Learnster

Privacy Policy

This privacy policy explains how we collect and use your personal data when you visit our website or use our services. It also describes your rights and how you can exercise them. We will only use the information in accordance with this privacy policy and the General Data Protection Regulation (EU 2016/679).

1. General

Learnster AB, reg.no. 559028-4369, (“Learnster”, “us”, “we” or “our”) respects and cares about your privacy. We want you to feel safe when we process your personal data. By way of this privacy policy (“Privacy Policy”), we want to inform you about how we ensure that your personal data is processed in correct manner and in accordance with applicable law, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

This Privacy Policy contains information about how Learnster, as the data controller, handle your personal data when visiting Learnster’s webpage, www.learnster.com and www.learnster.se (the “Webpage”), and as a current, prospective, or former customer of Learnster’s services or another business contact (“Customers”) as described within this Privacy Policy. We process your personal data in order to be able to provide our services to you in the best and most appropriate manner.

2. Data Controller

Learnster is the data controller for the processing of visitors to the Webpage and its Customer’s personal data. Thus, Learnster is responsible for ensuring that the processing is in compliance with applicable law. Please find our contact details at the bottom of this Privacy Policy.

In order to avoid any misunderstanding, Learnster is acting as a data processor in relation to the Customer’s users of Learnster’s services. Thus, the Customer will have to inform its data subjects of its processing of personal data through Learnster’s services.

3. Our processing of your personal data


3.1. WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS?
We process the following categories of your personal data:

Contact information: your name, phone number, email address and employer;

Usage data: cookie information, behaviour on the Webpage or in our services and platform and information you provide by filling our online forms (e.g., information about your role as an employee or employer);

User data: your name, phone number, email address, title, organisation, organisational affiliation, course history, test history, survey history, unit information and rating/assessment;

Device data: IP-number, internet connection, operating system, time zone, screen resolution, language settings, web browser settings and equipment used;

Technical data: technical information generated through your use of our Webpage and services, such as response times, location, dates and times of usage and any encountered errors or crashes;

Transaction data: information which is required for processing of a payment of your subscription to Learnster’s services, including purchased services or products, bank account information and invoicing details;

Communication data: information contained in your communications with us. For example, the information you provide to us in any support message or otherwise when you contact us;

3.2. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA
We process your personal data for the following purposes: 

– to analyse the use of our Webpage and platform;
– to administer and carry out our services towards you as Customer;
– to market our services;to improve and personalise our services to our users;
– to comply with legal obligations;
– to analyse risks to our IT environment or business;
– to communicate with you when you contact us for any reason;
– to establish and defend legal claims; and
– for administration in connection with an acquisition, restructuring, etc.

In the tables below, you are provided with more information about our processing of your personal data. 

3.2.1 To analyse the use of our Webpage and platform
We process your personal data for the following purposes: 

We process your personal data to conduct market and user analyses, for example by analysing statistics based on information gathered through our Webpage and platform. The results of our analyses are used to improve, develop, replace, and create new and existing services and to ensure an optimal user experience for our Customers and end users. For example, by way of analysing how end users interact with our Webpage and platform, we can improve our user interface to make it more intuitive and helpful, or create new features that increase the value of the content we deliver or improve quality of life when using our services, including the Webpage and our platform.

Categories of data
Legal basis
Retention time
Usage data
Device data
Technical data
Processing is necessary for the purposes of our legitimate interests to provide, improve and develop our Webpage and services. 
Your personal data is kept during the entire contract period and 12 months thereafter. After this period, your data is aggregated in such a way that identification is no longer possible, and no personal data remains.For more information regarding our retention time for cookies, please see Learnster’s Cookie Policy.

3.2.2 To administer and carry out our services towards Customers 
We process personal data to administer our relationship with our Customers, including storing preferred contact persons, sending information in an electronic format (not marketing) and storing any potential agreements and to process payments. 

Categories of personal data
Legal basis
Retention time
Contact information
Transaction data
User data
Technical data
Device data
Processing is necessary for the purposes of performing the contract with our Customers and to receive payments for our services.
Personal data contained in receipts, order confirmations, agreements, or otherwise  relating to transactions will be kept for 7 years in accordance with the Swedish accounting act.Personal data relating to communications, preferred contact persons and other actions needed in order to administer our relation with and provide our service to our Customers are kept during the entire contract period and 12 months thereafter. We may keep your personal data for a longer time period if necessary to establish, exercise or defend a legal claim in case of a dispute regarding e.g. payment.

