GDPR Privacy Notice

Introduction

At Ardor Learning (“Ardor”), we are committed to safeguarding the privacy of personal data. This privacy notice explains how Ardor processes your personal data, and your rights in relation to the personal data we hold.

Ardor is the data controller of your personal data and is subject to the European Union General Data Protection Act (the “GDPR”) in so far as your data was provided to Ardor while you were in the European Union. For more information on whether the GDPR applies to your personal data, please see https://www.eugdpr.org/.


Scope

This privacy notice applies to all data subjects, as defined below, whose personal data is collected by Ardor, while the data subject is in the European Union. European Union Member States include Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and United Kingdom. If you were in any of these European Member States at the time you provided Ardor with your personal data, this privacy notice will apply to you.

Further, this privacy notice applies to all GDPR affected data whether it was provided to Ardor on the Ardor website, through your employer organization or by any service or tool whereby personal data is collected by, or on behalf of, Ardor.


Responsibilities

The GDPR Compliance Team is responsible for ensuring that this notice is made available to data subjects (as defined below) at the time Ardor processes their personal data (as defined below). All employees/staff of Ardor who interact with data subjects that are subject to the GDPR are responsible for ensuring that this notice is drawn to the data subject’s attention.


Who We Are?

Ardor Learning is pioneering the future of online English education. A Silicon Valley company with offices and operations in the USA, Spain, Mexico, Netherlands, China, Japan and India, Ardor Learning’s Global team has more than 300 years of rich industry experience. Ardor’s mission is to produce true learning outcomes evidenced by enhanced skills that support your business objectives, ensuring scalability, transparency and return on your investment.

Our comprehensive learning solutions include a full range of distance teaching and in-person teaching services, utilizing eLearning, audio and video platforms. Ardor Learning can also provide a standalone assessment tool to help your organization identify communication weaknesses and target outcomes.

Our approach is to blend technology with human touch to provide the “best of both worlds” and to ensure learners achieve demonstrable skill improvement. The ultimate test of any learning product is not how many people use it or how much time they spend in the program, but the rather the skills they develop. Our blended approach has produced completion and proficiency achievement at much higher levels than the average industry rates.

Our GDPR Compliance Team can be contacted at:

Email - gdprcompliance@ardorlearning.com

The Types of Information We Collect:

Under the European Union’s General Data Protection Regulation (GDPR) personal data is 
defined as: 

“any information relating to an identified or identifiable natural person ('data subject'); an 
identifiable natural person is one who can be identified, directly or indirectly, 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”.

The personal data that Ardor collects about you includes: your name and contact information such as e-mail address, primary phone number, secondary phone number, additional information we are required or authorized by applicable laws to collect and process in order to authenticate or identify you or the information you have provided, information you choose to include in e-learning, phone classes and virtual live web classes.

Personal data may also contain “special categories of data.” Under the GDPR, “special categories of data” is defined as: 

“racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.”


Ardor does not collect any “special categories of data” as defined under the GDPR.

How We Collect Your Information


We may collect your personal data in several ways, for example:

From the information you provide to us voluntarily when you interact with us during registration; 


From the information your employer provides to us voluntarily when they ask us to register you for our service; 

When you communicate with us by telephone, email or via our website, for reasons

including, but not limited, to making inquiries;

In addition, we automatically collect certain information regarding visitors to our Site, including information about your equipment, browsing actions and usage patterns. The information we collect automatically is statistical data and does not include personal information. We use this information solely for internal purposes, such as to improve our Site.


How we process information about you

Under the GDPR, processing is defined as:


“Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.”

The personal data we process will be used to allow us to register you as a student, administer your courses, provide services during your time as a student, maintain your student record, manage your academic progress, provide personal and academic advice and support, register for events, to determine your eligibility for placement in learning programs, to inform you of the scope of services offered, to contact you for upcoming events, provide you with information about Ardor, promote Ardor services, and to allow us to fulfill our contractual obligations.

The technologies we use for automatic data collection include cookies. Cookies are small text files stored on your device (computer, tablet or mobile) when you are on the Internet, including on Ardor’s websites. You can delete cookie files from your hard drive at any time or avoid cookies by configuring your browser to reject them or to notify you when a cookie is being placed on your hard drive. By browsing our Site, you accept the use of Cookies in order to offer you program setup tailored to your interests and to perform traffic statistics. We also use these files to perform traffic statistics. 


