Privacy Notice - Digital Business Konsult

This Privacy Notice was last updated on March 01, 2022.

At Digital Business Konsult, located at BOS House, Oldenway Business Park, Ballybrit, Galway, H91 E65V Ireland, we value your privacy and respect any personal data entrusted into our hands. This Privacy Notice (“Privacy Notice”) explains our privacy practices and how we use your personal data to perform our business activities described below. Please read this Privacy Notice carefully to learn how we collect, use, share, and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding your Personal Data.

A reference to “Digital Business Konsult,” “we,” “us” or the “Company” is a reference to Digital Business Konsult and its relevant affiliate involved in the collection, use, sharing, or other processing of Personal Data.

Unless we link to a different policy or state otherwise, this Privacy Notice applies when you visit or use the Digital Business Konsult website, mobile applications, APIs or related services (the “Services”). By using the Services, you agree to the terms of this Privacy Notice. You shouldn’t use the Services if you don’t agree with this Privacy Notice or any other agreement that governs your use of the Services.

Table of Contents

What Personal Information we collect
How We Get Data About You
What We Use Your Data For
Who We Share Your Data With
How We Protect Your Data
Overseas transfers of personal data
How long we keep your data
Your Rights as a Data Subject
Users outside the EU
Changes to this Privacy Notice
Contacting Us
Complaints to the Information Commissioner

1. What Personal Information we collect:

We collect your personal information in order to provide and continually improve our training products and services. The type of information that we collect depends on how you use our products. We collect certain data from you directly, like information you enter yourself, data about your participation in courses, work experience meetings and data from third-party platforms you connect with Digital Business Konsult. We also collect some data automatically, like information about your device and what parts of our services you interact or engage with.

1.1 Data You Provide to Us

We may collect different items of data from or about you depending on how you use our Services. Below are some examples to help you better understand the data we collect. You can choose not to provide certain information but then you might not be able to take advantage of some of our services.

When you create an account and use the services, including through a third-party platform, we collect any data you provide directly, including:

Account Data	In order to use certain features (like enrolling in a course), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your name, email address, password, phone number, occupation, skill interests, gender, age, date of birth, and account settings and assign you a unique identifying number (“Account Data”).
Profile Data	You can also choose to provide profile information like a photo, headline, biography, language, website link, social media profiles, country, or other data. Your Profile Data will be publicly viewable by others.
Shared Content	Parts of the Services let you interact with other users or share content publicly, including by posting reviews on a course page, asking or answering questions, sending messages to students or instructors, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted.
Testimonials	As part of our promotional activities, we encourage students who have secured employment or fulfilled other personal objectives following participation in our programmes to submit testimonials and reviews to inspire and motivate others. Such testimonials and reviews may contain personal information about you like your name, skills gained, occupation, role, employer and location. Such content will be publicly viewable.
Course Data	When you enrol in and take courses, we collect certain data including which courses, projects and tasks you’ve started and completed; course purchases; subscriptions; course certificates; your exchanges with trainers, and other students; and essays, answers to questions, and other items submitted to satisfy course requirements. If you are a trainer, we store course content that may contain data about you.
Student Payment Data	If you make purchases, we collect certain data about your purchase (such as your name and post code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code. For security, Digital Business Konsult does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
Trainer Payment Data	If you are a trainer, you can link your PayPal or other payment account to the Services to receive payments. When you link a payment account, we collect and use certain information, including your payment account email address, account ID, physical address, or other data necessary for us to send payments to your account. In order to comply with applicable laws, we also work with trusted third parties who collect tax information as legally required. This tax information may include residency information, tax identification numbers, biographical information, and other personal information necessary for taxation purposes. For security, Digital Business Konsult does not collect or store sensitive bank account information. The collection, use, and disclosure of your payment, billing, and taxation data is subject to the privacy policy and other terms of your payment account provider.
Data About Your Accounts on Other Services	We may obtain certain information through your social media or other online accounts if they are connected to your Digital Business Konsult account. If you login to Digital Business Konsult via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, account ID number, login email address, location, physical location of your access devices, gender, birthday, and list of friends or contacts. Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us. If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
Sweepstakes, Promotions, and Surveys	We may invite you to complete a survey or participate in a promotion (like a contest, sweepstakes, or challenge), either through the Services or a third-party platform. If you participate, we will collect and store the data you provide as part of participating, such as your name, email address, postal address, date of birth, or phone number. That data is subject to this Privacy Notice unless otherwise stated in the official rules of the promotion or in another privacy policy. The data collected will be used to administer the promotion or survey, including for notifying winners and distributing rewards. To receive a reward, you may be required to allow us to post some of your information publicly (like on a winner’s page). Where we use a third-party platform to administer a survey or promotion, the third party’s privacy policy will apply.
Communications and Support	If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, messages, location, Digital Business Konsult user ID, refund transaction IDs, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Notice.

