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Privacy

Learnerbly’s Privacy Policy will help you understand what information we collect and process using this website, how we use it, and what choices you have about your personal data. When we refer to “Learnerbly” within this Privacy Policy we are referring to Enternships Limited of 9th Floor, 107 Cheapside, London EC2V 6DN.

Enternships Limited is established within the United Kingdom and is registered under the UK Data Protection Act as a Data Controller with the Information Commissioner’s Office (no. Z2720747). This Privacy Policy also aligns with the requirements of the EU General Data Protection Regulation 2016/679 (“GDPR”).

Learnerbly has carried out a comprehensive assessment of our current data processing practices based on industry best practices, and the advice of our external Data Protection Consultant.


  1. Data Collected by Learnerbly

You may decide to send us your personal information via our website if you are seeking more information or for one or more of the following purposes:

  1. User profile and other personal information: users provide Learnerbly with information about themselves (name, email address, job function, learning goals) through the member registration process and learner survey / on-boarding process. From time to time we may invite users to provide information through other parts of the website – for example, where Learnerbly or a partner sponsors a promotion through the website.
  2. Member-provided content: Learnerbly allows users to augment their profile information (regarding learning needs, feedback on courses) and other materials which may include personal information about themselves or others, to the website which is available for Company admins/managers who are the main point of contact between Learnerbly and the end-users and therefore need to access the personal data, as well as information which users may choose to make visible to peers if they decide to share information with other users, and therefore these other users may see their name associated with a request. We securely store and host these materials on behalf of our users.
  3. Non Member provided content: Learnerbly also collects the IP addresses of the computers used by visitors to the website. They are used, together with further information about visits to the site, to note a visitor’s interest in the website and for statistical purposes. They do not allow us to identify the visitor unless they also choose to submit personal information to the website.

  4. Personal Data Processing Activities

By voluntarily interacting with this website or any services which are made available to you directly from this website, you are providing us with your explicit consent to undertake the personal data processing activities which are described below. You can amend or remove your consent at any time (as per Section 5 of this Privacy Policy).

  1. Learnerbly uses personal information collected through the website to authenticate its users, to provide services through the site, to tailor and improve those services and to administer our user relationships. Please find a list of the services below:
    • Allow users to log-in to the Learnerbly app
    • Request a demo
  • Subscribe to the newsletter
  1. Learnerbly may also use contact details collected through the website to send you updates, newsletters or other communications regarding www.learnerbly.com and the services available through the website. You can choose not to receive these communications at any time (as per Section 5 of this Privacy Policy).
  2. From time to time, Learnerbly or a partner may sponsor a promotion through the Site. Where Learnerbly or a partner collects personal information from you for the purposes of a promotion, we will explain the purposes for which the information will be used and whether it may be disclosed to third parties at the point of collection. You can select not to take part in such activities (as per Section 5 of this Privacy Policy).
  3. Upon your written instruction, we will securely delete or return your Personal Data and all copies thereof on termination of this agreement, unless we are required to retain it under a legal or regulatory obligation to store the Personal Data

  4. Sensitive Personal Data

GDPR specifies a set of personal data categories which are considered to be “sensitive” and which require special consideration by Data Controllers. This website and any services which are made available from this website do not knowingly collect or process any sensitive personal data and supporting Data Protection Impact Assessments which support this assessment are available from Learnerbly’s Data Protection Manager (see Section 10 of this Privacy Policy).


  1. Children’s Personal Data

This website, and any services which are made available from this website are not designed for or directed towards children under the age of 13 as the Learnerbly platform is designed for its Clients’ employees who must be of legal working age have the status of employee. If you become aware that a child under that age of 13 has provided us with their personal information, regardless of whether parental/guardian consent has been provided, please contact Learnerbly’s Data Protection Manager (see Section 10 of this Privacy Policy) so that we can take appropriate action.


  1. Data Subject Rights

As described within GDPR, you have several rights connected to the provision of their personal data to Learnerbly using this website. These include your right to request that Learnerbly:

    • confirms to you what personal data Learnerbly may be processing or storing about you, if any, and for what specific purposes (noted within this Privacy Policy)
    • corrects any inaccurate or incomplete personal data about you
    • changes the consent which you have previously provided to Learnerbly in relation to the processing or storage of your personal data, for example if you no longer wish to receive marketing communications from Learnerbly
    • permanently erases all your personal data promptly, and confirms to you that it has done so (there may be reasons why we may be unable to do this)
    • provides you with a complete copy of your personal data for you to move to an alternative data processor
  • stops processing your personal data, whilst an objection or complaint from you is being investigated and resolved

If you would like further information on how you can exercise your rights in respect of your personal data, please contact Learnerbly’s Data Protection Manager (see Section 10 of this Privacy Policy).

