PRIVACY POLICY & DATA PROTECTION

1. About VLE

VLE is an innovative virtual learning platform that supports users unique needs and brings virtual on-demand learning courses designed by experienced education practitioners who are committed to providing highest-quality quality training and education services. You may buy, enrol, access and complete a Course on VLE for which we may collect obtain, store and use information about you. VLE platform is owned and operated by Upskill Online Limited trading as Olive Media (referred to as “VLE” “we”, “our” or “us”). We care about your privacy. This Policy, which applies to the VLE platform, vle.olivegroup.io (“Site”), (together with our VLE Terms of Use and any other documents referred to in the Site) explains how we collect and use your information. Please read it carefully. For questions about this Policy, or if you want to enforce your rights: please contact Olive’s Privacy Officer, at compliance@olivegroup.io.

2. Who we are

Upskill Online Limited is a limited company incorporated in Ireland with company number 470792, whose registered office is at Glasshouse 1, Dun Laoghaire, Harbour Court, George’s Place, Dun Laoghaire, A96 P0A4 Co. Dublin, Ireland. For the purpose of applicable data protection laws Olive forms part of the data protection regime in the Ireland and the Data Protection Act 2018 (DPA 2018) and EU General Data Protection Regulation 2016/679 applies to the processing of personal data wholly or partly by automated means and to the processing your Personal Information collected through the Site.

2.2 Definitions

2.2.1 “Personal Information” in this Policy means “Personal Data”; as defined in the EU General Data Protection Regulation 2016/679(EU). In summary, it means information that identifies you, whether directly or indirectly, including for example your name, gender, address, email address, phone number and any other information that you may voluntarily submit to us, as well as any online identifiers such as your click stream data or IP address.

2.2.2 “Data Protection Laws” means the data protection and information privacy laws of Ireland and the European Union and includes any legislation in force from time to time which implements Directive 95/46/EC or Directive 2002/58/EC of the European Community, the Data Protection Acts 1988 and 2003 (as amended), and once applicable the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and/or any corresponding or equivalent Irish laws or regulations, once in force and applicable.

2.2.3 “Data Processing” refers to any action performed on Personal Data, such as collecting, recording, organizing, storing, transferring, modifying, using, disclosing, uploading or deleting.

2.2.4 “General Data Protection Regulation” means Regulation (EU) 2016/679, known as the General Data Protection Regulation (the “GDPR”).

2.2.5 “Special Categories of Data” has the meaning as set out in Data Protection Laws.

2.2.6 “‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

3. When do we collect information about you?

We collect Personal Information when you visit our platform or site, when you enrol for a Course and register get access to VLE Platform, when you email, call or write to us, or provide us with information in any other way, including by interacting with us via social media such as Facebook or Twitter. We also collect information when you take a Course or otherwise, use our apps, or if your company has provided your details to us to enable us to provide you with access to and use our courses or apps. All the information collected in the local storage of about you is deleted when you logout from the application.

4. Consent

Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us at compliance@olivegroup.io.

5. What types of personal information do we collect and process?

5.1 Each time you visit a Site we may automatically gather the following information:

5.1.1 technical information about your computer such as domain name, browser type and version, operating system and platform, IP address, cookie information and time zone setting; and Following are the information we store in the local storage for logged in user:

• First and Last Name

• Email Address

• User Authentication token from backend servers

• Member ID

• Profile pic url

• mobile number

• Information of client under which user is logged in:

 Client Name

 Client domain

 Client ID

 Client logo url

5.1.2 information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time), what web pages you visited on the Site and how long you spend on each page, page interaction information (such as scrolling, clicks and mouse-overs), page response times, download errors, traffic data, location data, weblogs, history of resources accessed on the Site, methods used to browse away from the page and information on what website you visited before accessing the Site.

