Last updated: 1st Sep 2023
Me Learning Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
1.1. We are committed to safeguarding the privacy of our website/LMS visitors and customers; in this policy we explain how we will handle your personal data.
2. How we use 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, Internet Service Provider (ISP), geographical location, browser type and version, device type, 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. 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 basis for this processing is 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, email address and physical address details. The account data may be processed for the purposes of operating our website, providing our services by creating a learner or administrator account on our Learning Management Systems (“Blue LMS”, “Form LMS”, “LMS”), ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you in connection with your use of the services. The legal basis for this processing is that it is necessary for the purposes of our legitimate interests and our customers’ legitimate interests in providing and receiving requested services, ensuring network and information security and availability and communicating with our customers and their users. We may also process your account data for the purposes of sending marketing communications to you in the circumstances set out in section 2.9 (see section 2.9 for further detail about our use of personal data for marketing purposes).
2.4. We may process information relating to transactions, including purchases of products and services, that you or your organisation enter into with us whether through our website or otherwise (“transaction data”). The transaction data may include your name and contact details, details relating to the method of payment used, and the transaction details. 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.
2.5. 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.
2.6. We may record phone calls. We will inform you at the beginning of the call if we are going to record your phone call. The call recording data may include any personal data disclosed during the phone call, and also communication metadata associated with the call (“call recording data”). Call recording data is used for the purposes of maintaining service quality and improving our services. The legal basis for this processing is legitimate interests.
2.7 We may process information related to feedback (“feedback data”) you leave as part of or following your classroom training (via evaluation forms), online training (via the platform’s feedback mechanism), research sessions or your purchase and/or implementation (via customer feedback surveys). The feedback data may include the name of your organisation, your full name and any further personal information you reveal within your comments. The feedback data will be processed to determine the effectiveness of our training and enable us to enhance, modify or otherwise improve our products and services. The legal basis for this processing is our legitimate interests, namely the ongoing improvement of our products and services.”
2.9. We may process your personal data (“notification data”) including your name, email address, job role and purchase history) for the purposes of sending email marketing communications to you in the following circumstances:
(a). If you have purchased a product or service from us or are a relevant contact for an organisation that has purchased a product or service from us;
(b). If you have subscribed to any of our newsletters or communications;
(c). If you have expressed an interest in staying up-to-date with Me Learning’s products and services
(d). If you are the relevant contact in your organisation for decision making or procurement of relevant products and services
In all those cases, we will store your information in our Customer Relationship Management System, Microsoft Dynamics CRM 365.
The legal basis for this processing is our legitimate interests, namely the ability to enhance and personalise our communications for the benefit of our customers and provide communication which we think will be of interest to you to and which will allow us to increase our business growth. You can object to this processing at any time by clicking the unsubscribe link at the bottom of our emails or by contacting us directly by sending an email to firstname.lastname@example.org.
2.10. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.11. 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. Providing your personal data to others
3.1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2. Financial transactions relating to our website and services are handled by our payment services providers, PayPal (before 25th May 2018), and BrainTree (after 25th May 2018May 2018 – Oct 2023) and Stripe (Oct 2023 – Present). 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://www.paypal.com/webapps/mpp/ua/privacy-full, https://www.braintreepayments.com/gb/legal/braintree-privacy-policy and https://stripe.com/gb/privacy.
3.4. If you have placed an order with us or completed our classroom training satisfaction survey, some of your data may be stored on Podio, which is used as a project management tool within the Service Delivery department. Citrix Podio is provided by Citric Systems, Inc.
3.5. If you request support via our helpdesk, either by email or phone, data related to your request, including some personal data such as name, telephone number and email address, will be transferred to Zendesk, Inc (‘Zendesk’). Zendesk is a service provider used by Me Learning that provides customer support incident management capabilities.
3.6. If you use the chat functionality on our website, data related to your request, including some personal data such as name, telephone number and email address, will be transferred to Crisp IM SAS (‘Crisp’). Crisp is a service provider used by Me Learning that provides live chat functionality.
