PRIVACY POLICY
LEWIVERSITY is committed to protecting your personal data. This policy aims at explaining how we achieve this and what your rights are under the applicable law. We recommend you take the time to read this Privacy Policy so as to better understand how we use your data and how you can protect it. If you do not agree with this policy, please do not register on our site.
The aim of this Privacy Policy is to inform you when, where and why we process personal data of people who access our content and Website. It explains how we process your data and the conditions under which we may provide it to others, how you can safeguard your rights and as well as how we keep your personal data secure.
By using this site, you represent that you are at least of majority age in your country of residence.
Who are we
LEWIVERSITY is a brand of the TEAM LEWIS Group which has offices in the UK, EU, US and APAC. Reference to TEAM LEWIS or “we” or “us”, unless stated otherwise, refers to LEWIS Communications (Holdings) Limited of Millbank Tower, Millbank, London, SW1P 4RS, United Kingdom. A list of all entities belonging to the TEAM LEWIS Group, can be viewed here. This policy shall refer to all companies within the TEAM LEWIS Group.
For more information about anything covered in this policy, please see the following index (hyperlinked).
The information we collect from you
How we collect your information
Why do we use your information
How long we will keep your information
Where we store your information
How we keep your information secure
Your rights as a Californian resident
General
Access to our LEWIVERISTY content (including online content, courses, website, related software etc.) is only possible if you have registered an account on our website. By doing so, we may collect personal data from you and decide why and how the personal data should be processed.
Whenever you access the website, we also put cookies on your device, by which we track your activity on our website (for clarity: www.lewiversity.com) (“Website”). You can always opt out of cookies except for those which are necessary. For more information on our Cookies, please visit our Cookies policy.
We may change our Privacy Policy from time to time so please check it once and a while to ensure you are still happy with any changes made. By continuing to using our site, you accept the changes made to the policy.
The information we collect from you
When you register an account on our Website, we may collect personal data from you and process it accordingly. We do so to perform our obligations under the Terms we have agreed with you or to adhere to any other obligations under applicable law (tax legislation).
We collect the following personal information;
- Identity and Contact Data, i.e. first name, last name, email address, phone number when you register an account on our Website or use our Website.
- Log in credentials - username and password as well as purchases or orders made by you, your feedback and review if any.
- Social network ID or “handle”– when you access our social network pages by leaving a comment.
- Marketing and Communication Data – your preferences in receiving marketing from us and your communication preferences.
- Technical Data – IP address, login data, browser type and version, time zone and location.
- Other information you freely provide to us.
Under no circumstances will we collect sensitive personal data.
How do we collect your information
We predominantly collect data from and about you from through:
- direct interactions with you when:
- you register your account or make a payment on behalf of yourself or your employer;
- your use of our social media
- Automated interactions when you access our Website where we have placed cookies or other similar technologies.
- Third Parties via Google Analytics and Google, employer
The lawful bases we rely on for collecting your information is:
- your consent
- under our Terms to perform our contractual obligations.
- as a legitimate interest to improve the quality of the online content.
- where we comply with a legal obligation.
Where we rely on your consent, please note that you may always withdraw it by contacting us at the information under the heading “Contact us”.
Why do we use your information
We will only use your personal data to the extent we are allowed to do so. This will be for the following reasons:
- To provide the services to you and/or authorize access to our Website and online content to perform our obligations under our Terms.
- To process your payment to give you access to our Website and online content.
- To comply with applicable law, including but not limited to tax legislation.
- To analyze the efficiency of our social media campaigns where you have provided your social network ID.
- To register you as a supplier of us.
- To use data analytics to improve our Website products, marketing.
- To deliver relevant content to you
- To respond to your inquiries
For payment services, please note that we use a third-party payment processor such as Stripe as opposed to directly processing your billing information. All transactions are secured as our payment provider uses SSL encryption protection. We do not store your payment information on our servers. We may use your payment card transaction data as shared by third-party services provider to confirm a specific transaction has occurred (e.g. date and amount of your purchase and last 4 digits of your card number so we can verify the purchase).
Our course and site are hosted by Thinkific Labs Inc. (“Thinkific”). They provide us with the online course creation platform that allows us to sell our product/services to you. They store your data on a secure server behind a firewall.
How long we will keep your information
We will only hold your personal data for as long is necessary to meet our obligations under the contract and during the time your account is active. If your last activity is more than one (1) year ago, your account will be considered expired. In such event as is the case when you delete your account yourself, we will undertake to remove any personal data from our active systems within 90 days or earlier.
We may also retain some of your personal data for longer if we need it to comply with the applicable legal, regulatory, tax, accounting or other requirements.