5.2 We process the following kinds of personal information if you provide it to us, or if your company provides it to us, or if it comes into existence by virtue of you taking a Course:

5.2.1 Information about you, including your name, job title, address, email and other contact details;

5.2. 2 Information about the company you are associated with;

5.2.3 Information about your use of our mobile applications, including information about which pages you view;

5.2.4 Information concerning your progress in taking a Course including information concerning your performance in assessments and where appropriate, your entitlement to a certificate;

5.2.5 Information you provide to us during communications you have with us and with our staff, for example comments or queries about the courses we provide.

5.2.6 Information about the course or about the content that you provide, such as the location of the person or the date on which you posted a photo or created an event, what you see through features that we provide, so we can do things such as propose masks and filters that you might like, or give you guidelines on using the same.

5.2.7 We also process the following kinds of personal information if you provide it to us, or if your company provides it to us, or if it comes into existence by virtue of you taking a Course: 1) Information about you, including your name, job title, address, email and other contact details; 2) Information about the company you are associated with; 3) Information concerning your progress in taking a Course including information concerning your performance in assessments and where appropriate, your entitlement to a certificate; 4) Information you provide to us during communications you have with us and with our staff, for example comments or queries about the courses we provide. 5) Information about the course or about the content that you provide, such as the location of the person or the date on which you posted a photo or created an event, what you see through features that we provide, so we can do things such as propose masks and filters that you might like, or give you guidelines on using the same. 6) VLE shall have the right to access the outlook calendar of the Teams User who set up a video classroom using VLE.

6. Why do we collect and use your Personal Information, and what are our lawful grounds for doing so?

6.1 We use your Personal Information for the following purposes:

6.1.1 To process and respond to requests, enquiries and complaints received by you, in accordance with our legitimate interest to provide you with a responsive service.

6.1.2 To track your progress through a Course, to assess your performance in assessments and to determine whether you have reached the standard which is required if you are to earn a certificate.

6.1.3 To provide services and products requested by you. We do this as necessary to carry out our legitimate interest to operate a business which offers training courses.

6.1.4 To communicate with you about services and/or products provided to you. We do this as necessary to carry out our legitimate interest to operate a business which offers training courses.

6.1.5 To update our records and for audit purposes, in accordance with our legitimate interest to operate a business which offers training courses.

6.1.6 To prevent or detect fraud, in accordance with our legitimate interest to do so.

6.1.7 Where legally required or where it is in our legitimate interest to do so, to comply with requests from law enforcement and regulatory authorities.

6.1.8 To analyse trends and profiles, for our legitimate interest to aim, to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.

6.1.9 To carry out customer satisfaction research, for our legitimate interest to aim to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.

6.1.10 If you make enquiries through a Site and agree in the contact form to receive email updates we will send you such updates on the grounds of your consent.

6.1.11 To enable third parties to carry out any of the purposes set out above on our behalf. For this we use our legitimate interest to run our business as efficiently as possible.

6.1.12 To create personalized services with clear recommendations and suggestions that are unique and relevant to users, we use users preferences, interests and activities based on the data that we collect and learn from users.

6.1.13 To communicate with users about our services and let users know about the Policies and Terms as well as to respond to users when the user contacts us.

6.2 The legal basis on which we collect, process and transfer your information in the manner described above are:

(i) your consent (where we have sought it and you have provided it to us), and in which case, you can withdraw your consent at any time;

(ii) where any such processing is necessary for the performance of a contract with us; and

(iii) our legitimate interests in conducting our business in a responsible and commercially prudent manner.

(iv) Our legitimate interest in maintaining a business relationship and communicating with you, as a business contact, about our courses, events and providing you with information about new developments.

6.3 Where we store your Personal Information

The personal information we collect from you is stored securely in servers in the EU region.

7. How long do we keep your Personal Information?

7.1 We hold your Personal Information for as long as we need to for legitimate legal or business reasons, including complying with any regulatory obligations. Personal Information collected through a application may be kept as follows:

7.1.1 The Analytics Companies keep anonymised information concerning your visits to the application on their servers, in accordance with their respective privacy policies.

