Privacy Policy

 

GDPR Readiness Assessment Powered by Positive Grid Limited Privacy Note

 

We take the private nature of your personal information very seriously, and are committed to protecting it. To do that, we've set up procedures to ensure that your information is handled responsibly and in accordance with applicable data protection and privacy laws. We're grateful for your trust, and we'll act that way.

 

The privacy policy explains how we use any personal information we collect about you when you use this website, our products, our wider services, and what choices we offer you to access, update, and control it.
As part of our efforts in implementing the latest policies, practices and processes, we will be reviewing these policies, practices and processes from time to time.

 

We reserve the right to amend the terms of this Privacy Policy at our absolute discretion. Any amended Privacy Policy will be posted on our website. You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

Glossary of Terms

PERSONAL INFORMATION:

 Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

  • Names and contact information (i.e. emails and telephone numbers)

  • National Insurance Numbers

  • Employment history

  • Employee numbers

  • Credit History

  • Personal tax

  • Payroll and accounting data

        SENSITIVE PERSONAL INFORMATION:

        Sensitive personal data refers to the above but includes genetic data and biometric data. For example:
        • Medical conditions
        • Religious or philosophical beliefs and political opinions
        • Racial or ethnic origin
        • Convictions
        • Biometric data (e.g. photo in an electronic passport)
        WHAT IS A DATA CONTROLLER?

        For general data protection regulation purposes, the “data controller” means the person or organization who decides the purposes for which and the way in which any personal data is processed.

        The data controller is Positive Grid Limited. Positive Grid Limited

        FLAT/RM A 12/F KIU FU COMM BLDG

        300 LOCKHART RD

        HONG KONG

        WHAT IS A DATA PROCESSOR?

        A “data processor” is a person or organization which processes personal data for the controller.

        Whose data we collect?

        We collect and process from a range of our customers:

        • Visitors to our website at www.positivegrid.com and other related websites.
        • Customers who use our software (including software demos) or our services.
        • Customers who bought our hardware directly or from our agencies.

        You will fall into one or more of these categories of customers.

        What data is being collected?

        COLLECTION OF PERSONAL DATA OFF LINE

        If Positive Grid processes personal data off-line (e.g. printed forms), the party concerned must be given an information notice regarding the processing in order to obtain their consent, whenever necessary; this also applies to situations in which the data are collected from forms downloaded from the web site (the privacy statement is set out on the forms together with, whenever necessary, the request for express consent to the specific handling operation in question).

        COLLECTION OF PERSONAL DATA ON LINE

        As regards to the collection of data directly on the web site (e.g. registration forms, data sent in order to benefit from services online), the basic information relating to the processing is provided on each individual form found on the site (e.g. at the end of each registration form); this page can however be accessed at any time in order to view the PRIVACY POLICY applied more generally by Positive Grid.

        Every request for information regarding the processing of personal data, whether optional, explicit or voluntary, made by electronic mail, necessarily requires the address of the sender/applicant to be given, as well as any further personal data included in the message, in order that a reply can be submitted.

        We collect data from you directly or receive them from 3rd party services (e.g. Google Analytics, BigCommerce, etc.)

        COLLECTION OF PERSONAL DATA FROM MESSAGING SERVICE

        We collect various information on our behalf from and about you, including information you directly provide when you use the Messaging Service. For example, we collect the phone number and/or email address you provided when signing up for the Messaging Service. When you send messages via the Messaging Service, we will also collect your messaging history and any information included in those messages.

        We may also collect information about you using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your device. Cookies enable personalization of your experience on the Messaging Service. For example, we use cookies to track the items in your Shopping Cart and may use that information to send you triggered text campaigns (e.g., sending you personalized text messages such as shopping cart reminders).

        If you participate in a contest, sweepstakes, research study, or email survey associated with the Messaging Service, we will collect basic contact information and any other information you choose to provide in connection with these activities. We will also collect your contact information if you contact us with questions about the Messaging Service or for customer service.

        PERSONAL DATA
        PROFILING:
        • Name
        • Age
        • Gender
        • Email
        • Country
        • Language
        • Phone
        • Address
        • Avatar
        • The others
        TECHNOLOGY:
        • Encrypted device UUID (Universally Unique Identifier)
        • OS version
        • Browser
        • Device
        BEHAVIOR
        INTERACTION WITH FUNCTIONS AND CONTENTS PRESENTED ON GIVEN PLATFORM (IF APPLICABLE):
        • Viewing/Browsing
        • Searching
        • Clicking
        • Playing
        • Adding to cart
        • Purchasing
        • Downloading
        • Login
        • Leaving/Abandoning
        TRANSACTION:
        • Product purchased
        • Amount
        • Payment method
        COOKIES

        Positive Grid uses “cookies” to personalize surfing on the Internet. A cookie is a text file that is stored in the non-volatile memory in the user’s device by the server of Web pages. Cookies cannot be used to execute programmes or transmit viruses to your computer. Cookies are designated to users individually and can only be read by Web servers belonging to the domain that created them.

        One of the main purposes behind cookies is to provide a simple, practical method to help you save time. For example, if you personalize Positive Grid pages or register with Positive Grid sites or services, a cookie will facilitate access to consult the Web pages in question. Every time you visit the Positive Grid page, you can call up the information supplied beforehand, thereby utilizing the Positive Grid personalized functions in a straightforward, practical way.

        Most browsers accept cookies automatically, but the browser may be programmed to refuse them. If you choose to refuse cookies, however, you may be unable to benefit from some of the interactive functions provided by Positive Grid services and by the Web sites you have visited.