If you are an employee of our Customers, some of your personal data (professional contact information) may also be processed in connection with our processing of the customer relation with your employer.

Categories of personal data
Legal basis
Retention time
User Data
Processing is necessary for our legitimate interest to efficiently conduct our business and our Customer's (your employer's) legitimate interest to use our services in order to efficiently operate its business. 
Same as above.

3.2.3 To market our services
We process your personal data to market Learnster and our services. We may use your personal data to e.g. send our newsletter. The purpose of our marketing measures is to send you direct advertisements as well as to contact you with information about our services. We also process your personal data in order to provide relevant and tailored communication to you and to market our services through social media channels, e.g. Facebook. The marketing through social media may be targeted. In order to do so, we need to understand what services you would be interested in receiving more information regarding. Hence, we will register which services you have viewed on our Webpage and use this information in order to provide you with marketing based on the services you have shown interest for by viewing them on our Webpage.

Categories of personal data
Legal basis
Retention time
Contact information
Usage data
Device data
Technical data
Communication data 
Processing is necessary for the purposes of our legitimate interest to be able to market our services. 
Your personal data is kept for a period of 12 months from the date the personal data was collected or from the date when you last came in contact with us, whichever occurs later.
You can easily opt-out from direct marketing by contacting us as further described in section 8.3. Please see our contact information under section 12 in this Privacy Policy.
For information regarding our retention time for cookies, please see Learnster’s Cookie Policy.

3.2.4 To improve and personalise our services to our users
We process your personal data in order to improve and personalize our services. Based on information gathered through your use of our services and their content, we can analyze end user patterns. For example, by studying what content is the most appreciated or how end users navigate our services, we can improve the content we provide and how we provide it.

Categories of personal data
Legal basis
Retention time
User data
Usage data
Device data
Technical data
Processing is necessary for the purposes of our legitimate interests to provide and develop our Webpage and services. 
Your personal data is kept during the entire contract period and 12 months thereafter.
For information regarding our retention time for cookies, please see Learnster’s Cookie Policy.

3.2.5 To comply with legal obligations
We process your personal data to verify your individual identity when you contact us for example to exercise your rights as a data subject.

We also process your personal data when that is necessary to comply with our legal obligations under applicable law, e.g. legislation regarding accounting, audit, and tax. 

Categories of personal data
Legal basis
Retention time
Contact information
User data
Transaction data 
We need to process your personal data to comply with our legal obligations under applicable legislation.
Your personal data is kept for as long as necessary to comply with applicable legal obligation. For example: 
Personal data relating to transactions are stored for 7 years according to the accounting act; or
Personal data processed in order to verify your identity when you contact us to exercise your rights as a data subject are stored for the duration of your matter and then will then be erased depending in connection with your matters.
We may keep your personal data for a longer time period if necessary to establish, exercise or defend a legal claim in case of a dispute regarding e.g. payment.

3.2.6 To analyse risks to our IT environment or business
We process your personal data

Categories of personal data
Legal basis
Retention time
Contact information
User data
Usage data
Device data
Technical data
Transaction data
Communication data
Processing is necessary for the purposes of our legitimate interest of securing our IT and business environment. 
Your personal data is kept during the entire contract period and 12 months thereafter. After this period, your data is aggregated in such a way that identification is no longer possible, and no personal data remains.
We may keep your personal data for a longer time period if necessary to establish, exercise or defend a legal claim in case of a dispute.

3.2.7 To communicate with you when you contact us
We process your personal data when you contact us through any means (e.g., phone, email, social media or by letter). We process your data in order to store and answer your communication, for example general questions or when you contact us in order to receive support.

Categories of personal data
Legal basis
Retention time
Contact information
User data
Usage data
Device data
Technical data
Communication data
Processing is necessary for the purposes of our legitimate interest to handle and answer your communication.
Your personal data and communication are stored and processed for as long as is necessary based on the matter and content of your communication, and for a period of 12 months thereafter. Whereafter your personal data are erased, but we may retain certain aggregated or statistical information, for example relating to the reason for your communication. 
We may keep your personal data for a longer time period if necessary to establish, exercise or defend a legal claim in case of a dispute.

3.2.8 To establish and defend legal claims 
In case of dispute, we are entitled to process your data to establish, exercise or defend the legal claim.

