PRIVACY POLICY

Introduction

This policy applies to your use of:

•  Our Site is hosted on [https://www.entreviable.com] (the "Website" or "Site") which can be accessed via PC or Laptop or Tablet, once you have downloaded or streamed a copy of the Site onto your PC or Laptop or Tablet device ("Device").
•  Any of the services accessible through the Website ("Services"). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Website is not intended for children and we do not knowingly collect data relating to children without proper parental consent. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

 Important information and who we are

(ENTREVIABLE) is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).

Contact Details

Our full details are:

•  Full name of legal entity: 

DIGITAL ENTREBRENREURSHIP DEVELOPMENT PLATFORM LIMITED

•  Email address: 

inquiries@entreviable.com

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review, this version was last updated on November 9^th, 2022. It may change, amend and if it does, these changes will be posted on this page and, where appropriate, when you next visit the Website. The new policy may be displayed on-screen and you may be required to read and accept the changes/amendments to continue your use of the Website or the Services.

It is important that the personal date and/or corporate data of the subscriber if it is a company ("Personal Data") that we obtain from you is accurate and up to date. You should keep us informed if your Personal Data changes during our relationship with you.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

•  Identity Data.
•  Contact Data.
•  Financial Data.
•  Transaction Data.
•  Device Data.
•  Content Data.
•  Profile Data.
•  Audio Video Data.
•  Usage Data.
•  Marketing and Communications Data.
•  Location Data.

We explain these categories of data herein below.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Information We Collect

We will collect and process the following data about you:

• Information you provide to us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Website, or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you register to use the Website, subscribe to any of our Services, search for our Website Services, Website share data via social media functions, enter a competition, promotion, or survey, and when you report a problem with the Website or any of our Services, in addition, if you are a job applicant seeking employment via any of your Website Services If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit our Website we will automatically collect personal data including Device, Content, and Usage Data. We collect this data using cookies and other similar technologies.
• Location Data. We also use GPS technology and other location technologies to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data or Location Services in your setting ("Device Settings").

• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties (and public sources) as set our below:

Online Tracking

We may use cookies, web beacons, and similar tracking technologies to facilitate administration and navigation on the Services, to better understand and improve the Services, and to provide you with a customized online experience as below:

• Cookies. A cookie is a string of information that is sent to by a website and stored on your hard drive or temporarily in your computer's memory. We may employ cookie technology to help you move faster through our Services. We may employ cookie technology to estimate our total audience size and traffic and to help us improve the Services' experience by measuring which areas are of greatest interest to users. You can turn off the ability to receive any of these cookies by adjusting the browser in your computer, but you should note that if you do so, this materially affect the functionality of the Services and the information you can access through them. Information about prohibiting the collection of cookies is set out below.

• Prohibiting the collection of cookies. If you would like to prevent ENTREVIABLE from collecting cookies when you visit our Website, please update the privacy setting in you chosen web browser. You can directly control cookie acceptance from there:

• Web Beacons and Other Tracking Technologies. We also may use other technologies. For example, we may use technologies called beacons (or "pixels") that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular e-mail message, determine the time and date on which you viewed the web beacon, and the IP address of your device. We use web beacons for a variety of purposes, including to analyze the use of our Services and in conjunction with cookies.
• Do Not Track Signals. Some web browsers may transmit "do not track" signals to the websites and other services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not act in response to these signals. If and when a standard is established and accepted, we may revisit our policy on responding to these signals.
• Third Parties that Provide Content Functionality. Some of the content and functionality on our Services may be provided by third party service providers. When you use our Services, such third parties may collect or receive certain information about you and/or your use of the Services, including using cookies, beacons, and similar technologies. This information may be combined with information collected across different websites, online services, and other linked or associated devices. These third parties may use your information to improve their own services. However, we do not permit such parties that receive or collect your information in connection with their services to share or use your information for other purposes.

How we use you Information

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• We use your information to send it to the educational offerings that you select at one or more of our affiliated or managed educational entities. We may share information with other ENTREVIABLE entities or our affiliated or managed educational institutions if you apply for a job opening or have a customer inquiry about one of their services. Other uses include, for example, responding to transactional requests and delivering, analyzing, and improving our Website(s) and other Services.
• We use your information where you have consented before the processing.
• We use your information where we need to perform a contract or agreement we are about to enter or have entered with you.
• We may use your information we to determine which areas of the Services are most frequently visited to understand how to enhance the Services.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights to not override those interests.
• We may use your personal information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, our employees or agents, or other users and to comply with applicable law.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We may use your Identity, Contact, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We will obtain your explicit consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask for your consent to share your personal data with the third parties set out below for the purposes set out in the abovementioned table:

• External Third Parties.
• Third Parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

Data Security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or other requirements. 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.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use of disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax. Accounting or other requirements.