The data listed above is stored by us and associated with your account.

1.2 Data We Collect through Automated Means

When you access the Services (including browsing courses), we collect certain data by automated means, including:

System Data	Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”).
Usage Data	Usage statistics about your interactions with the Services, including courses accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services (“Usage Data”).
Approximate Geographic Data	An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.

2. How We Get Data About You

We use tools like cookies, web beacons, and similar tracking technologies to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.

2.1 Cookies and Data Collection Tools

We use cookies, which are small text files stored by your browser, to collect, store, and share data about your activities across websites, including on Digital Business Konsult. They allow us to remember things about your visits to Digital Business Konsult, like your preferred language, and to make the site easier to use. To learn more about cookies, visit https://cookiepedia.co.uk/all-about-cookies.

Digital Business Konsult and service providers acting on our behalf (like Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools“) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Notice.

2.2 Why We Use Data Collection Tools

Digital Business Konsult uses the following types of Data Collection Tools for the purposes described:

Strictly Necessary: These Data Collection Tools enable you to access the site, provide basic functionality (like logging in or enrolling in courses), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are required for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.
Functional: These Data Collection Tools remember data about your browser and your preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the Services (like your preferred language or volume level for video playback).
Performance: These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from. These tools can help us test different versions of Digital Business Konsult to see which features or content users prefer and determine which email messages are opened.
Advertising: These Data Collection Tools are used to deliver relevant ads (on the site and/or other sites) based on things we know about you like your Usage and System Data (as detailed in Section 1), and things that the ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and content that you share publicly on the Services.
Social Media: These Data Collection Tools enable social media functionality, like sharing content with friends and networks. These cookies may track a user or device across other sites and build a profile of user interests for targeted advertising purposes.

You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional. To learn more about managing Data Collection Tools, refer to Section 6.1 (Your Choices About the Use of Your Data) below.

3. What We Use Your Data For

We only process data for specified purposes and if it is justified in accordance with data-protection law. The table below lists the various purposes for which we process personal data and the corresponding justification for it. Some processing of your personal data is justified on the basis of contractual necessity. In general, this applies to personal data you provide to us upon subscription to manage your account and monitor academic performance.

We use your data to do things like provide our services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our services, analyse how people use our services, serve personalized advertising, and as required by law or necessary for safety and integrity. Without that information, we would be unable to provide you with your chosen academic programme and related support services.

If you engage in our programs but do not complete or procure a subscription, we will retain your personal data in line with our retention schedules for statistical and audit purposes or in the event of a complaint or an appeal.