Categories of personal data
Legal basis
Retention time
Contact information
User data
Usage data
Device data
Technical data
Transaction data
Communication data
Processing is necessary for the purposes of our legitimate interest of the establishment, exercise or defence of legal claims. 
Your personal data is kept for as long as necessary in order for Learnster to establish and defend legal claims. 

3.2.9 For administration in connection with an acquisition, restructuring, etc
In case of a merger, divestiture, restricting, reorganization, dissolution or other sale or transfer of Learnster’s assets, we may need to process your personal data in order to enable such transfer.

Categories of personal data
Legal basis
Retention time
All of the above. 
The processing is necessary for the purposes of our legitimate interest of enabling mergers, divestitures, restructuring, reorganization, dissolution and other sale or transfers of Learnster’s assets, which we assess overrides your interest in data protection of your personal data. 
Your personal data will be processed for as long as necessary in order to fulfil the purpose with the processing.
Personal data that is transferred to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Learnster’s assets will not be stored by Learnster after such transfer unless required to fulfill any of the other purposes set out above. 
4. Where we collect your personal data from

The personal data we process about you is the information you have provided us as well as information we have gathered or has been provided to us from other sources. We may have obtained your contact data from a third party marketing lead provider.  

5. Automated decision-making

We do not use automated decision-making in our business in a manner that would have a meaningful effect on you.

6. With whom do we share your personal data?

We may share personal data with third parties that are trusted recipients. Such sharing is based on our business relationship with the third parties, your consent or legal or contractual obligations. We strive to ensure that your personal data is always processed in accordance with this Privacy Policy. With whom we may share your personal and the categories of personal data shared are specified in the table below:

We may share your personal data with
Categories of personal data shared
Third party providers, such as IT-suppliers used for business systems and case management and subcontractors.
Contact information
User data
Usage data
Device data
Technical data
Transaction data
Communication data 
A buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of Learnster’s assets.
All of the above.
Social media providers, such as Facebook and LinkedIn. We kindly refer to the policy of each service provider for information about their processing of personal data. 
Contact information
Usage data
Device data
Technical data
Communication data 

We may also in certain cases be required to share your personal data with public authorities or other third parties in connection with audits, court proceedings or similar reasons. 

We will not sell your personal data to any third party. 

7. Where do we process your personal data?

Learnster aim at processing your personal data within EU/EEA. In some cases, we transfer your personal data to countries outside of the EU/EEA. When personal data is transferred outside of the EU/EEA, we have taken measures to ensure that your personal data is protected and that the transfer is carried out in accordance with applicable law. More specifically, when carrying out any transfer to a country that lacks an adequacy decision by the European Commission, we will use the European Commission’s Standard Contractual Clauses as legal basis for the transfer. In addition, we ensure, and also expect our data processors to ensure, as required by legislation, that your personal data remain protected regardless of whether they are transferred outside the EU/EEA.

The countries outside of the EU/EEA to which Learnster transfer your personal data and the legal basis for the transfer are specified in the table below.

Country outside of the EU/EEA
Legal basis for the transfer
Ukraine
Standard Contractual Clauses

For more information on the legal basis for a specific transfer or to request a copy of the relevant documentation regarding the safeguards taken for the transfer, please contact us through our contact information stated in section 12 below.

8. Your rights

8.1 Our responsibility for your rights
Learnster is in its capacity of data controller responsible for ensuring that you can exercise your rights and that your personal data is processed in accordance with applicable law. You may at any time contact us to exercise your rights. Your will find our contact details in section 12 below. Learnster is responsible for responding to your request to exercise your rights within one month from our receipt of your request. We are entitled to extend this period by two months when necessary, taking into account the complexity of your request or if we have received a large number of requests. We will inform you of any such extension within one month or receipt of your request, together with the reasons for the delay and information about your right to lodge a complaint with a supervisory authority. All information and communication, and all actions we carry out, is at no cost for you. If the action you request is manifestly unfounded or excessive, we are entitled to charge you an administrative fee to provide you with the requested information or carry out the requested action or refuse to meet your request. 

8.2 Your right to access, rectification, erasure and restriction of processing
You have right to request: 
a) Access to your personal data. This means that you have the right to request information on our use of your personal data. You also have the right to request a copy of the personal data being processed by us, at no cost. However, we may provide you with the information in a commonly used electronic format. The copy of your personal data will be sent to your registered address.

b) Rectification of your personal data. We will at your request, or at our own initiative, rectify, anonymise, erase or complement personal data that you or we discover is inaccurate, incomplete or misleading. You also have the right to complete the personal data with additional data if relevant information is missing.

c) Erasure of your personal data. You have the right to request that we erase your personal data if we no longer have an acceptable reason for processing the data. Such acceptable reasons for processing the data are if the processing is necessary:
(i) in order for us to comply with a legal obligation;
(ii) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes;
(iii) for the establishment, exercise or defense of legal claims. 