3.7. If we identify an issue raised as a software bug, information about that issue, and potentially some about the individual who has raised the bug, will be transferred to Atlassian Pty Ltd (‘Atlassian’). Atlassian produce ‘Jira’, a project management tool used by Me Learning throughout the development lifecycle.
3.8. If you have access to our Blue LMS or Form LMS platforms, or signed up to take part in our user research, we use Mandrill to send emails from both LMS to you. For LMS users, these emails include (but are not limited to) platform registration details, password resets and reminders to complete training. For those taking part in user research, the emails include invites to participate in user tests, interviews and online surveys. Mandrill is a transactional email API for MailChimp users provided by The Rocket Science Group LLC d/b/a MailChimp (‘MailChimp’).
3.9. If you have made a purchase, sent an enquiry, called us with a question and/or use our services, we may store data relating to you or your purchase on SharePoint (such as copies of contracts, meeting minutes, details about complaints / improvement suggestions). Me Learning also uses Exchange Online (Office 365) to send direct emails to you and may receive copies of support tickets by email, and it is possible these could contain personal data relating to learner users. If you have enquired about or purchased a product or service or completed our customer satisfaction survey, we will use the information you have given to update our customer relationship management system, Microsoft Dynamics CRM, so one of our advisors can contact you about the product/service. These services are provided by Microsoft Corporation (‘Microsoft’). Although Microsoft is based in the US, data that Me Learning stores in Office 365 are hosted on servers located in the UK.
3.10. We use Amazon Web Services (“AWS”) to host our LMS platforms and products. All data and backups are located within the UK or Ireland. We may also use additional services provided by Amazon to provide related services, such as email or authentication services.
3.11. Prior to November 2023, we used a number of products provided by HubSpot Inc. We used HubSpot to:
- send all of our digital marketing communication. For this purpose, HubSpot will be holding a copy of your email address and process information in relation to your email activity (such as clicks, opens or unsubscribes). This information will also be synchronised to Microsoft Dynamics CRM.
- send customer satisfaction, research or feedback surveys/questionnaires to our existing contacts. For this purpose, HubSpot will process and hold a copy of any survey responses you submit.
- capture data relevant to page visits that occur on our website. This data can include IP organisation information, such as the IP address and organization name, visit statistics such as the time and duration and page view statistics such as the operating system, URLs visited and browsers used.
- HubSpot Inc processes the data but the data is stored within Microsoft Dynamics CRM.
3.12. We use SMTP.DK.ApS to send some of our digital marketing communication. For this purpose, SMTP.DK.ApS will be holding a copy of your email address and process information in relation to your email activity (such as clicks, opens, bounces or unsubscribes).
3.13. We use Twilio, Inc.’s SendGrid services to send emails from the website to you, your licence recipients (when assigning licences to them) and ourselves. These emails include (but are not limited to) personal information entered into web forms, IP addresses, name and order details.
3.14. We use Rustici Software LLC’s SCORM Cloud software to provide data on licence/account usage by Me Learning customers who host Me Learning’s courses on their own LMS.
3.15. We use WPEngine, Inc. (‘WP Engine’) to host our website. The data centre is located within the UK.
3.16. We use LearnDash by Liquid Web, LLC (‘LearnDash’) to host courses on our online shop. If you register a free account then we will store your email address and course enrolment data such as completion status and quiz scores. Course enrolment data is wiped after 12 months of enrolment. We store information about you for as long as your account exists.
3.17. In addition to the specific disclosures of personal data set out in this Section 3, we may 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1. In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom of Great Britain and Northern Ireland (UK) or European Economic Area (EEA).
4.2. The hosting facilities for our website are situated in the UK.
4.3. Some of our service providers listed in section 3 are situated in the United States of America (USA) and Australia, and our use of their services involves a transfer of some personal data outside of the UK and EEA to the USA, Australia and other countries where they or their sub-processors have establishments. Details of the relevant service providers and the safeguards in place to protect the personal data transferred to them are explained below:
LogMeIn, Inc. (‘LogMeIn’) (USA) (GoToWebinar services): Transfers to LogMeIn are subject to the LogMeIn Data Processing Addendum, which incorporates Standard Contractual Clauses, and can be viewed here: https://logmeincdn.azureedge.net/legal/lmi-customer-dpa-2020v1.pdf.