        GOOGLE ANALYTICS

        Positive Grid uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States . Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

        Positive Grid uses Google’s program for “interest-based advertising” for some marketing operations. In the process of this program a special browser cookie is stored on the user’s computer. It is used for serving the user special ads by Positive Grid, Google or third-party services when visiting other websites. Users can opt out of Google’s use of these cookies by visiting the Opt out site of Google ads.

        If you want to opt-out, download and install the add-on for your web browser. (https://tools.google.com/dlpage/gaoptout?hl=en)

        THIRD PARTY SITE

        Our website may contain links to other websites operated by third parties. We are not responsible for the privacy policies of websites operated by third parties that are linked to our website. We encourage you to read the privacy policies of all such third party websites you visit. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

        RAKUTEN

        Rakuten Advertising may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.

        How do we share your data?

        We may engage and contract with third party companies (e.g. service providers) to provide services that help us with our business activities such as cloud hosting services. These third party service providers are limited to only using information as instructed to provide contracted services to us.

        We may also disclose your personal information:

        • As required by law such as to comply with a subpoena or similar legal process. To the extent we are legally permitted to do so, we will take commercially reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of a legal process. Positive Grid also may be required to disclose personal information in response to lawful requests by public authorities, including requests from national security or law enforcement authorities.
        • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a written government request.
        • We will share your personal information with third parties only in the ways that are described in this Privacy Notice. We do not otherwise sell your personal information to third parties.

        How will the data be used?

        GENERAL PURPOSE FOR WHICH DATA ARE USED

        All personal data acquired and/or requested, either prior to or during the course of contractual relationship, will be used to fulfill your requirements, ensuring that the contractual obligations are met and administrative and legal obligations are provided correctly by the company Positive Grid, thereby allowing the business activities associated to its objectives to be conducted as efficiently as possible. The supply of data is not mandatory but is necessary in order to set up and execute this agreement; refusal to provide such data may therefore prevent the company from establishing a working relationship with you. Furthermore, your non-sensitive personal data provided with your express consent, revocable at any time, has been obtained, for the following additional uses:

        1. Inclusion in Positive Grid’s databases for the purpose of sending business notices/information relating to commercial activities conducted by Positive Grid.
        2. Use for statistical purposes in connection with promotional campaigns.
        3. Circulating of personal data, including in the form of images and/or videos within the company’s official website.
        PROCESSING METHODS

        Data will be processed using appropriate methods and tools that guarantee their confidentiality and may be processed using electronic or automated means (network data processing systems not accessible to the public) and using non-automated means (paper-based archives and records), both protected by appropriate security measures such as personalised passwords offering exclusive access, personal identity codes and limited access to records.

        Certain types of data that are considered sensitive by the law (such as data capable of revealing racial and ethnic origin, religious, philosophical or other convictions, political opinion, membership of political parties, trade unions, associations or organisations of a religious, philosophical, political or trade union nature, as well as personal data capable of revealing state of health or sexual activities), which we could be made aware, after being informed by yourself or after having processed documents furnished by you, at the start up or during the course of a working relationship with our Company, may only be used with your prior written consent.

        TRANSFER OF DATA

        Personal data supplied may not be transferred by our Company, except

        1. Only in the circumstances outlined by law, for the purpose of supplying the service requested and/or executing the agreement, in order to fulfill administrative, accounting and/or fiscal obligations referred to under point 1). In such circumstances, your express consent is not required, but failure to provide it will prevent the Company from setting up a working relationship or responding to your request;
        2. Solely to outside associates of the company Positive Grid, acting as tax and/or accountancy consultants, for the performance of the tasks described under point 1). Again, in these circumstances, your express consent is not required, but failure to provide it will prevent the Company from setting up a working relationship or responding to your request;
        3. To subsidiary companies and/or companies in which shares are held, sales networks (agents, dealers, collaborators and/or distributors), customer service and support agents, sub-suppliers and sub-contractors involved in conducting agreement / contractual or business relations.

        How do we protect our customer’s data?

        We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we collect from you.

        How long will the data be stored for?

        We will retain your information for as long as you maintain a GDPR Readiness Assessment account (if you are an EU user) with us and have not otherwise requested us to delete your information.

        Access to your information, correction, portability and deletion

        You are in complete control. You can object or withdraw your consent to the use of your personal data at any time.

        Subject to some legal exemptions, you have the right to:

        • Request a copy of the personal information Positive Grid holds about you;
        • To have any inaccuracies corrected;
        • To have your personal data erased;
        • To place a restriction on our processing of your data;
        • To object to processing; and
        • To request your data to be ported (data portability).

        Depending on the scope and nature of the work required to process your access request, we may require to impose a fee to recover our administrative costs involved.

        We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

        Please address any such requests to the Positive Grid Data Protection Officer by contacting privacy@positivegrid.com

        If you are dissatisfied with the way LearnTech processes your personal data you should formally raise such complaints with the Data Protection Officer (DPO).

        Privacy Policy
        Positive Grid
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        What is Positive Grid Mobile Messaging?

        By subscribing to Positive Grid mobile messages, you agree to receive autodialed marketing messages to the telephone number used at the time of opt in. Message frequency may vary. Message and data rates may apply. Consent is not required as a condition of purchasing any goods or services. In the event that you change or deactivate your mobile number, it is your responsibility to notify Positive Grid at help.positivegrid.com/hc/en-us/requests/new to have your number removed. Terms & Conditions are subject to change. The mobile carriers are not liable for delayed or undelivered messages. You can view our privacy policy by clicking www.positivegrid.com/pages/privacy-policy.

        Positive Grid Alerts Mobile Messages:

        Text advertised keyword to 53645 to receive promotional alerts from Positive Grid.

        Text STOP to 53645 to opt out.

        Text HELP to 53645, or submit a ticket at help.positivegrid.com/hc/en-us/requests/new for assistance.