal.com (online payments)
- FreshDesk (Customer help center and support tickets)
- Agile CRM (CRM, form handling, appointment scheduling and user analytics)
- FirstPromoter (registration and tracking of affiliates)
- Google Analytics (website user analytics)
- MixPanel (website user analytics)
- Segment (website user analytics)
- HotJar (website user analytics)
- Google AdWords (targeting and tracking of ad campaigns)
- Facebook (targeting and tracking of ad campaigns)
- useFOMO (display of user notifications)
- LeadPages (displaying pop-ups and registration forms)
- Wistia (showing user videos and tracking analytics)
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site and Platform, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails, at the point of providing your details, or and by managing your Account).
Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site and Platform you may be required to submit or allow for the collection of certain data.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. Please contact us at email@example.com and request this form.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site and Platform, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for analytics and for marketing purposes. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and Platform and your use and experience of Our Site and Platform will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a banner requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site and Platform may not function fully or as intended.
Certain features of Our Site and Platform depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
(Cookie declaration last updated on 24/05/2018)
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary||Expires|
|PHPSESSID||Preserves users states across page requests||Yes||When you close your browser|
|debug||Helps with the identification and resolution of potential bugs||Yes||When you close your browser|
|learnworlds_session||Preserves User Login information and states||Yes||When you close your browser|
|XSRF-TOKEN||Preserves User Login information and states||Yes||When you close your browser|
|wfvt_#||Remembers the user’s submitted data when a comment is submitted in a blog post. The purpose is to auto-populate form fields for subsequent comments, in order to save time for the user.||Yes||When you close your browser|
|__tld__||Cookie used by the Jetpack plugin of WordPress||Yes||When you close your browser|
and the following third-party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose||Expires|
|wordfence_verifiedHuman||Learnworlds.com||Used by WordFence to verify that interactions are coming from real human users and not bots||When you close your browser|
|analytics/v1/observations/capture||api.leadpages.io||Used by site’s popups and download forms.||When you close your browser|
|centerVisitorId||js.center.io||Used by site’s popups and download forms.||Persistent|
|JSESSIONID||learnworlds.agilecrm.com||Preserves users states across page requests||When you close your browser|
|5q129tl640cemcatr8a01qfje1-agile-crm-guid||learnworlds.com||Used by Agile CRM to preserve user sessions across pages||5 years|
|5q129tl640cemcatr8a01qfje1-agile-crm-session_id||learnworlds.com||Used by Agile CRM to preserve user sessions across pages||When you close your browser|
|5q129tl640cemcatr8a01qfje1-agile-crm-session_start_time||learnworlds.com||Used by Agile CRM to preserve user sessions across pages||When you close your browser|
|5q129tl640cemcatr8a01qfje1-agile-original-referrer||learnworlds.com||Used by Agile CRM to preserve user sessions across pages||5 years|
|__cfduid||usefomo.com||Used by the content network, Cloudflare, to identify trusted web traffic.||1 year|
|Fomo.hstry-count-since-first-event-10271||learnworlds.com||Used by Fomo for showing user notifications||Persistent|
|Fomo.hstry-first-timestamp-10271||learnworlds.com||Used by Fomo for showing user notifications||Persistent|
|Fomo.snv-10271-53613523||learnworlds.com||Used by Fomo for showing user notifications||Persistent|
|ci_session||refersion.com||Preserves users states across page requests||When you close your browser|
|AWSELB||learnworlds.refersion.com||Used to distribute traffic to the website on several servers in order to optimise response times||When you close your browser|
|wistia-http2-push-disabled||wistia.com||Used for showing the Wistia video player||When you close your browser|
|loglevel||learnworlds.com||Used for showing the Wistia video player||Persistent|
|muxData||learnworlds.com||Used for showing the Wistia video player||20 years|
|statsQueue||learnworlds.com||Used for showing the Wistia video player||Persistent|
|wistia||learnworlds.com||Used for showing the Wistia video player||Persistent|
|__distillery||learnworlds.com||Used for showing the Wistia video player||1 Year|
|@@History/@@scroll|#||learnworlds.com||Used for preserving page scroll position||Persistent|
Our Site and Platform uses analytics services provided by Google, Mixpanel, Segment, and HotJar. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site and Platform is used. This, in turn, enables us to improve Our Site and Platform and the products and services offered through them.
The analytics services used by Our Site and Platform uses the following Cookies:
|Name of Cookie||Purpose||Strictly Necessary||Expires|
|_ga (2x)||Google Analytics: Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||No||2 years|
|_gat (2x)||Google Analytics: Used by Google Analytics to throttle the request rate||No||When you close your browser|
|_gid (2x)||Google Analytics: Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||No||When you close your browser|
|collect||Google Analytics: Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels.||No||When you close your browser|
|ajs%3Acookies||Segment: Cookie used by Segment for analytics purposes||No||1 year|
|ajs%3Atest||Segment: Cookie used by Segment for analytics purposes||No||1 year|
|ajs_anonymous_id||Segment: Cookie used by Segment for analytics purposes||No||1 year|
|ajs_group_id||Segment: Cookie used by Segment for analytics purposes||No||1 year|
|ajs_group_properties||Segment: Cookie used by Segment for analytics purposes||No.||Persistent|
|ajs_user_id||Segment: Cookie used by Segment for analytics purposes||No||1 year|
|ajs_user_traits||Segment: Cookie used by Segment for analytics purposes||No||Persistent|
|mp_#_mixpanel||MixPanel: Cookie used by MixPanel for analytics purposes||No||1 year|
|_hjIncludedInSample||HotJar: Determines if the user’s navigation should be registered in a certain statistical placeholder||No||When you close your browser|
Targeting/Marketing cookies are used to track visitors across websites. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. If you do not allow these cookies, you will experience less targeted advertising.
|Name of Cookie||Purpose||Strictly Necessary||Expires|
|ads/ga-audiences||Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites.||No||When you close your browser|
|fr||Used by Facebook to deliver a series of advertisement products such as real time bidding from third-party advertisers||No||3 months|
|tr||Used by Facebook to deliver a series of advertisement products such as real time bidding from third-party advertisers||No||When you close your browser|
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site and Platform more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Dr Panagiotis Siozos, CEO):
Email address: firstname.lastname@example.org.
Telephone number: +44 11 6464 9900.
Postal Address: LearnWorlds (CY) Ltd, Gladstonos 120, Foloune Building, 2nd Floor, B1, 3032, Limassol, Cyprus.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.