Last Updated: June 2019
The University of Manchester, in association with Trilogy Education Services UK Limited, provides the Course as more fully described on the Site (defined below).
Particularly Important Information
Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is Trilogy Education Services UK Limited whose registered address is 3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT. Our data protection officer may be contacted at email@example.com.
Changes to this Policy: We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will post a notice on our Site prior to such changes(s) taking effect.
Purposes of Processing
What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation 2016/679; and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Site. If you created a profile/registered with us, you will have been asked to tick to agree to provide this information in order to view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Site.
Collecting Your Personal Data
We collect information about you in the following ways:
Information You Give Us. This includes when you:
Using the Site. If you post Personal Information in a comment or to a chat room, blog or other public area of the Site, we may collect the information you post. Posted information is also available for viewing and disclosure by other users of the Site, and we have no control over such use. We discourage posting sensitive or Personal Information in comments as they are viewable by the public.
Information We Get from Others. We may also get information about you from other sources, for example, where a third party facilitates your purchase of a course. We may add this to information we get from our Site.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site. For example, when you use the Site, we collect information such as IP address, location data, and anonymous usage statistics, by using cookies, server logs, and other similar technology. Please see the ‘Cookies’ section for further information.
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognise your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Strictly necessary cookies||These cookies are essential in order to enable you to move around the Site and use its features, such as accessing the secure areas of the Site. They also enable us to deliver services you have asked for.
Examples of strictly necessary cookies set by us are cookies that keep you logged in during your visit on the Site and that enable you to navigate between pages during a browser session so that you can use the Site most efficiently.
|Functionality Cookies||These cookies allow the Site to remember choices you make such as your user name when you login to your account or the language or region you are in. They may also be used to help you watch a video or comment on a blog and are intended to improve your online experience.
Examples of functionality cookies set by us are cookies that may serve a different version of the Site to you as compared to other users to determine which version works better, cookies that prevent you from seeing different homepages or other split tests in the future, and bookmarking cookies that help us retrieve and display information you stored on our Site for your next visit.
|Performance cookies||These cookies collect statistical information on how visitors use our Site so that we can make improvements to the Site, how it works and our services. These cookies do not collect information that identifies visitors. The information that is collected is aggregated and therefore anonymous.
Examples of performance cookies set by us are cookies that track website traffic and help us collect data about what users are doing on our Site so that we can improve our website and enhance your overall experience.
Examples of internet-based advertising cookies set by us are cookies that tell us where you came from so that we can evaluate marketing and advertising campaigns, cookies that help us determine where you are located so that we can serve you advertisements that are relevant to you based on your location and cookies that help us group you into interest groups with other users so that we can show you advertisements that are relevant to you while you’re on our Site and on other websites.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.
We do not serve Flash cookies but Adobe Flash Player may be used by third parties serving advertisements to the Site in cases where these advertisements are served with flash related content. It is not possible to block or restrict or block flash cookies using your browser setting, however information on how to do this is available from the Adobe website at: http://www.adobe.com/products/flashplayer/security.
These are small image files that may be placed by us or third parties in respect of your use of the Site or within the body of our newsletters so we or third parties can understand which parts of the Site are visited or whether particular content is of interest.
Generally. We may use other companies to serve third-party advertisements when you visit and use the Site. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.
Targeted Advertising. In order to serve offers and advertisements that may interest you, we may display targeted advertisements on the Site/Application(s)/Services, or other digital properties or applications in conjunction with our content based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide personal data to advertisers when you interact with an advertisement.
Your Ad Choices. Some of the third party services providers and/or advertisers may be members of the Network European Interactive Digital Advertising Alliance (“EDAA”) Self-Regulatory Program for Online Behavioural Advertising. To learn more, visit http://www.edaa.eu/edaa-for-users which provides information regarding targeted advertising and the “opt-out” procedures of EDAA members.
Mobile. We may, from time to time, offer certain location or pinpoint based services, such as location assisted navigation instruction. If you elect to use such location-based services, we must periodically receive your location in order to provide such location-based services to you. By using the location-based services, you authorise us to: (i) locate your hardware; (ii) record, compile and display your location; and (iii) publish your location to third parties designated by you by means of location publication controls available within the applications (for example, settings, user preferences). As part of the location-based services, we may also collect and store certain information about the users who elect to use such location-based services, such as a device ID. This information will be used to provide you the location-based services. We may use third-party providers to help provide such location-based services through mobile systems and we may make information available to such providers to enable them to provide their location-based services, provided that such third party providers may use the information only in accordance with this Policy.
Using Your Personal Data
We may use your personal data as follows:
Sharing Your Personal Data
We may share your personal data as follows:
When we use the term “anonymous data”, we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyse usage patterns in order to make improvements to our Site.
Third Party Sites
Our Site may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
User Generated Content
You may share personal data with us when you submit user generated content to our Site. Please note that any information you post or disclose on our Site will become public information, and will be available to other users of our Site and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on our Site. Such personal data and other information will not be private or confidential once it is published on our Site.
If you provide feedback to us, we may use and disclose such feedback on our Site, including your personal data..
International Data Transfer
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We seek to use reasonable organisational, technical and administrative measures to protect personal data within our organisation. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Information section below.
Data required to verify participation and performance in our programs will be retained indefinitely so that we may provide you with records of your completion of, and/or performance in, our programs upon your request. We will retain all other personal data we hold on you for three (3) years after the end of all programs in which you participate so that we may send you emails regarding other product offerings, including programs, unless a longer retention period is required or permitted by law (for example for regulatory purposes). In the event that you have opted out of receiving such emails, we will retain your personal data for three (3) years after the end of all programs in which you participate, to ensure that we record and respect your preferences and opt-out choices..
Our Policy on Children
Our Site is not directed to children under 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Information section below. We will delete such information from our files as soon as reasonably practicable.
Sensitive Personal Data
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site or otherwise to us.
If you send or disclose any sensitive personal data to us when you submit user generated content to our Site, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Site.
In order to perform the services, we may collect sensitive personal data as part of our video recordings of lectures. We will only do so with your consent. As per the ‘Your Rights’ section, you can opt-out of this processing at any time.
If you wish to exercise any of these rights, please contact us using the details in the Contact Information section below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: firstname.lastname@example.org. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
We welcome your comments or questions about this Policy. You may contact us in writing at email@example.com or 3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT.