Privacy Policy

 

Hive Learning Privacy Policy

This Privacy Policy describes the information that we gather on, or through, our Services and how we use and process such information. For each processing purpose we will articulate the reason for requiring the data, what data we will process, the legal basis for processing the data and how long we will keep the data.

Where the legal basis of consent is to be used, this will be gathered freely, and we will use clear, plain language that is easy to understand, and you will be able to remove your consent at any point.

References in this Privacy Policy and on our platform to “we”, “our” or “us” are references to Hive Learning Limited, company number 08183912 and its affiliates within the Hive Learning group of companies. References to “you” and “your” means each natural or legal person who uses our platform or the associated services.

  1. What Information do we collect about you and how do we use it?

We collect/process information so that we can provide the best possible experience when you utilise our Services.  This section of the policy will describe the purpose for processing your Personal Data, the legal basis to do so and how long we will keep your data.

“Personal Data” has the meaning given to it in the Data Protection Laws.

“Data Protection Laws” means any and all laws, statutes, enactments, orders or regulations or other similar instruments of general application and any other rules, instruments or provisions in force from time to time relating to the processing of personal data and privacy applicable to the performance of this Agreement, including where applicable the Data Protection Act 2018, the Regulation of Investigatory Powers Act 2000, the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003) and the UK GDPR (Regulation (EU) 2016/679), as amended or superseded. 

1.1. Our Product / Service

If you choose to use our Services, including access to the platform, email notifications, newsletters and product/service updates, you must provide us with some Personal Data so that we can provide our Services to you; this will include your name, email address and IP address. Other non-mandatory Personal Data (for example job titles) may also be gathered on an optional basis, but is not mandatory to use our product/services. 

We do not collect any special categories of sensitive personal data, such as ethnicity or medical information. 

We will process data using two legal rationales: 

  1. if you are an individual and not associated with a contracted client we will use legitimate interest based upon our Terms and Conditions;
  2. if you are associated with a contracted client we will use the performance of a contract as the legal basis to process the data. 

Our ability to retain the Personal Data will be determined by account activity, if the account is not used for over two (2) years we will delete your data. Accounts associated with contracted clients will be deleted on termination of the contract.

1.2.Our use of Productivity Tools

If you choose to use our Service, Personal Data items such as name, email address, telephone number and other non-mandatory Personal Data may be stored in our corporate cloud application platform, corporate email platform and our help desk platform. 

We will process Personal Data using two legal rationales:

  1. if you are an individual and not associated with a contracted client we will use legitimate interest based upon our Terms and Conditions; 
  2. if you are associated with a contracted client we will use legitimate interest as the legal basis to process the data.

Our ability to retain the Personal Data will be determined by account activity, if the account is not used for over two (2) years we will delete your data. Accounts associated with contracted clients will be deleted on termination of the contract.

1.3.Cookies

Like many platforms and apps, we use cookies and similar technologies to collect additional platform or app usage data and to improve our Services. Platform usage information is collected using cookies to monitor aggregate site usage metrics such as total number of visitors and pages viewed. We will store the cookie values on our platform to allow us to perform our analysis, however this will not be used for any marketing analysis and is essential to deliver our reporting service. 

 

We will process data under the legitimate interest legal basis as we only use the data to perform aggregated tracking analysis and will not target individuals based upon this analysis. You will also need to accept our cookie policy to allow us to process the data.

We will retain active cookie data for a period of up to one (1) year, a cookie will remain active if a user re-visits our platform.

Learn more about how we use cookies by visiting our cookie policy on the platform. 

  1. Updating This Policy

We may change or update this Privacy Policy at any point so that it accurately reflects our Services, if we believe it does not fundamentally change your data privacy rights. If we believe your rights have been affected we will contact Users 30 days before we implement the change. If you continue to use the Service once the Privacy Policy has been updated or amended, you will be bound by the updated Privacy Policy. If you do not want to agree to any updated or amended Privacy Policy, you can request an account deletion.

  1. Your Rights

3.1.Accessing or Rectifying your personal data

In most circumstances before we are able to invoke your rights we may need to verify you as the data subject, therefore we will request data from you and this will be checked against our records before we can proceed.

We want to make sure that your personal information is accurate and up to date and you have the right to request a copy and update the Personal Data that we hold about you. You may ask us to access your personal data, correct or remove information you think is inaccurate. If you would like to invoke any of these rights, please email or write to us at dp@hivelearning.com or DP - Hive Learning, Scale Space, 58 Wood Lane, London, W12 7RZ. 

3.2.Deletion

Based upon the retention periods described above we will remove your Personal Data from our platforms.

