PRIVACY POLICY

Effective date: April 22, 2020

Open Learning Global Pty Ltd and its associated companies (“us”, “we”, or “our”) operate the https://www.openlearning.com/ website and the OpenLearning App mobile application (the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

1. DEFINITIONS

1.1 Service – Service means the website https://www.openlearning.com/, any website managed or hosted by OpenLearning and the OpenLearning mobile application.

1.2 Personal Data – Data about a living individual who can be identified from those data.

1.3 Usage Data – Data collected automatically from the Service infrastructure.

1.4 Cookies – Small pieces of data stored on your device.

1.5 Data Controller – OpenLearning is the controller responsible for processing your Personal Data.

1.6 Data Processor – Third parties that process data on behalf of the controller.

1.7 Data Subject – Any user whose personal data is processed.

2. INFORMATION COLLECTION AND USE

2.1. We collect several types of information for various purposes to provide and improve our Service.

2.2 Types of Data Collected

2.3 Personal Data

While using our Service, we may ask you to provide personally identifiable information including:

• Email address
• First name and last name
• Cookies and Usage Data

We may contact you with newsletters, marketing or promotional materials. You may opt-out using the unsubscribe link.

3. USAGE DATA

Usage Data is collected automatically when using the Service.

It may include:

• IP address
• Browser type and version
• Pages visited
• Visit time and duration
• Device identifiers

4. LOCATION DATA

We may use and store location data if you grant permission.

You can enable or disable location services anytime through device settings.

5. TRACKING & COOKIES DATA

We use cookies and tracking technologies to monitor Service activity.

Examples include:

• Session Cookies
• Preference Cookies
• Security Cookies
• Advertising Cookies

6. USE OF DATA

OpenLearning uses collected data to:

• Provide and maintain the Service
• Notify users of changes
• Provide customer support
• Improve the platform
• Monitor usage
• Detect technical issues
• Provide offers and updates

7. LEGAL BASIS FOR PROCESSING (GDPR)

If you are in the European Economic Area (EEA), processing may occur because:

• We must perform a contract with you
• You have given consent
• Legitimate business interests
• Legal obligations

8. TRANSFER OF DATA

Your information may be transferred to computers outside your jurisdiction including Australia.

We ensure adequate safeguards and security controls are in place.

9. DISCLOSURE OF DATA

Business Transaction: Personal data may transfer during mergers or acquisitions.

Law Enforcement: Data may be disclosed if required by law.

We may disclose personal data to:

• Comply with legal obligations
• Protect company rights or property
• Investigate wrongdoing
• Protect public safety

11. SECURITY OF DATA

Sensitive information is transmitted via SSL encryption.

Payment data is not stored on our servers.

However, no online system can guarantee 100% security.

12. DO NOT TRACK SIGNALS

We do not support Do Not Track (DNT).

Users can manage this setting through their browser preferences.

13. GDPR DATA PROTECTION RIGHTS

Users in the EEA have rights including:

• Access personal data
• Update or correct data
• Request deletion
• Restrict processing
• Data portability

14. DATA RIGHTS – PHILIPPINES

Users in the Philippines have rights under the Data Privacy Act of 2012.

More information can be found at:

https://www.privacy.gov.ph

15. REQUESTING DATA DELETION

You may request permanent deletion of your personal data.

Contact us at:

privacy@openlearning.com

16. SERVICE PROVIDERS

We may employ third-party companies to facilitate our Service.

These providers process data only on our behalf.

17. ANALYTICS

We use analytics services including:

Google Analytics
Firebase

18. ADVERTISING

Advertising services may include Google AdSense and DoubleClick cookies.

You can manage advertising settings at:

http://www.google.com/ads/preferences/

19. BEHAVIOURAL REMARKETING

We may use remarketing services from:

Google Ads
Twitter
Facebook

20. PAYMENTS

Payment processors include:

Apple In-App Payments
Google Play Payments
Stripe
PayPal / Braintree

Our Service may contain links to third-party sites.

We recommend reviewing the privacy policy of every external site.

22. CHILDREN’S PRIVACY

Our public platform does not knowingly collect personal data from anyone under the age of 18.

If a parent believes a child has provided personal data, please contact us so we can remove it.