Citric Systems, Inc. (‘Citrix’) (USA) (Podio services): Transfers to Citrix are subject to the Citrix Data Processing Agreement, which incorporates Standard Contractual Clauses, and can be viewed here: https://www.citrix.com/en-gb/buy/licensing/citrix-data-processing-agreement.html
The Rocket Science Group LLC d/b/a MailChimp (‘MailChimp’) (USA) (Mandrill services): Transfers to MailChimp are subject to the MailChimp Data Processing Addendum, which incorporates the Standard Contractual Clauses, and can be viewed here: https://mailchimp.com/legal/data-processing-addendum/.
HubSpot, Inc. (‘Hubspot’) (USA) (digital marketing services): Transfers to HubSpot are subject to the HubSpot Data Processing Agreement, which incorporates the Standard Contractual Clauses, and can be viewed here: https://legal.hubspot.com/dpa.
Atlassian Pty Ltd (‘Atlassian’) (Australia) (support services project management tool): Transfers to Atlassian are subject to the Atlassian Data Processing Addendum, which incorporates the Standard Contractual Clauses, and can be viewed by downloading the Data Processing Addendum here: https://www.atlassian.com/legal/data-processing-addendum.
Twilio, Inc. (‘Twilio’) (USA) (SendGrid email services): Transfers to Twilio are subject to the Twilio Data Protection Addendum, which incorporates the Standard Contractual Clauses, and can be viewed here: https://www.twilio.com/legal/data-protection-addendum.
WPEngine, Inc. (‘WP Engine’) (USA): Whilst our website is hosted in the UK, complete offsite backups are performed as an automated daily process and are encrypted via SSL in transit and also encrypted at rest. You can find more information the WP Engine Data privacy addendum here: https://wpengine.co.uk/legal/dpa/.
4.4. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
4.5. Explanation of international transfer terms referred to in this section:
Standard Contractual Clauses: These are standard data protection clauses for data transfers between EU and non-EU countries adopted by the European Commission pursuant to a decision of the European Commission that those clauses provide an adequate level of protection for personal data transferred between the parties to those clauses. See the Europa website for more information on, and links to, the standard contractual clauses: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
Binding Corporate Rules: These are data protection policies adhered to by companies established in the EU for transfers of personal data outside the EU within a group of undertakings or enterprises, which must include all general data protection principles and enforceable rights to ensure appropriate safeguards for data transfers, be legally binding and enforced by every member of the group. See the Europa website for more information on binding corporate rules: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/binding-corporate-rules-bcr_en.
5. Retaining and deleting personal data
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. We will retain your personal data as follows:
(a). Your account data will be retained as long as you are an active service user. If you are no longer an active service user for a period of one year, your data will be archived for a further six months, after which it will be permanently deleted. If you want to become an active service user again after your data has been disposed of you will be treated the same as a new service user.
(b). Your usage data will be retained for a period of 38 months, following which it will be deleted
(c). Your transaction data will be retained for a period of seven years, following which it will be deleted
(d). Your correspondence data will be retained for a period of five years, following which it will be deleted
(e). Your call recording data will be retained for a period of 36 months, following which it will be deleted
(f). Your participant data will be retained until you inform us (by contacting us directly or unsubscribing from our mail list) that you are no longer interested in taking part in our user research, after which it will be deleted
5.4. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a). Your notification data will be retained until you opt out of receiving relevant communication from us
(b). Your feedback data will be retained for five years or for as long as the portal you left the feedback on is active (if this is longer), following which it will be deleted
5.5. 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. We may notify you of changes to this policy by email, notices on our website or products or any other appropriate method.