We use the data we collect through your use of the Services to:

Purpose	Legal basis / Justification
Assessing eligibility to undertake our training programmes and workshops	Processing is necessary for the purposes of taking steps prior to entering into a contract with us.
Supporting applicants through the application process and providing further information on the services we can offer.	Necessary for negotiating to enter into a contract and legitimate interests in providing support to applicants.
Provide and administer training programmes, workshops and related services, including to facilitate course participation, issue course completion certificates, display customized content, and facilitate communication with other users	Necessary for performing a contract, i.e. to provide your chosen training programme. This can be a contract with us or a contract between you and your home institution (“contractual necessity”).
Identifying students and assisting them in trying to succeed in their learning via the platform system.	Contractual necessity and legitimate interest in assisting our students to succeed in their training.
Assessment of skills acquisition, progress and performance (including attendance), and where necessary providing support.	Contractual necessity.
Process your requests and orders for courses, products, specific services, information, or features.	Contractual obligation
Administration of complaints and suggestions, interruption and withdrawal.	Contractual necessity.
Mentoring and Employability Support.	Contractual necessity and our legitimate interest in assisting our students and alumni to progress in their careers.
Regulating Digital Business Konsult’s community (including dealing with misconduct under our procedures for academic and other misconduct including disciplinary procedures).	Contractual necessity and our legitimate interest in maintaining academic standards and the good order of the learning community.
Obtaining payment of fees	Contractual necessity and our legitimate interest in obtaining payment for the services we provide.
Processing instructor payments	Contractual necessity and our legitimate interest in rendering payment for the services we procure.
Protecting our property and assets (e.g. by dealing with misconduct).	Necessary for our legitimate interest in safeguarding our property and assets.
Providing appropriate I.T. tools and other infrastructure facilities e.g. a virtual learning environment.	Contractual necessity; legitimate interest in providing a proper infrastructure to support the provision of academic programmes and related student services.
Solicit feedback from users	Contractual necessity and our legitimate interest in ensuring the service is improved and optimised
Solicit testimonials and reviews	Necessary for our legitimate interests in maintaining and optimising the business and marketing.
Registering alumni to maintain an alumni network.	Necessary for our legitimate interests in maintaining an alumni network, and marketing.
Communicate with you about your account by: Responding to your questions and concerns; Sending you administrative messages and information, including messages from instructors, trainers, students; notifications about changes to our Service; and updates to our agreements; Sending you information, such as by email or text messages, about your progress in courses, rewards programs, new services, new features, promotions, newsletters, and other available courses (which you can opt out of at any time);	Contractual necessity and our legitimate interest in marketing Digital Business Konsult and promoting student welfare.
Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;	Legitimate interest
Market and administer surveys and promotions administered or sponsored by Digital Business Konsult;	Legitimate interest

4. Who We Share Your Data With

We share certain data about you with instructors, other students, companies performing services for us, Digital Business Konsult affiliates, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

With Your Instructors: We share data that we have about you (except your email address) with instructors or teaching assistants for courses you enrol in or request information about, so they can improve their courses for you and other students. This data may include things like your city, country, browser language, operating system, device settings, the site that brought you to Digital Business Konsult, and your activities on Digital Business Konsult. If we collect additional data about you (like age or gender), we may share that too. We will not share your email address with instructors or teaching assistants. We also enable our instructors to implement Google Analytics on their course pages to track sources of traffic to their courses and optimize their course pages.
With Other Students and Instructors: Depending on your settings, your shared content and profile data may be publicly viewable, including to other students and instructors. If you ask a question to an instructor or teaching assistant, your information (including your name) may also be publicly viewable by other users depending on your settings. When you collaborate and work on projects with other students, they will be able to see your data. Your data will also be viewable by other students on the mobile messaging apps we use.
With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
With our Affiliates: We may share your data within our corporate family of companies that are related by common ownership or control to enable or support us in providing the Services.
With Business Partners: With your consent, we may share information that can be used to directly contact you with third party business partners, such as companies that may be offering products or services or other opportunities that may be of interest to you. We have agreements with other websites and platforms to distribute our Services and drive traffic to Digital Business Konsult. Depending on your location, we may share your data with these partners.
To Power Social Media Features: The social media features in the Services (like the Facebook Like button) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy.
To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
For Advertising: If we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1), to use this data to offer you targeted ad delivery to personalize your user experience (through behavioural advertising), and to undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks’ behavioural advertising, see Section 6.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads.
For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
- Permitted or required by law;
- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
- Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
- Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Digital Business Konsult, our users, employees, members of the public, or our Services.
- We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Notice.
During a Change in Control: If Digital Business Konsult undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
After Aggregation/De-identification: we may disclose or use aggregated or de-identified data for any purpose.
With Your Permission: with your consent, we may share data to third parties outside the scope of this Privacy Notice.