7.2 We will keep your information for at least as long as our relationship with you is active, and for any further period as required by our retention policy.

7.3 If you would like more detailed information about our retention policy, please email us at compliance@olivegroup.io or use one of the other methods in the “Contact us” section below.

8. Disclosure of your Personal Information

8.1 We may disclose your Personal Information to companies within our corporate group. We will not share Personal Information collected through our Site with unrelated third parties, except as provided in this Policy.

8.2 We may disclose to your employer details concerning your progress in taking the Course, up to and including the award of a certificate.

8.3 We may disclose your Personal Information to competent regulatory authorities and bodies as requested or required by law.

8.4 If we sell all or any part of our business, the parties which buy it may have access to your Personal Information.

8.5 We also provide information and content to research partners and academies to conduct research and support innovation as well as promote our business and these parties are not authorised to keep or use your Personal Information for any other purpose.

8.6 We may disclose the data to third parties who we engage to provide services to us in connection with this website, such as outsourced service providers, IT services providers, professional advisers, and auditors.

9. Controlling your Personal Information

You have the right to ask us not to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your Personal Information, by clicking “unsubscribe” in any of our marketing emails to you, or by contacting our Privacy Officer at any time at compliance@olivegroup.io.

We at VLE do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the definition of Sensitive Personal Information under clause 2.2 above.

10. Security

We aim to ensure that your Personal Information is secure. In order to prevent unauthorised access or disclosure, we have appropriate physical, technical and organizational measures to safeguard and secure the Personal Information we collect. Our service providers are required to do the same. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information once we receive it, we cannot guarantee the security of your data transmitted to a Site; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and use leading technologies and encryption software to safeguard your data, and keep strict security standards to prevent any unauthorized access.

10.1 While using some third parties services for the purpose of payment processing, research or statistical data analysis, some personal information may be transferred to those third parties. We remain responsible for your information when shared with third parties, and shall instruct such third parties to abide by the GDPR rules.

10.2 All private information like User’s e-mail address, access log-in can be accessed only by providing User’s password.

11. Cookies

Each Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse a Site and also allows us to improve the Site. Providing us with your Personal Information is always your choice. However, your decision not to provide certain information may limit our ability to provide you with our complete services. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy linked at clause 10 above.

12. Links to other Website

A Site may contain links to the website of other companies and organisations which may be of interest (“Third Party Site”). If you decide to leave the Site and access the Third-Party Sites or to use or install any Third-Party Applications, Software or Content, you do so at your own risk and you should be aware that our terms and policies no longer govern. You should review the applicable terms and policies, including privacy and data gathering practices, of any site to which you navigate from the Site or relating to any applications you use or install from the site.

13. Your rights and how to update your information

You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

13.1 The right to be informed about the processing of your personal data;

13.2 The right to access your personal data;

13.3 The right to rectification of your personal data;

13.4 The right to erasure of your personal data;

13.5 The right to data portability;

13.6 The right to object to processing of your personal data;

13.7 The right to restrict processing of your personal data.

13.8 The right to request access to your information and information related to our use and processing of your information;

13.9 The right to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In order to exercise any of the rights set out above, or if you have any questions about how we process your personal data, you can email us at compliance@olivegroup.io or write to us at Glasshouse 1, Dun Laoghaire , Harbour Court, George’s Place, Dun Laoghaire, A96 P0A4 County Dublin. Please note that the limitation or deletion of your personal data may mean that we will be unable to provide you with the communications and/or invitations described above.

We are required to keep all personal data accurate and up to date. To assist us in doing so, we ask you to contact your usual business contact at Olive Group or email compliance@olivegroup.io with any relevant changes, such as change of address or contact telephone numbers.