If Learnerbly does not address your request or fails to provide you with a valid reason why it is unable to do so, you have the right to contact the Information Commissioner’s Office to make a complaint. They can be contacted via their website (www.ico.org.uk) or by telephone 0303 123 1113.


  1. Declaration of Sub-Processors

To make an informed decision on whether to provide consent for your personal data to be processed or stored by Learnerbly using this website, we need to make you aware of other organisations that act as Data Processors for us in the provision of our services to you:

    1. Google (https://policies.google.com/privacy/frameworks), a provider of web analytics, cloud and communications services based in the US who have declared compliance with the EU-US Privacy Shield Framework, as set forth by the US Department of Commerce, covering the collection, use and retention of personal data transferred from the UK/EU to the United States.
  1. AWS, Amazon (https://aws.amazon.com/compliance/eu-us-privacy-shield-faq/) a provider of web analytics, cloud-based hosting and communications services based in the US who have declared compliance with the EU-US Privacy Shield Framework, as set forth by the US Department of Commerce, covering the collection, use and retention of personal data transferred from the UK/EU to the United States
    1. Hubspot (https://legal.hubspot.com/privacy-policy), a provider of software products for internal communications, sales and marketing based in the US who have declared compliance with the EU-US Privacy Shield Framework, as set forth by the US Department of Commerce, covering the collection, use and retention of personal data transferred from the UK/EU to the United States.
    1. Intercom (https://www.intercom.com/terms-and-policies#eu-us), a customer messaging platform based in the US who have declared compliance with the EU-US Privacy Shield Framework, as set forth by the US Department of Commerce, covering the collection, use and retention of personal data transferred from the UK/EU to the United States.
  1. AngelList, (https://angel.co/terms) a platform connecting applicants and employers based in the US who have declared compliance with the EU-US Privacy Shield Framework, as set forth by the US Department of Commerce, covering the collection, use and retention of personal data transferred from the UK/EU to the United States

The activities within which each of these Data Processors participate have been recorded within the applicable Data Protection Impact Assessments, and these are available upon request from the Learnerbly Data Protection Manager (see Section 10 of this Privacy Policy).

  1. Website Cookies

This website uses cookies to record your activity data. We use both session-based and persistent cookies, dependent upon how you use or interact with this website.

Cookies are small text files sent by us to your computer, or from your computer or mobile device to us each time you visit our website. They are unique to your device or web browser. Session-based cookies last only whilst the browser is open and are automatically deleted when the browser is closed. Persistent cookies last until you (or your browser) deletes them, or until they expire.

We use cookies which are not specific to your account but are unique and allow us to undertake website analytics and customization. If you decide to disable some or all cookies, you may not be able to use some of the functions on our website. We may use third-party cookies, for example Google Analytics, and you may choose to opt-out of third party cookies from their website.

Note that Learnerbly may allow advertisers that are presenting advertisements on some pages of www.learnerbly.com to download and access their cookies onto your computers. Advertiser’s use of cookies is subject to their own privacy policies and are not communicated within this Learnerbly Privacy Policy.

  1. External Links

This website may include relevant hyperlinks to external websites not controlled by Learnerbly. Whilst all reasonable care has been exercised in selecting and providing any such links, you are advised to exercise caution before clicking any external links. We cannot guarantee the ongoing suitability of external links, nor do we continually verify the safety or security of the contents which may be provided to you. You are advised, therefore, that your use of external links is at their own risk and we cannot be responsible for any damages or consequences caused by their use of them. You should also review the applicable privacy policy provided by external websites before sharing their personal information with them.


  1. Changes to this Privacy Policy

Learnerbly may change this Privacy Policy from time to time, and if we do so we will post any changes on this page. If you continue to access this website or use services available from this website after those changes have come into effect, you will have agreed to the revised policy.


  1. Contacting Learnerbly

If you have any questions about this Learnerbly Privacy Policy, would like to exercise any of your statutory rights, or to make a complaint, please contact:

Learnerbly Data Protection Manager
Enternships Limited
9th Floor, 107 Cheapside
London
EC2V 6DN

email: dataprotection@learnerbly.com

  1. Version

This Privacy Policy (version 2.2) is effective from 25.01.2019