The Privacy Policy describes how Opennetworks (Pty) Ltd (“Opennetworks”), a South African registered company, collects, uses and discloses information related to its digital training platform, and the choices that you have with respect to the information.
Please note the terms of this Privacy Policy only apply to the digital training platform as described below. For Privacy Policies relating to Opennetworks’ other products and services, please refer to the Master Sales Agreement concluded with Opennetworks (if applicable) or to the relevant Privacy Policy relating to that specific product or service.
Identification
Opennetworks (“us”, “we”, or “our”) operates a web application (at https://script.google.com/macros/s/AKfycbzkvzI78ZdBbl5orgOZLFk0ZN4aOnmR5v0Lb-JLqJ4bjAi1vWw/exec and https://script.google.com/a/macros/opennetworks.com/s/AKfycbxxhQyMOqVQfi4lZT5IeyQKKtrFLO2ku9-ojBPq4vLxGpKhSK90/exec) for the purposes of making digital training content available to subscribers (the “Platform”).
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Platform and the choices you have associated with that data.
We use your data to provide and improve the Platform. By using the Platform, you agree to the collection and use of information in accordance with this policy.
Definitions
Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage data
Usage Data is data collected automatically either generated by the use of the Platform or from the Platform infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small pieces of data stored on your device (computer or mobile device).
Data controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of our Users’ Personal Data.
Data processors (or service providers)
Data processor (or service provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
Data subject
Data Subject is any living individual who is the subject of Personal Data.
Requested account permissions
Some permissions to your account are required for the Platform to operate. The Platform will ask for permissions to access your account to see basic pieces of information. The permissions granted are used exclusively for the operation of the Platform limited to the services offered. Below are the specific permission to data access requirements, why they are necessary and how they are used:
Google account information
This permission is used to see your email address, which is used to determine what digital content you should have access to, based on your subscription to the Platform.
Connect to an external service
This permission allows the Platform to create a network connection to a backend service, which, based on the your email address, determines which video content you are allowed to access and ensures that the user interface renders the correct options to view such content.
This permission is used exclusively to render the correct content and user interface for the user.
Information collection and use
We may collect several different types of information for various purposes to provide and improve our Platform to you. The Platform shall not transfer or share the data with third parties without your prior express consent (other than to Opennetworks’ Data Processors who are acting on behalf of Opennetworks).
Types and usage of data collected
Personal data
While using our Platform, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally, identifiable information may include, but is not limited to:
- Email address
- First name and last name
We may use the data collected for various purposes: To determine whether you should have access to content; To provide and maintain our Platform; To notify you about changes to our Platform; To allow you to participate in interactive features of our Platform when you choose to do so; To provide customer support; To gather analysis or valuable information so that we can improve our Platform; To monitor the usage of our Platform; To detect, prevent and address technical issues.
We may use your Personal Data to contact you with news, special offers and general information about other goods, services and events which we offer that are similar to the Platform. We may also contact you requesting feedback on your experience of the Platform. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or contact us at support@opennetworks.com.
Usage data
We may also collect information on how the Platform is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Platform that you visit, which content has been viewed, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking cookies data
We may use cookies and similar tracking technologies to track the activity on our Platform and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Platform. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Platform. Examples of Cookies we may use: Session Cookies, to operate our Platform; Preference Cookies, to remember your preferences and various settings; Security Cookies, for security purposes. More information about Cookies, please read our Cookies Policy.
Legal basis for processing personal data under General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), Opennetworks’ legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Opennetworks may process your Personal Data because: We need to perform a contract with you; You have given us permission to do so; The processing is in our legitimate interests and it’s not overridden by your rights; For payment processing purposes; To comply with the law.
Retention of data
Opennetworks will retain your Personal Data only for the purposes set out in this Privacy Policy and for the duration as applicable by law. We will delete your Personal Data on your request, unless and to the extent it is necessary that we retain and/or need to use it in order to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and/or enforce our legal agreements and policies.
Opennetworks will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Platform, or we are legally obligated to retain this data for longer time periods.
Transfer of data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction, where the data protection laws may differ than those from your jurisdiction. The persons in charge of data processing some of whom may be located outside the European Union. Others may include third parties necessary for the fulfillment of legal duties.
If you are located outside Spain or the United States and choose to provide information to us, please note that we may transfer the data, including Personal Data, to Spain and the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Opennetworks will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of data
Business transaction
If Opennetworks is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Disclosure for law enforcement
Under certain circumstances, Opennetworks may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal requirements
Opennetworks may disclose your Personal Data in the good faith belief that such action is necessary to: To comply with a legal obligation; To protect and defend the rights or property of Opennetworks; To prevent or investigate possible wrongdoing in connection with the Platform; To protect the personal safety of users of the Platform or the public; To protect against legal liability.
Security of data
The security of your data is important to us and we take all reasonable precautions to ensure the security thereof. Furthermore, all interactions between your Google account and our Platform occur over a secure HTTPS connection.
Your data protection rights under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Opennetworks aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at support@opennetworks.com.
In certain circumstances, you have the following data protection rights: The right to access, update or to delete the information we have on you: Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us at support@opennetworks.com to assist you. The right of rectification: You have the right to have your information rectified if that information is inaccurate or incomplete. The right to object: You have the right to object to our processing of your Personal Data. The right of restriction: You have the right to request that we restrict the processing of your personal information. The right to data portability: You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format. The right to withdraw consent: You also have the right to withdraw your consent at any time where Opennetworks relied on your consent to process your personal information. Please note that we may ask you to verify your identity before responding to such requests. You may exercise your rights by contacting us at support@opennetworks.com expressing your appropriate identification details and the specific right you wish to exercise.
Our policy on emails consists of sending only the messages you have asked to receive. If you do not wish to receive messages via email we will offer you the option of exercising your right to renounce receiving such messages. And you have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact (support@opennetworks.com) or your local data protection authority in the European Economic Area (EEA).
Service providers
We may employ third party companies and individuals (“Service Providers”), to provide the Platform on our behalf, to perform Platform-related services or to assist us in analyzing how our Platform is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers (including Google Analytics) to monitor and analyze the use of our Platform.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Platform. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Platform available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google/intl/en/policies/privacy/.
Changes to this Privacy Policy
We may update our Privacy Policy from time to time. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact us
If you have any questions about this Privacy Policy, please contact us at support@opennetworks.com.
