1.1 We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (" usage data "). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use, and any scores or other inputs and outputs associated with the usage of our products and services. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal bases for this processing are the fulfilment of our contract with you to provide you with access to our products and services, and our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (" account data "). The account data may include your name and email address and any payment information you provide to us. The source of the account data is you or the organisation through which you access our products and services. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal bases for this processing are the fulfilment of our contract with you to provide you with access to our products and services, and our legitimate interests, namely the proper administration of our website and business.
2.4 We may process information that you post for publication on our website or through our services (" publication data "). The publication data includes the structure, metadata, and content of all materials that you provide to us in connection with your use of our products and services. The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal bases for this processing are the fulfilment of our contract with you to provide you with access to our products and services, and our legitimate interests, namely the proper administration of our website and business.
2.5 We may process information contained in any enquiry you submit to us regarding our products and/or services (" enquiry data "). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is the fulfilment of your request to us.
2.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (" transaction data "). The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (" notification data "). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the fulfilment of your request to us.
2.8 We may process information contained in or relating to any communication that you send to us (" correspondence data "). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.9 We proctor tests using webcam - for this we capture images, video and sound through your device when you use our products and services. This is to prevent impersonation and use of unfair means. By using our products and services, you consent to us capturing and processing images, video, and sound from your camera and microphone. The legal basis for this processing is consent.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
3.3 Financial transactions relating to our website and services are handled by our payment services providers, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://stripe.com/.
3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.5 We use Hubspot.com to manage the feedback from our customers. Hubspot.com gathers correspondence data, usage data and account data. You can find information about Hubspot.com privacy policies and practices at https://legal.hubspot.com/privacy-policy .
3.6 We use Amazon Web Services as a storage for the media collected for proctoring purposes. You can find information about Amazon Web Services privacy policies and practices at https://aws.amazon.com/privacy/ .
3.7 We use Google Cloud Platform for data backups. You can find information about Google Cloud Platform privacy policies and practices at https://www.google.com/policies/privacy/ .
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The hosting facilities for our website are situated in Republic of Ireland and United States and provided by Heroku. You can find information about the hosting providers’ privacy policies and practices at https://heroku.com/ . Heroku relies on Salesforce’s Processor Binding Corporate Rules and the European Commission’s standard contractual clauses for transfer of personal data outside of the European Economic Area. By using the website or providing us with your information, you consent to transfer your data to Republic of Ireland and United States.
4.3 Our data backups are situated in United Kingdom and hosted by Google Cloud Platform. You can find information about the hosting providers’ privacy policies and practices at https://www.google.com/policies/privacy/ . By using the website or providing us with your information, you consent to transfer your data to United Kingdom.
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email or through the private messaging system on our website.
7.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
7.2 We may withhold personal information that you request to the extent permitted by law.
7.3 You may instruct us at any time not to process your personal information for marketing purposes.
7.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
7.5 You have the right to request access to and rectification or erasure of personal information, the right to restrict processing of your personal information, and the right to object to processing of your personal information. You have the right to object to your personal information being processed on the grounds of our legitimate interests.
7.6 You have the right to lodge a complaint regarding our processing of your personal information with a data protection supervisory authority in a country where you live, work, or where you believe a breach may have occurred.
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9.1 Our website and services are targeted at persons over the age of 18.
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
13.3 We use Heroku to scale the performance of our website. Heroku gathers information about website use by means of cookies. You can find information about Heroku privacy policies and practices at https://www.salesforce.com/company/privacy/.
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website.
Quilgo collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal information it processes.
If you are a Client, by using our products and services, you confirm that you have the appropriate permission to share the personal information of your users with us, and that you have provided them with access to a copy of this policy.
If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
We will retain personal information we process on behalf of our Clients for as long as needed to provide services to our Client. Quilgo will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
16.1 This website is owned and operated by Native Platform Ltd.
16.2 We are registered in England and Wales under registration number 09897552, and our registered office is at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.
16.3 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form; or
(d) by email to [email protected].
This document was last updated: Sunday 27 September 2020