3.3.Object, Restrict or Withdraw Consent

You may wish to object to or restrict our ability to process your Personal Data, this can be done either via email or in writing, using the contact details below. Further context may need to be requested to ensure we can carry out the relevant tasks on our platforms to perform the request.

3.4.Portability

You may wish to port your Personal Data to another platform. If you would like to invoke this right, please email or write to us at dp@hivelearning.com or DP - Hive Learning, Scale Space, 58 Wood Lane, London, W12 7RZ.

  1. Who We Are And How To Contact Us

This Privacy Policy is issued on behalf of the Hive Learning group of companies so when we mention “Hive Learning”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the group responsible for processing your data. If you are an individual and not associated with a contracted client we are the Data Controller and are responsible for defining and managing how your personal data is processed. If you are associated with a contracted client we are a Data Processor and the contracted client will be responsible for defining and managing how your personal data is processed (as the Data Controller).  

Our company name is: Hive Learning Limited

Our company address is: Scale Space, 58 Wood Lane, London, W12 7RZ. 

Our email address is: dp@hivelearning.com

  1. To Whom We Disclose Information

Except as described in this Privacy Policy, we will not intentionally disclose the Personal Data that we collect or store on the Service to third parties without the consent of the data subject or data controller. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

Unrestricted Information

Any information that you voluntarily choose to include in a public area of the Service, such as a public profile page, will be available to any visitor or User who has access to that content.

  1. Service Providers

We work with third party service providers who provide email hosting, core corporate applications, web hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information. An up to date list of our service providers can be found at the end of this Privacy Policy. 

6.1.Overseas transfers

If you are a User based in the UK or the European Economic Area (EEA), the information you provide may be transferred to countries outside the UK or EEA that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy. However, we will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your information, you consent to these transfers for the purposes specified above.

We may transfer your personal information to our service providers located outside of the UK or EEA as specified in the list of service providers which can be found at the end of this Privacy Policy. 

All of our International service providers have each provided the information to demonstrate they have appropriate technical and organisational measures in place to safeguard Personal Data, and it shall be processed to at least the same standards as set out by the General Data Protection Regulations (GDPR). Each organisation has entered into Standard Contractual Clauses with Hive Learning,  which is accepted by the European Commission as evidence that an adequate level of protection exists for the Personal Data in the country, territory, or organisation where it is being transferred.  

6.2.Non-Personally Identifiable Information

We may make non-personally-identifiable information available to third parties for various purposes. This data may be automatically-collected and would be analysed to create an aggregated view of the data, ensuring the reported information was anonymous.

6.3.Law Enforcement, Legal Process and Compliance

We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

6.4.Change of Ownership

Information about data subjects, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the Personal Data commits to a privacy policy that has terms substantially consistent with this Privacy Policy.

  1. Our Data Security

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way.

The following security procedures, and technical and organisational measures to safeguard your personal information have been put in place:

  • In cases where Personal Data is being processed in third countries or third parties, a rigorous data protection impact assessment is being performed to ensure that your data is always secured.
  • Our application platform is hosted in ISO 27001 certified secure data centres in the UK.
  • Firewalls, intrusion detection and prevention, anti-virus and anti-malware and backup and disaster recovery are in place to prevent data loss or deletion.
  • 24/7 security guard, closed circuit television and a door access control system to authorized personnel secures our offices and data centres.
  • Our applications are engineered by following industry standards to minimise security vulnerabilities and updates on a regular basis.
  • Intrusion detection and prevention secures the network traffic to the servers and applications.
  • Anti-malware and anti-virus software is deployed to all of our servers and regularly scan and update with the latest anti-malware and virus signatures.
  • We regularly apply critical, security patches and firmware updates to operating systems and physical hardware to minimise the risk of vulnerabilities.
  • Our employees undergo background screening and selection processes, with a restricted list of employees having access to secure areas of the applications, databases and physical infrastructure. The access to the secure areas are logged and auditable.
  • We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
  • We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
  • We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
  • Our employees receive regular Security and Data Privacy awareness training

 

  1. Complaints

If you are not happy with this privacy policy, or you wish to speak to a supervisory authority, you can contact the ICO on 0303 123 1113 or via their website www.ico.org.uk.  