7. Your rights
7.1. In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2. Your principal rights under data protection law are:
(a). the right to access;
(b). the right to rectification;
(c). the right to erasure;
(d). the right to restrict processing;
(e). the right to object to processing;
(f). the right to data portability;
(g). the right to complain to a supervisory authority; and
(h). the right to withdraw consent.
7.3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9. To the extent that the legal basis for our processing of your personal data is:
(a). consent; or
(b). that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.10. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.11. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.12. You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.
8. Third party websites
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. Personal data of children
9.1. Our website and services are targeted at persons over the age of 16.
9.2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
10.1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
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.
12. Cookies that we use
Blue LMS is our current learning management system, which has been used to host ours and our customers learning since 2016. Instances of Blue LMS are found on URLs structured as “sitename.melearning.univeristy”.
- We use cimastersession_melearning to validate authenticated users’ sessions.
- We use cookieAgree to store your acceptance of our cookies.
- We use csrfmastercookiename for security to prevent automated attacks.
- If you use Single Sign-on (SSO) login, we use PHPSESSID and SimpleSAMLAuthToken to identify you during the login process.
Form LMS is our new learning management system (totally independent of Blue LMS). Instances of Form LMS are found on the URL “https://app.melearning.co.uk/“.
- Our infrastructure provider uses __cfduid for identifying potential malicious users
- We use accessToken, firstStageToken, refreshToken and secondStageToken to validate authenticated users’ sessions.
13. Cookies used by our service providers
13.5. We use AutomateWoo to send emails regarding your shopping cart and previous purchases if you have been logged in while visiting our website and have not opted out of receiving those emails by clicking the unsubscribe link at the bottom of any previous emails. Emails you receive will be a) two hours after leaving the site without completing the purchase and b) two hours after completing a purchase about other courses we believe you may be interested in. The relevant cookies are wp_automatewoo_session_started, wp_automatewoo_visior_session.
14. Managing cookies
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). https://help.opera.com/en/latest/web-preferences/ (Opera);
(d). https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e). https://support.apple.com/en-gb/guide/safari/sfri11471/mac (Safari); and
(f). https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-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.
15. Our details
15.1. This website is owned and operated by Me Learning Ltd.
15.2. We are registered in England and Wales under registration number 05842638, and our registered office is at The Barn, Brackwell Farm, Nether Winchendon, Aylesbury, Bucks, HP18 0DS.
15.3. We are registered as a fee payer with the UK Information Commissioner’s Office. Our data protection registration number is ZA105645.
15.3. You can contact us:
(a). by post, to the postal address given above;
(b). using our website contact form;
(c). by telephone, on the contact number published on our website; or
(d). by email, using the email address published on our website.
Force24 Cookies & Tracking
Our organisation utilises Force24’s marketing automation platform.
Force24 cookies are first party cookies and are enabled at the point of cookie acceptance on this website. The cookies are named below:
They allow us to understand our audience engagement thus allowing better optimisation of marketing activity.
f24_autoId – This is a temporary identifier on a local machine or phone browser that helps us track anonymous information to be later married up with f_24personid. If this is left anonymous it will be deleted after 6 months. Non-essential, first party, 10 years, persistent.
f24_personId – This is an ID generated per individual contact in the Force24 system to be able to track behaviour and form submissions into the Force24 system from outside sources per user. This is used for personalisation and ability to segment decisions for further communications. Non-essential, first party, 10 years, persistent.
The information stored by Force24 cookies remains anonymous until:
- Our website is visited via clicking from an email or SMS message, sent via the Force24 platform and cookies are accepted on the website.
- A user of the website completes a form containing email address from either our website or our Force24 landing pages.
- The Force24 cookies will remain on a device for 10 years unless they are deleted.
We also use similar technologies including tracking pixels and link tracking to monitor your viewing activities.
Device & browser type and open statistics
All emails have a tracking pixel (a tiny invisible image) with a query string in the URL. Within the URL we have user details to identify who opened an email for statistical purposes.
All links within emails and SMS messages sent from the Force24 platform contains a unique tracking reference, this reference help us identify who clicked an email for statistical purposes.