The purpose of this statement is to explain to you what personal information we collect and how we may use it. Highland Learning Academy Ltd referred to as “HLA” in this statement.
1. About Us
This website https://hla.scot. is owned and operated by Highland Learning Academy Ltd, a company registered in Scotland no. SC456515, having its registered offices at Morrich House Davidson Drive, Castle Avenue Industrial Estate, Invergordon, Scotland, IV18 0SA
HLA is committed to protecting your privacy and maintaining the security of any personal information received from you. We strictly adhere to the requirements of the data protection legislation in the UK, including the General Data Protection Regulation 2016 and the Data Protection Act 2018.
2. Definitions
Unless the context otherwise requires, in this Agreement the following expressions shall have the meanings set out below:-
“Affiliate” means organisations which we partner, work or associate with.
3. The Data Protection Officer (DPO)
Due to the type of data we collect and the nature of our business we currently have no legal requirement to have a DPO at HLA.
4. Information we collect about You and How we use it
When you register on our website, take part in a competition or place an order, we may collect your personal details which may include name, address, email address, phone number and other personal information that we will use to identify you, your order details and payment information. This allows us to process and manage your registration as well as process your order and provide you with the goods or service chosen.
We do not collect sensitive information (also known as special categories of information) about you except when you specifically knowingly provide it and have consented to this. Examples are allergies in a situation where food maybe provided or a disability so we can ensure a venue can facilitate access.
We obtain some information from google analytics which is anonymous and other social media platforms for example Facebook. The social media information provided is limited and only that which you have previously agreed with them that they can share.
5. What we do with your Information
We will use your personal information for a number of purposes including
• To process your orders and provide our services to provide you with information about them and to deal with your requests and queries.
• For administration purposes which means we may contact you for reason related to goods or services you have signed up for.
• To provide personalised communications.
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• For analysis and research to improve our services and goods offered.
• We may use and disclose information in aggregate (so no individuals are identified) for marketing and strategic development purposes.
6. What if I don’t provide some or all of the information requested?
The impact of this will depend on what information you withhold but the main impacts may be:
• We may not be able to process or fully process your order.
• We may not be able to contact you to let you know of problems regarding your order or the goods/services provided.
• We may not be able to respond fully to requests and queries you may have.
Withholding marketing consent. You are free to do this at any time. It will only stop you receiving marketing. It will not impact any other service/goods we provide you with.
7. Will You be contacted for Marketing Purposes?
We use your personal information to update you about new products/services by post, email and SMS text message. We will only contact you with your consent. You will provide this either when you fill in a form to provide your data.
8. What grounds (legal basis) are we processing the data under?
There are a number of grounds we process your data under. These are
• Contractual – we need the information to perform the contract for goods or services you have requested/ordered including payment, delivery etc.
• Legal – should we be legally required to contact you concerning a product e.g. a product recall.
• Legitimate interest – this means the processing is in HLA’s interest. It allows us to manage the customer relationship effectively and efficiently and improve the goods and/or services we provide by better understanding how our online provisions are used and which goods are popular with which groups of individuals.
• Consent – where you have given us consent to market to you.
9. Sharing your Information with Third Parties
We may from time to time provide your personal information to third parties for the purposes of providing you with our goods and services. These third party providers include payment processors, providers of card validation services, credit referencing providers, third party sales processor (includes fulfilment services) and service providers who assist us with hosting our marketing campaigns. They do not decide what is done with your data and only process it on our behalf. These third parties may be located outside the European Economic Area; however we only use providers that provide adequate protection for your information at all times.
10. When transferring any personal information outwith the EEA we only do so under one of the legally recognised transfer mechanisms for ensuring the data is safeguarded. These are:
• The country in question has been deemed safe for data transfer by the European Commission. Also known as an adequacy finding.
• The contract for data processing contains the standard contractual clauses laid down by the European Commission to safeguard the transfer of personal data.
• Binding corporate rules – this is where a large company’s own internal processes for international data transfer have been signed-off and agreed by the European Commission as safeguarding the data.
