Welcome to ICSI Ltd,
1. About Us
1.2 If you have any questions about your personal information, please click on “support” in your Account Dashboard.
2. Use of the Website and Online Courses and Content
3. Collection of Information
3.1 When you access the Website via any means, use the Online Courses and Content, register or post notes, assignments or other material, respond to or participate in any survey or questionnaire sent to you by us, provide comments via the support button, or make a purchase through the Website, we may collect, store and use certain of your personal information in line with this policy. We may also ask you for information when you report a problem with the Website or the Online Courses and Content.
3.2 To register or make a purchase on the Website, we ask for your name and email address. As part of your Learner profile you may also provide your location and other information that will help other learners get to know you and help us to tailor the service to suit you. We may also ask you about your gender and educational history or qualifications in order to understand more about you (responding to these questions will always be optional, however). We will also store the results of your assessments relating to Online Courses and Content. When you make a purchase, our payment service provider, will also collect and process your credit card or other payment details. If you contact us, we may also keep a record of that correspondence.
3.3 We may also collect data relating to your visits to the Website that cannot identify you but records your use of our Website and Online Courses and Content including, for example, details of how long you have used the Website and the Online Courses and Content for.
3.4 We may also collect your computer’s IP address in order to help us tailor the service to your location.
3.5 If you elect to verify your identity through our Website, our identity verification partner will receive directly from you, process and store your personal information and identity documentation for this purpose. Our identity verification partner may store your information for a maximum of 5 days for the sole purpose of resolving user support issues. Upon successful verification of your identity, we will store only the name given on your identification documentation; if you participate in a credit bearing course or Program, we may share the confirmation that we have received from our provider with the relevant course provider or accrediting organisation to allow you to receive credit.
3.6 Finally, we may receive information about you from third parties (such as credit reference agencies) who are legally entitled to disclose that information.
4. Use of Your Information
4.1 By accessing the Website via any means, using the Online Courses and Content, registering or posting notes, assignments or other material, providing comments via the support button, or making a purchase via the Website, you agree that your personal information may be collected, stored, used and shared by us and our partners, course and content providers, or third parties we work with, for any of the following purposes:
(a) to provide, maintain, protect and improve the quality of the Website and the Online Courses and Content we offer, including by conducting anonymised market research, and to protect us and our users;
(b) to provide you with a personalised browsing experience when using the Website;
(c) to fulfil any contractual agreements between you and us;
(d) You can control your email preferences on the Student Dashboard page.
(e) to tailor our advertising on social media to your use of the Website;
(f) to manage your Learner account that you hold with us;
(g) to allow you to use the full range of features on or via our Website;
(h) to send you course-specific email notifications and updates about Online Courses and Content you are enrolled on;
(i) to comply with legal and regulatory requirements;
(j) to contact you occasionally in order to invite you to share your opinions and experiences of ICSI Ltd;
(k) to allow universities and other partner institutions that provide Online Courses or Content to perform academic research (as more fully set out in paragraph 12 below);
(l) if you are taking Online Content and Course for credit, certification and/or another formal recognition of learning (“Accreditation”) to allow the applicable university and/or other partner institution to monitor your progress and award you with the relevant Accreditation as required; and
(m) in order to provide third party goods or services available through our Website, including (but not limited to) confirmation of the Courses you have participated in and/or the award you have achieved as a result (if applicable) for accreditation or CPD purposes, and to enable you to participate in our refer-a-friend rewards scheme.
4.2 We may use your email address to send you course notices and updates about our Services. You can control your email preferences on the My Account page.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone with information, news, and offers on the relevant Online Course and Content. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
5. Storage of Information
5.1 All information is stored on our secure servers. When you register, we will ask you to choose a password which enables you to access the Online Courses and Content. You are responsible for keeping this password confidential. We ask you not to share this password with anyone.
5.2 In addition, we (or third parties acting on our behalf) may also store or process information that we collect about you in countries outside the European Economic Area, which may have lower standards of data protection. Specifically, servers used by our Website are located in Ireland and our third party service providers operate around the world. We have put in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet.
6. Legal Basis for Processing Your Information
6.1 Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
6.2 However, we will normally collect personal information from you only (i) where we have your consent to do so, (ii) where we need the personal information to perform a contract with you, or (iii) where the processing is in our legitimate interests and not overridden by your rights. In some cases, we may also have a legal obligation to collect personal information from you.
6.3 If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your information).
6.4 Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
7. Disclosure of Your Information
We may disclose your personal information to third parties when permitted by law including:
(a) with your consent;
(b) to our suppliers in order for them to help us provide our services to you, this includes:
universities and other partner institutions that provide Online Courses or Content;
our provider of customer relationship management services (which allows us, for example, to send personalised email communications to you);
our provider of file storage and management services if you email us directly;
our payment services provider (as discussed at paragraph 3.2 above) when you make a purchase to process your payment;
our identity verification partner (as discussed at paragraph 3.5 above) to verify your identity where you choose to select this option;
where you have agreed, to our refer-a-friend scheme provider, solely to enable your participation in the refer-a-friend scheme;
our customer service software if you contact our support team; and
providers of assessments and marking services when you sign-up for an assessment or submit a piece of work for marking.
These suppliers’ use of your personal data may be subject to their own privacy policies, which are available on their websites, and which we suggest you familiarise yourself with in the relevant circumstances set out above.
(e) if we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect our rights, property, or safety, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
8. Data Retention
8.1 We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
8.2 When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. Your Rights
9.1 You have the following data protection rights:
You can edit your personal details via your profile page whenever you wish. We maintain a procedure in order to help you confirm that your personal information remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners.
In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contacting ICSI Ltd” heading below.
You may unsubscribe from certain email communications by following the Unsubscribe link in the email communication itself. You may also update your personal information by logging into the Website and visiting your Learner account page. You may also email us at firstname.lastname@example.org in order to access, correct, or update your personal information on our systems. We will answer every email as promptly as possible. Unless you are also enrolled with a University and are taking an Online Course for Accreditation, or you are taking an Online Course through your employer, you have the right to delete your account. To do so, you can go to your settings.
Similarly, if we have collected and process your personal information on the basis of your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you have any privacy-related questions or unresolved problems, you may contact us using the information provided at paragraph 14 below.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
The Website may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. Please check these policies before you submit any personal information to these websites.
We strongly believe in protecting the privacy of children. In line with this belief, we do not knowingly collect or maintain personal information from persons under 13 years of age, and no part of the Website is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access the Website at any time or in any manner. We will take appropriate steps to delete any personal information of persons less than 13 years of age.
12. Links to Third Party Websites
12.1 When clicking on a link within a course step or in a course email, you will be taken to a third party website, the use of which has been arranged by and is the responsibility of the course providing organisation.
12.3 The course providing organisation will only use your personal information for the purpose stated in the course and in accordance with the terms of the third party website.
12.4 Whether you follow a link in a course and submit your personal information or not, your course progress will in no way be affected. Nor will your course marks or ICSI Ltd profile.
14. Contacting ICSI Ltd
FAO: Data Protection Officer
The Pinnacle, Office 203, 170 Midsummer Boulevard
Milton Keynes, MK9 1BP, United Kingdom