Given this, erasure shall be made by us if none of the above applies and if:
(i) the personal data is no longer necessary for the purposes for which it was collected;
(ii) we use your personal data with your consent, and you withdraw your consent;
(iii) you object to the processing of your personal data based on our legitimate interest and there is no overriding legitimate ground for the processing;
(iv) the personal data has not been lawfully processed; or
(v) we are required to erase the personal data due to a legal obligation.
However, there might be requirements under applicable law, or other compelling reasons, that prevents us from immediately erase your personal data. In such case, we will stop using your personal data for any other reasons than to comply with the applicable law, or the relevant compelling reason.

d) Right to restrict processing. This means that we temporarily restrict the processing of your personal data and that we must inform you before the restriction of processing is lifted. You have the right to request restriction of the processing when:
(i) you have requested rectification of your personal data in accordance with section 8.2 b) above, during the period of time we are verifying the accuracy of the data;
(ii) the processing is unlawful and you do not want the personal data to be erased;
(iii) Learnster, in its capacity as data controller, does no longer need the personal data for the purposes for which it was collected, but you require us to retain the information for the establishment, exercise or defense of a legal claim; or 
(iv) you have objected to our legitimate interest for the processing in accordance with section 8.3 below, during the time we determine whether our legitimate interest overrides your privacy rights. 

At Learnster, we will take all reasonable and possible actions to notify any recipients of your personal data regarding any rectification, erasure or restrictions carried out by us in accordance with this section 8.2. At your request, we will also inform you of which third parties we have shared your personal data with.

8.3 Your right to object to the processing 
You have the right to object to the processing of your personal data when such processing is made with a legitimate interest as the legal basis (please see section 3 above). If you object to such processing, we will only continue with the processing if we have a compelling legitimate reason for the processing that outweighs your interests, rights or freedoms, or if continued processing is necessary for the establishment, exercise or defense of a legal claim.

You always have the right to object to the processing of personal data when such processing is made for direct marketing purposes. If you object to such processing, we will no longer process the personal data for such purposes. 

8.4 Your right to withdraw your consent 
If we need your consent in order to process your personal data, you always have the right to withdraw such consent at any time by contacting us. You will find our contact details at the end of this Privacy Policy. 

8.5 Your right to data portability 
According to the GDPR, you have right to data portability which entails that you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to directly transmit those data from us to another controller, when technically feasible. Your right to data portability is applicable when we process your personal data on the basis of consent or performance of contract and when the processing is carried out by automated means. The right to data portability entails in practice that you for example have the right to receive and transfer the personal data you have given to us when you created a user account on our Webpage. 

8.6 Your right to lodge a complaint with the supervisory authority 
You have the right to lodge a complaint regarding our processing of your personal data with the supervisory authority. The competent supervisory authority in Sweden is Integritetsskyddsmyndigheten, IMY. 

9. We protect your personal data

We want you to feel safe when providing us with your personal data. Therefore, Learnster has implemented appropriate security measures to protect your personal data against unauthorized access, alteration and erasure. In the case of security breach that may significantly affect you or your personal data, e.g. when there is a risk of fraud or identity theft, we will contact you and inform you of what you can do to reduce the risk. 

10. Cookies

Learnster uses cookies. Learnster collects data through cookies in order to be able to analyze the usage statistic on our Webpage, to improve our services and to be able to provide our services. In our Cookie Policy, we provide you with more detailed information on how we use cookies. You will find the Cookie Policy.

11. Amendments to this Privacy Policy

Learnster has the right to amend this Privacy Policy at any time. The latest version will always be available on our Webpage.

Learnster will inform you of any changes to the Privacy Policy with reasonable prior notice. If you do not consent to these changes, you have the right to object to the processing before the changed Privacy Policy enters into effect. 

12. Contact information

Do not hesitate to contact us at Learnster if you have any questions regarding this Privacy Policy, our processing of your personal data, or if you want to exercise your rights.
E-mail: support@learnster.com
Webpage: www.learnster.com
Address: Torsgatan 26, 113 21 Stockholm

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