• If the data is going to the USA it can be safely transferred to a company that is certified under the EU-US Privacy Shield.
• Appropriate certification schemes
11.We will not for provide your data to other third parties for marketing purposes unless you have specifically consented to this when you first provided your data to us.
12. Currently we do not have the ability to react to “do not track” being set in the browser, if you wish to opt out of tracking we suggest downloading an ad blocking technology such as Ghostery.
13. What if I am aged under 16?
We will need to obtain consent from your parent/guardian before you can use some of our services. If we don’t receive consent from your parent/guardian in the time indicated we will delete your information.
14. How we Protect your Information
We follow strict security procedures in the storage, use and disclosure of information which you have given us, to prevent unauthorised access to, and loss, misuse or alteration of your personal information in accordance with the UK data protection legislation. These include access control, firewalls and virus checking procedures.
You are responsible for keeping any confidential passwords or other login or access details which you select or which we allocate to you secret. Whilst we take steps to ensure the security of your information, there is a risk that any information transmitted over the Internet and stored on a computer may be intercepted or accessed by an unauthorised party.
We also recommend that if you use a shared computer or a computer in a public place such as a library that you close your browser when you have finished you session
15. How long we hold your Data for
Some of the information you provide to us is necessary to carry out repeated tasks, such as verifying your identity when signing in to use an account or providing our goods and services to you or you using an online checkout. We will keep this information for as long as you remain a registered user of any of our sites or an active customer plus a reasonable time (approximately 18 months) beyond this to deal with queries or issues.
Some information may be required for longer periods such as financial information for HMRC purposes, usually a maximum of 7 years.
HLA does not retain your payment card information. It is keyed directly into the payment processor’s system when you provide it.
16. Your rights regarding your Personal Information
Under the Data Protection law you have a number of rights with respect to your personal information which are:
• Correcting your Information
You are entitled to have your personal information updated to ensure it is up-to-date and accurate. This can be done by following the instructions below.
• Withdrawing Consent
You have the right to withdraw your consent to any processing that is currently being done under your consent e.g. marketing.
You can also follow the process below.
• Obtaining a copy of your Information
You are entitled to receive a copy of the personal information we hold about you.
• Deleting your information
You can request that we delete personal information in certain circumstances. These will be specific to each case.
• Data Portability
• You are entitled to have us transfer to another controller the personal information that you have provided us with.
• Restricting Processing
You can request a restriction on the processing of your data in some limited circumstances. Examples are concerns over data accuracy or we no longer require to hold your data but you have requested its retention by us to aid you in a legal matter.
• Right to object to processing
You are entitled to request that we stop processing your data for marketing purposes and in other limited circumstances such as asking us not to process your data by wholly automated means or not to analyse your information for targeted content etc. (also known as profiling).
17. Sale of the Business
Should all or part of the business be sold to or taken over by another organisation, your personal information may move to that other organisation as part of the sale or takeover agreement.
18. Right of complaint to the Regulator for Data Protection
The data protection laws in the UK are regulated and enforced by the Information Commissioner’s Office (ICO). Each individual has the right to raise a concern/complaint to the ICO if they have any concerns about how their personal information and/or privacy is treated. You can do this via
The ICO’s website (https://ico.org.uk/concerns ), follow the links or have an online Live Chat
Call the ICO helpline on 0303 123 1113
Email casework@ico.org.uk
Postal address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
19. Links to Third Party Websites
Our website may contains links to other websites belonging to third parties which are not covered by this privacy policy. If you want to click through to a third party website, please make sure that you read the privacy policy for that website.
20. Updates to this Policy
We may update this Policy at any time without notice. We will tell you that we have updated the policy by emailing you at the email address you have provided to us and/or by posting an announcement on the website. By continuing to use the website after we have emailed you or posted a notice informing you of an update, you accept the changes to this Policy.
21. Contacting Us
If you have any questions about privacy, or wish to update your details or action any of your other data rights at any time, please contact us using info@highlandlearningacademy.co.uk
Privacy Statement 03/06/2019