  1. CCPA

In relation to the California Consumer Privacy Act (CCPA), we confirm the following

  • We do not sell any personal information
  • We do not offer any financial incentive for your personal information
  • You will not receive any discriminatory treatment by our business for exercising your privacy rights
  • We will not charge you for exercising your privacy rights
  • Upon receiving a request to know or a request to delete, we will confirm receipt of the request within 10 business days and provide information about how the business will process the request.
  • We will respond to requests to know and requests to delete within 45 calendar days.
  • We shall not disclose in response to a request to know a consumer’s Social Security number, driver’s licence number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics.
  • We are able to provide the information and classification of information when responding to a Request to Know request
  • We are able to delete the personal information in relation to a Request to Delete request

 

This Privacy Policy was last updated September 2022.

 

Service providers

      Schedule of Sub-Processors (last reviewed 20 10 23)

  Sub-processor: Name/Company number/Address Purpose Location of processing
1 Accelerate Technology Limited Internal operations UK
09576924/ Scale Space, 58 Wood Lane, London, W12 7RZ, UK
2 Accelerate People Limited Customer assessment/ feedback tools UK
09577006 / Scale Space, 58 Wood Lane, London, W12 7RZ, UK
3 Hive Learning, Inc. Intergroup operations. US
7279297/ 1178 Broadway, 3rd floor, New York, NY 10001, US
4 Typeform SL For obtaining client feedback Ireland
Calle Pallars 108 (Aticco - Typeform), 08018 Barcelona, Spain
5 Microsoft Corporation Power BI services for usage analytics and reporting applications. Azure Cognitive OpenAI service UK / France
600413485 / One Microsoft Way Redmond, Washington 98052-6399, US
6 Amazon Web Services EMEA SARL UK Hosting services  UK / Ireland
FC034225 / 38 Avenue John F. Kennedy, Luxembourg 1855, Luxembourg
7 Mailchimp (The Rocket Science Group, LLC) Marketing and sales tools US
675 Ponce De Leon Ave NE Ste 5000, Atlanta, GA 30308, US  
8 HubSpot UK Holdings Ltd Marketing CRM and automation tools Ireland
HubSpot Ireland Limited, HubSpot House, One Sir John Rogerson's Quay, Dublin 2, Ireland Attention: Legal, (with copy to HubSpot, Inc.)
9 Slack Technologies, LLC.  Messaging tools US
199972598 / 500 Howard Street, San Francisco, CA 94105, US
10 ZenDesk, Inc.    Helpdesk software US
264411091 / 989 Market St San Francisco, CA 94103, US 
11 Blenheim Chalcot IT Services India PVT. Ltd. Back-office finance and invoicing services and queries India
103-104 B Wing, Fulcrum Hiranandani Business Park, Sahar Airport Road, Andheri (East), Mumbai, 400099, India
12 Blenheim Chalcot LTF Limited. Internal group co. operations UK
05064255 / Scale Space, 58 Wood Lane, London, W12 7RZ, UK
13 Freshworks, Inc Back-office finance and invoicing services US
San Mateo, CA 2950 S. Delaware Street, Suite 201 San Mateo CA 94403, US  
14 Google LLC  Corporate applications (Google Workspace), analytics and display networks US
3582691 / 1600 Amphitheatre Pkwy Mountain View CA 94043, US
15 Asana, Inc.   Project Management tasks US
633 Folsom Street Suite 100 San Francisco, CA 94107-3600, US 
16 Vimeo, Inc. To upload videos of stakeholders within  learning programmes US
555 W 18th St, New York, US
17 Fospha Limited Aggregated web journey analytics UK
08902419 / Scale Space, 58 Wood Lane, London, W12 7RZ, UK
18 Zapier, Inc. Online meeting data management US
548 Market St. #62411, San Francisco, CA 94104-5401, US
19 IntentPro Limited  Operational Tools UK
13873023 / Scale Space, 58 Wood Ln, London W12 7RZ, UK
20 PostHog Inc. Product analytics UK
2261 Market St #4008, San Francisco, US
21 Bugsnag  Application monitoring Ireland
(Smartbear (Ireland) Limited), Mayoralty House, Flood Street, Galway, Ireland
22 Cognism Limited  Prospecting services UK
09392705 / 5 Chancery Lane, London, England, WC2A 1LG, UK
23 8X8 UK Limited  In-platform video conferencing EU
 05083841  Oxford House, Bell Business Park, Smeaton Close, Aylesbury, Buckinghamshire, HP19 8JR, UK
24 Basecamp (37 Signals LLC) Project management tools US
2045 W Grand Ave, Suite B, PMB 53289, Chicago, Illinois 60612, USA
25 Atlassian Pty Ltd (JIRA and Confluence) the tools for project management of our product and software development Ireland
Level 6 341 George St, Sydney, NSW 2000, Australia 

 

In order to provide the best service to our customers, this list may change.

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