5. How we protect your data

We take appropriate precautions including organisational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorised disclosure of, or access to, the Personal Data we process or use. 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. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in the “Contacting us” section, below.

6. Overseas transfers of personal data (i.e. outside the European Economic Area (EEA)

Where possible, we aim to hold personal data relating to students within the EEA. Where any of your personal data is transferred outside the EEA it will be subject to a legally binding data sharing agreement and to an adequacy decision by the European Commission (country, territory or specified sectors), or other appropriate safeguards as set out in Article 46 of the GDPR.

7. How long we keep your data

We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the “Purposes for which we process Personal Data and the legal bases on which we rely” section, above) or as long as required to fulfil our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorised use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

For more information on data retention periods, please contact us by using the information in the “Contacting us” section, below.

8. Your rights as a data subject

As a data subject, you may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

Access your Personal Data held by us;
Know more about how we processed your Personal Data
Rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
Erase or delete your personal data. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
Object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
Restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
Transfer your Personal Data to another controller if the data is processed by automated means and the processing is based on your consent or contractual necessity.
Opt out of certain disclosures of your Personal Data to third parties
If you’re under the age of 16, opt in to certain disclosures of your Personal Data to third parties;
Not be discriminated against for exercising your rights described above;
Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). Automated Decision-Making currently does not take place on our websites or in our services;
Withdraw your consent at any time (to the extent we rely on consent for processing), without affecting the lawfulness of the processing based on such consent before its withdrawal. Your requests will be considered at the latest within one month.

8.1 Your Choices About the Use of Your Data

You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.

To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
If you’re located in the European Economic Area, you may opt out of certain Data Collection Tools by clicking the “Cookie settings“ link at the bottom of any page.
The browser or device you use may allow you to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control whether location or other data is collected and shared.
To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Economic Area, visit the Your Online Choices site. To opt out of Google’s display advertising or customize Google Display Network ads, visit the Google Ads Settings page. To opt out of Taboola’s targeted ads, see the Opt-out Link in their Cookie Policy.
To opt out of allowing Google Analytics, Mixpanel, ZoomInfo, or Clearbit to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on, Mixpanel Opt-Out Cookie, ZoomInfo’s policy, and Clearbit data claiming mechanism.
Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings on that platform.

If you have any questions about your data, our use of it, or your rights, please contact us by using the information in the “Contacting us” section, below.

9. Users outside the UK

In order to provide the Services to you, we must transfer your data out of the United Kingdom and process it there. We ensure adequate data protective measures are in place in such location where our data is processed. By visiting or using our Services, you consent to storage of your data on servers located in the United Kingdom. If you are using the Services from outside the United Kingdom, you consent to the transfer, storage, and processing of your data in and to the United Kingdom or other countries.

We may also subcontract the processing of your data to, or otherwise share your data with, service providers and others in countries other than your country of residence, including the United Kingdom, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

If we provide any information about you to any such non-European Union entities, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Notice

If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

10. Changes to this Privacy Notice

We will update this Privacy Notice from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes.

As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Notice. The revised Privacy Notice supersedes all previous Privacy Notices.

We encourage you to periodically review this Privacy Notice to stay informed about our collection, processing and sharing of your Personal Data.

11. Contacting us

11.1. Exercising your rights, queries and complaints

For more information on your rights, if you wish to exercise any right; any concerns, questions or queries you may have or if you wish to make a compliant, please contact our Data Protection Officer:

Name: Oludare Olorunfemi.

Email address: info@digitalbusinesskonsult.com

12. Complaints to the Information Commissioner

You have a right to complain to the Information Commissioner’s Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s