Our Site uses Google Analytics Demographics and Interest Reporting to help us understand, in aggregate, the age, gender and interests of Site visitors. This Google Analytics tool does not reveal to Ardor your name or other identifying information. Ardor does not combine the information collected through use of Google Analytics with personally identifiable information. The information received from Google Analytics is used only to improve our Site and the type of information displayed to Site visitors, so we can better serve those interested in Ardor.

Ardor hires other companies to provide services on their behalf. Ardor will provide these companies only with the information they need to deliver the services, and they are contractually prohibited from using that information for any other purpose.

At any time, while accessing our Site, any visitor may decline participation in any activity that would require providing information. Your decision not to participate will not affect your ability to use any other feature on our Site.


The lawful basis for processing your information


Ardor processes personal data required to provide you with the services such as register you as a student, administer your courses, , maintain your student record, manage processes in relation to your academic  progress,  provide  personal  and  academic  advice  and  support,  process  event registrations, for identification and security purposes, and to allow us to fulfill our contractual obligation; To assist in event registrations and for any other purpose for which you provide us with your personal data.

Sharing Your Personal Information


For the purposes referred to in this privacy notice and relying on the bases for processing as set forth above, we may share your personal data with certain third parties in providing you the service. You are given the opportunity to opt-in to some of these data sharing agreements, where Ardor does not have a legitimate basis, or contractual purpose for sharing the data. Ardor will not share your personal data with third parties unless it is necessary for the legitimate interests of Ardor in providing you services, or where it is necessary for the purposes of entering into or carrying out a contract between you and Ardor. 

Any third parties that we may share your data with are obliged to keep your details secure, and to use them only to fulfill the service they provide you on our behalf. 

Retention period

Ardor will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will strive to keep your information accurate and up to date, and not keep it for longer than is necessary. 


Your rights as a data subject


At any point while Ardor is in possession of, or processing your personal data, you, the data subject, have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.

Right of portability – you have the right to have the data we hold about you transferred to another organization.


Right to object – you have the right to object to certain types of processing such as direct marketing. 

Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

Right to judicial review: if Ardor refuses your request under any of the above rights, we will provide you with a reason as to why. You have the right to complain as outlined below.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data. These rights differ depending upon the location within the world where information was created or shared. The erasure of your information may also be subject to Ardor’s Records Retention Policy. Should the data fall within one of the areas where Ardor is under a legal requirement to retain such data for a certain period, Ardor will retain that data in accordance with its legal obligations.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. Should Ardor determine that you are not entitled to exercise that right, we will provide you with the reason(s) for the denial.

Can I find out the personal data that Ardor holds about me?


Ardor at your request, can confirm what information we hold about you and how it is processed. If Ardor does hold personal data about you, you can request the following information:

The details of how and why your data is processed.


Contact details of the data protection officer, if applicable.


The purpose of the processing as well as the legal basis for processing.


If the processing is based on the legitimate interests of Ardor or a third party, information about those interests.

The categories of personal data collected, stored and processed.


Recipient(s) or categories of recipients that the data is/will be disclosed to.


If we intend to transfer the personal data to a third country or international organization, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. 

In other cases, we will ensure there are specific measures in place to secure your information. How long the data will be stored.


Details of your rights to correct, erase, restrict or object to such processing. 

Information about your right to withdraw consent at any time.

How to lodge a complaint with the supervisory authority.


Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

The source of personal data if it wasn’t collected directly from you.

Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

If you wish to exercise your right to access the data Ardor has about you, please contact GDPR compliance team at gdprcompliance@ardor.com 

 

What forms of Identification will I need to provide in order to access my data?

Where Ardor has reasonable doubts concerning the identity of the person making the request to exercise one of the enumerated individual rights above, Ardor may request the provision of additional information necessary to confirm the identity of the data subject making the request.

Ardor accepts the following forms of identification when attempting to confirm the identity of the data subject making the request:

Driver’s License

Passport

Original birth Certificate

 

Under what circumstances will Ardor contact me?

 

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure. Notwithstanding this, Ardor will contact you if we identify that a breach affecting your personal data has occurred.

Complaints


In the event that you wish to make a complaint about how your personal data is being processed by Ardor or authorized third parties, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Ardor’s GDPR Compliance Team at gdprcompliance@ardorlearning.com


Changes and amendments to this policy


From time to time, we may update or amend this GDPR Privacy Notice to reflect new or different privacy practices, without notice to you. However, if these changes are material, we will place a notice on our website and/or otherwise communicate this fact to you.