In some circumstances you can ask us to delete your data: below for further information.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances you have the following rights under the General Data Protection Regulation (GDPR) to access personal information that we process about you.

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about (if any) you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure in accordance with Data Protection Act 2018 of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• if you want us to establish the data's accuracy;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. You acknowledge and agree that if you withdraw your consent to access and process your personal data and to this privacy policy, we may not be able to provide certain products or services to you, and you will not be able to utilize the Application/Site for its intended purpose, and your account and profile may no longer be valid and we cannot verify your profile for consumption by third-party entities whom you wish to grant access to your record for any product/service you require. Under no circumstances will we be liable to you or to any person for any indirect, incidental, special, punitive, cover or consequential damages (including, without limitation, damages for lost profits, revenue, sales, goodwill, use of content, impact on business, business interruption, loss of anticipated savings, loss of business opportunity) resulting from withdrawing your consent.
• You also have the right to ask us not to continue to process your personal data for marketing purposes. 
• You can exercise any of these rights at any time by contacting us at [inquiries@entreviable.com]

Links to Other Web Sites

We may make content or services from other websites including our co-branded websites, other ENTREVIABLE affiliated websites or managed educational institutions, available to you from links located on the Website. These other websites are not subject to this Privacy Policy. We recommend that you review the Privacy Policy at each such website to determine how that site protects your privacy.

Transfer of Data Outside of Your Home Country

Your information may be stored, processed, and accessed in the United Kingdom or any other countries where ENTREVIABLE and our affiliates have facilities. By using the Services, you consent to the collection, transfer, storage, and processing of information outside your country.

If you are in the EU and applicable law specifies relevant legal grounds for processing personal, the legal grounds for our processing activities are to perform our contract(s) with you; to meet our legal obligations; and for our legitimate business purposes, including to improve our operation and Services and to detect and prevent fraud. We rely on your consent to send your personal information to our affiliated or managed educational institutions so that they may send you direct marketing messages about educational consent at any time. You may lodge a complaint with a supervisory authority if you consider that our processing of your personal information infringes applicable law.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed, and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us. 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

External third parties

Service providers acting as processors based in or outside the United Kingdom who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in who provide consultancy, banking, legal, insurance and accounting services.

Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances. Financial taxation, judicial authorities, state agencies.

Other parties we may share your data with, including the following

•     Organisations that introduce you to us (Such as UCAS, Recruitment Agencies)
•     External Examiners for examination, assessment and moderation purposes
•     Professional/Funding bodies and Student Loans company
•     Monitoring and Reporting Requirements Data reporting to third parties 
•     Other universities, employers, prospective employers, providers of training contracts or pupillages

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

Identity Data: includes first name, father’s name, grandfather’s name, last name, maiden name, username or similar identifier, password, marital status, residency status, family member data, title, date of birth, gender, disability declaration, criminal conviction declaration, all data provided/printed visually on government-issued identification documents. For corporate users and subscribers, it includes the full name of the company, its national number, registration number, address, authorized signatories, and a representative of the company as a point of contact.

Contact Data: includes physical address, mailing address, utility bill data, delivery address, email address and telephone numbers.

Financial Data: includes bank account, payment card details, specimen signature data, sources of income data, banking-related data.

Academic Data: includes data such as education and academic history, training records, qualifications, personal statements, CVs, personal achievements and references.

Employment Data: includes employer name, employer address and Contact Data, job title, salary and/or income, and employment status and type of employment. 

Transaction Data: includes details about payments to and from you and details of in-App purchases. 

Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.

Content Data: includes information stored on your Device, including login information, photos, videos or other digital content, check-ins, and any content provided to us using the Site.

Profile Data: includes your username and password, any data and/or documents provided to us using the Site, in-App purchase history, your interests, preferences, feedback, and survey responses.

Audio and Video Data: includes Liveness verification in audio-video authentication and photographic, audio and video data.

Usage Data: includes details of your use of our Site including, but not limited to, traffic data and other communication data, and account activity/actions made using the Site. 

Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

Location Data: includes your current location disclosed by GPS technology or any other technology, as well as your Contact Data.