Where we store your information
When you visit our Website, your personal data may be processed by platforms outside the UK. This may result in transfer of personal data outside of the UK or EU. Our hosting platform Thinkific is based in Canada. Thinkific makes use of AWS servers in the United States.
The transfer of personal data to Canada and the US is based on the EC adequacy decision for Canada and the EU-US Data Privacy Framework to which AWS is a member.
Please take the time to check the relevant privacy policies of our third party providers:
For more information on the Data Privacy Framework see DPF
How we keep your information secure
We have put in place appropriate physical, technical and organizational security measures to prevent your personal data from being accidentally lost, disclosed, modified, or used and accessed in an unauthorized way. In addition, we only share your personal data to those employees, contractors and third parties on a need-to-know-basis. They will only process your personal data on our instruction, and we have put safeguards in place through data protection agreements where applicable and confidentiality obligations.
Your personal data may be held on our IT systems and/or on the IT system of third parties which provide IT hosting or other data protection services. These can be within or outside the UK.
We have in place a data breach notification process if we suspect a personal data breach and will notify you and any applicable authority as requested by law. All personal data is processed through a secure network. Any payment transactions will be encrypted.
Your rights under this policy (GDPR)
You have rights under data protection laws in relation to your personal data. Below you find an overview of most rights available.
Your right to access your data. You have the right to ask us for copies of your personal information and to check that we are lawfully processing it.
Your right to correction of your data. You have the right to ask us to correct personal information we hold from you and which you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to delete your data. You have the right to ask us to delete your personal information where there is no good reasons for us to continue processing it.
To delete your personal data, you can delete your account in part or as a whole or contact us as indicated in the section “Contact Us”.
Your right to restrict or object the processing of your personal data. You have the right to ask us to restrict or stop the processing of your personal data that we store for a specified or indefinite period. However, we may oppose your request if this is necessary to comply with a legal obligation.
Your right to data portability
You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
To exercise your rights please contact us via the “Contact Us” section. We have one (1) month to respond to your request.
Your rights as a Californian resident
This section applies to individuals residing in California from whom we may collect Personal Information. The section should be read in conjunction with the information and disclosures already contained in this Privacy Policy. We refer in particular to each individual section that explain who we can share your data with.
As of January 1, 2020, if you are a Californian resident you will have the following rights under the Californian Consumer Privacy Act 2018 (“CCPA”)
Right to Know and Access. Under the CCPA, you have the right to request disclosure of the information we may have collected, used and disclosed about you in the preceding twelve (12) months of your request. Such a request for information will include the following:
a. Categories of your Personal Information that we have collected or disclosed by us
b. Categories of sources from which your Personal Information was obtained:
c. The purpose for which the categories are collected by us (business or commercial purpose) during the past 12 months.
d. Categories of third parties with whom we may have shared personal information during the past 12 months
e. Specific pieces of Personal Information we have collected about you during the last 12 months
f. If we disclosed your Personal Information with a third party for a business purpose, the PI categories that each category of recipient obtained.
Right to Delete. You have the right to request the deletion of personal information we may hold of you or have collected about you, subject to certain exceptions.
Right to Non-Discrimination. You have the right not be treated differently following the exercise of your CCPA privacy rights, subject to certain limitations. We will not discriminate against you for exercising your rights and will not charge you for the information we will provide.
Right to Opt-out and Opt-in / Shine the Light. Our position is that we do not sell Personal Information for commercial purposes. Sale under the CCPA relates to selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating your personal information to another business or third party for monetary or other valuable considerations. Under the CCPA Californian residents have the right to opt out of the sale of their personal information.
Please note that these requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity on the basis of the information we request and that you have subsequently provided to us. These verifiable consumer requests (“VCR”) will be pursuant to CCPA requirements and legislation and can only be made by you, or by an Authorised Agent, a person registered with the Californian Secretary of State that you authorise to act on your behalf. When using an agent, a statement signed by you and the Authorised Agent which includes proof of the agent’s registration with the Californian Secretary of State must be provided. We do not knowingly hold household requests. Any such request will be dealt with as an individual request.
You may make a request related to your personal information twice per 12 month period. Any requests invoking your rights should be address to [email protected] OR via post to LEWIS PR. Inc, 111 Sutter Street Suite 850, CA.
How to complain
You have the right to make a complaint at any time to the Information Commissioner’s Office and your local data protection authority in your country of residence.
For UK:
Information Commissioner’s Office - Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Contact Us
If you have any questions regarding this Privacy Policy, including any requests to exercise your legal rights, please contact the TEAM LEWIS data protection officer using the following details:
FAO of the Data Protection Officer
Legal Team
Floor 22, 21-Millbank Tower,
London,
SW1 P 4RS
Email: [email protected]