List of active policies

‘Personal data’, in this privacy notice, means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is someone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Why we collect your personal data

So that we can help you, we need your data and here we tie in our legal justifications for needing to collect your data. In order for us to provide you with our services or for correspondence purposes we need to collect your personal data. We ensure that the information we collect and use is confined to this purpose. We always process your personal data for specific purposes, with the nature of the data collected depending on your interaction with us. We are committed to transparency in this.

Our legal bases for controlling or processing personal data are:

Article 6.1(a) GDPR (Consent): You provide informed consent to us or have a reasonable expectation that we will use your information in a certain way – for example, to engage in our community discussions, or to hear about new services or offers. You can withdraw your consent at any time either by selecting ‘delete my data’ within the specific service or by request to info@humanasset.com;

Article 6.1(b) GDPR (Contract): Providing our services and fulfilling our obligations to you, usually relating to a terms of service or partnership agreement;

Article 6.1(c) GDPR (Legal Obligation): The necessity to meet compliance with our legal obligations; and/or

Article 6.1(f) GDPR (Legitimate Interest): Where it is in our legitimate interests to do so. We only rely on ‘legitimate interests’ as the legal basis for processing by us, or third parties we use, for these purposes:

• emergency contacts for people who work with us, such as employees and contractors for health and safety purposes;
• providing login systems to users via their existing social media accounts.

Where we rely on a specific basis for processing your information and you wish to object to that processing, you must be aware that it might not be possible for you to continue using our services.The special categories of personal data (Article 9 of GDPR) we process are:

• facial images, IF you have uploaded and we store your profile picture;
• any special categories of special personal data which any user volunteers while using our services (for example in a forum or submission).

If we need to pass on special category personal data (see Article 9 of GDPR) to a third party, we will only do that in accordance with the legal bases under Article 6 of GDPR as outlined above.

If you would like more details please refer to our Register of GDPR Information.

How we collect personal data

Here we give you examples of ways that you interact with us and the resulting data we may collect!

Celestyal keeps personal data from you when you interact with us. This can be through our websites, over the phone, in person, including, without limitation, when you:

• request support;
• register for or participate in an online class, exam, certification, training, webcast or other event;
• request information or materials;
• participate in surveys or evaluations;
• submit questions or comments; or
• submit content or posts on our forums or other interactive webpages.

How we use personal data

Here we let you know what happens if we need to engage others to assist us to service your needs. If we do engage others we have set how we ensure your data is kept safe.

We may need to pass your personal data on to third-party service providers contracted to us in the course of dealing with you. We do this because there are services, such as our video conferencing facility, which will not work unless we are able to make these transfers. Any third parties we share your data with are obliged to keep your personal data secure and use it only for necessary service delivery. When your data is no longer required to fulfil the service, those third parties will be directed to dispose of your data in accordance with our standard procedures.

We seek to enter into Data Processing Agreements with our third party service providers to ensure they only process your data as instructed by us. If you obtain products or services directly from us on behalf of others we will ensure you enter into a Data Processing Agreement (DPA) with us. You will also need to enter into a DPA with your students/employees/customers when using our systems. An example of our DPA is available on our website.

GDPR information is not shared to any Specific Third Parties at this time.

How we store personal data

Here we outline our processes for data storage, how we will protect your data and keep it only for as long as needed!  We will process (collect, store and use) the information you provide in a manner compatible with GDPR. We maintain physical, organisational and technical safeguards for all personal data we hold. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain certain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept are governed by specific business sector requirements and agreed practices. Personal data can be held in addition to these periods depending on individual business needs. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. We will process different forms of personal data for as long as it is necessary and proportionate for the purpose for which it has been supplied and we will store the personal data for the shortest amount of time possible, taking into account legal and service requirements,

Marketing

No marketing data are collected

Data protection rights

You control the personal data you share with us! Here, we outline your rights under GDPR and CCPA.At any point while we are in possession of or we process your personal data, you have the following rights:

(GDPR) right of access – you have the right to request a copy of the information that we hold about you;

(GDPR) right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete;

(GDPR) right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records;

(GDPR) right to restriction of processing – where certain conditions apply to have a right to restrict the processing;

(GDPR) right of portability – you have the right to have the data we hold about you transferred to another organisation;

(GDPR) right to object – you have the right to object to certain types of processing such as direct marketing;

(GDPR) right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling;

(GDPR) right to judicial review: in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below;

(CCPA) right to deletion - you have the right to delete personal information collected from you (with some exceptions);

(CCPA) right to opt out of sales - we do not sell your data;

(CCPA) right to be free of discrimination - if you exercise your rights we will not discriminate against you; and/or

(CCPA) right to know - you have the right to know:

• the categories of personal information collected;
• specific pieces of personal information collected;
• the categories of sources from which we collect personal information;
• the purposes for which we use your personal information;
• the categories of third parties with whom we share your personal information; and/or
• the categories of information that we disclose to third parties.

Where we are your Data Controller, please make your request directly to the Data Protection Officer at zacademy@zorbas.com.cy. We will always respond within one month.

However, if we are processing your data on behalf of your Data Controller (your service provider) you should contact them directly.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

Useful Resources

We provide you with useful resources to streamline your engagement with us. We remain committed to building a secure LMS experience that protects the privacy and security of learners' and employees’ data. We provide all users with the tools to ensure that their data, information and operations are secure and protected. Privacy features embedded with Moodle LMS ensure that Moodle is GDPR compliant and adheres to local privacy legislation requirements.

Our privacy notice and managing your data is only applicable when you are using our services. It does not cover your use of others’ sites and services.

This privacy notice outlines how we manage your personal data. If the website you are using is not hosted by us or you click on a link to another website, we encourage you to read their privacy notice.

Verification

Before we action a request we need to ensure it is from you.

Before we action a personal data request we need to verify your identity. We accept a request made through your personal Moodle account while you are logged in. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

Amendments to our Privacy Notice

We are transparent about any updates made to this Notice.

Moodle LMS updates our privacy notice when necessary or in response to:

• feedback from our community, customers, relevant authority, industry or other stakeholders;
• changes in our products or services; and/or
• data processing or policy changes.

How to contact us

If you have any questions about the privacy notice, please contact us by email at zacademy@zorbas.com.cy