14. Access to your Personal Information, deletion, restriction, rectification, and transfer

You have the right to request details and a copy of the Personal Information we hold about you and to ask us to delete, restrict, stop using, correct, rectify or transfer (port) your Personal Information. Our response to your requests may depend on which legal grounds we are using to process the data in question (see section above). For more information about your rights under the EU General Data Protection Regulation 2016/679 &680 please see the EU Directives given effect in Ireland by the Data Protection Act 2018 in Ireland. You can exercise your rights by sending us a written request using our by email at compliance@olivemedia.co; by post at Glasshouse 1, Dun Laoghaire , Harbour Court, George’s Place, Dun Laoghaire, A96 P0A4 Co. Dublin, Ireland. With each request please include identification information (a copy of your passport or driving licence and a recent utility bill). Please be as specific as possible in your request about your requirements, so that we can respond to you as quickly as possible.

15. Complaints to the ICO

If you are unhappy with us, our service, or with the way that we treat your Personal Information, please contact us. You also have the right to contact the Irish Data Protection Commission by emailing info@dataprotection.ie or by telephone at 1890 252 231. However, we would appreciate it if you would contact us first so that we can endeavour to resolve any issues that you might have. Our contact details are set out below.

16. Unsubscribe

If you no longer wish to receive further marketing communications and/or invitations from us, you can unsubscribe at any time by emailing us at compliance@olivegroup.io.

17. Disclosure of your information to third parties

We disclose your information to third parties, only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights. We will not sell your Personal Information collected through the application with any third party.

18. Data Retention Policy

It is the responsibility of the Olive Group to take all precautions necessary to secure proprietary information and to prevent unauthorised access to the data. The management of OLIVE GROUP is dedicated to mitigating the risks associated with data breaches.

18.1. Data Retention Period

General Data:General Data: We will retain all client-related data for a standard period of 6 months from the date of their exit from our services. After this period, the data will be permanently deleted from all systems and storage media and will not be accessible to anyone.

Contractual Obligations: In instances where the Company has contractual obligations with clients regarding data retention, the data will be preserved for the duration specified in the respective contracts.

18.2. Data Handling and Security

Data Access: Access to client data will be granted only to authorised personnel with a legitimate business need. Strict access controls are being enforced to prevent unauthorised access.

Data Security: We have implemented robust security measures, including encryption and access controls, to protect stored data from unauthorised disclosure, alteration, or destruction.

Data Backup and Recovery: Regular data backups are being conducted to ensure data integrity and facilitate data recovery in the event of accidental loss or system failures.

18.3. Data Disposal

Expiry of Retention Period: At the end of the 6-month retention period, all general client data will be permanently deleted from our databases, archives, and backup systems.

Contractual Data: In case of contractual obligations regarding data retention, data will be disposed of in accordance with the terms specified in the respective agreements.

18.4. Client Data Retrieval

Client Request for Data: If a client requests access to their data within the 6-month retention period, we will provide the data in a timely manner, subject to verification of the client’s identity.

Contractual Obligations: We will adhere to contractual obligations concerning data access and retrieval as outlined in the respective agreements with clients.

19. Changes to this privacy policy

Any changes we may make to our Policy in the future will be posted on this page and, where appropriate and feasible, notified to you by email. Please check these Terms and any Policies periodically for changes. User’s continued use of the application after the changes become effective constitutes the binding acceptance of such changes. Except as stated elsewhere, such amended Terms will automatically be effective upon the earlier of (a) the User’s ongoing use of the application with actual notice of the new terms, or (b) 30 days after we have posted notice of the new terms on this page.

20. Contact us

We are committed to resolving any privacy concerns you may have. If you have any questions or comments about this Policy, or if you wish to exercise your rights, please contact Olive’s Privacy Officer for queries or requests relating to taking a Course: Olive’s Privacy Officer for queries or requests relating to taking Course:

By email: compliance@olivegroup.io

By post: Brendan Kavanagh, Upskill Online Limited, 176 Block E, The Hunt Building, Town Centre, Grand Parade, Laughanstown, Dublin 18, D18 VY3V