NRG Training

PRIVACY POLICY

1. Our Sites
You may [buy, enrol, access, and complete a Course on our Sites.] The Site is owned and operated by Upskill Online Limited trading as Olive Media (referred to as “Olive” "we", "our", or "us"). We care about your privacy. This Policy, which applies to the Site, (together with our Website Terms of Use and any other documents referred to in the Site) explains how we collect and use your information. Please read it carefully. For questions about this Policy, or if you want to enforce your rights: please contact Olive’s Privacy Officer, Thomas Cullen at compliance@olivegroup.io. , or at +353 (0) 1411 1011.

2. Who we are
Olive is a limited company incorporated in Ireland with company number 470792, whose registered office is at The Glasshouse, GH1, Dun Laoghaire, Harbour Court, George’s Place, Dun Laoghaire, A96 P0A4 Co. Dublin, Ireland. Olive is registered as a data controller with the UK Information Commissioners Office, with registration number ZA313568. For the purpose of applicable data protection laws, Olive is the data controller of your Personal Information collected through the Site.
Definitions
“Personal Information” in this Policy means "Personal Data" as defined in the EU General Data Protection Regulation 2016/679(EU). In summary, it means information that identifies you, whether directly or indirectly, including for example your name, gender, address, email address, phone number, and any other information that you may voluntarily submit to us, as well as any online identifiers such as your clickstream data or IP address.
“Data Protection Laws” means the data protection and information privacy laws of Ireland and the European Union and includes any legislation in force from time to time which implements Directive 95/46/EC or Directive 2002/58/EC of the European Community, the Data Protection Acts 1988 and 2003 (as amended), and once applicable the General Data Protection Regulation (EU) 2016/679 (the "GDPR") and/or any corresponding or equivalent Irish laws or regulations, once in force and applicable.
“Data Processing” refers to any action performed on Personal Data, such as collecting, recording, organizing, storing, transferring, modifying, using, disclosing, uploading, or deleting.
“General Data Protection Regulation” means Regulation (EU) 2016/679, known as the General Data Protection Regulation (the “GDPR”);
“Special Categories of Data” has the meaning as set out in Data Protection Laws.

3. When do we collect information about you?
We collect Personal Information when you visit our platform or website, when you enroll for a Course and register for login details, when you email, call or write to us, or provide us with information in any other way, including by interacting with us via social media such as Facebook or Twitter. We also collect information when you take a Course or otherwise, use our apps, or if your company has provided your details to us to enable us to provide you with access to and use our courses or applications.

4. What types of personal information do we collect and process?
Each time you visit a Site we may automatically gather the following information:
(a) technical information about your computer such as domain name, browser type and version, operating system and platform, IP address, cookie information and time zone setting; and
(b) information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time), what web pages you visited on the Site and how long you spend on each page, page interaction information (such as scrolling, clicks and mouse-overs), page response times, download errors, traffic data, location data, weblogs, history of resources accessed on the Site, methods used to browse away from the page and information on what website you visited before accessing the Site.
We also process the following kinds of personal information if you provide it to us, or if your company provides it to us, or if it comes into existence by virtue of you taking a Course:
(a) Information about you, including your name, job title, address, email and other contact details;
(b) Information about the company you are associated with;
(c) Information about your use of our mobile applications, including information about which pages you view;
(d) Information concerning your progress in taking a Course including information concerning your performance in assessments and where appropriate, your entitlement to a certificate;
(e) Information you provide to us during communications you have with us and with our staff, for example comments or queries about the courses we provide.
(f) Information about the course or about the content that you provide, such as the location of the person or the date on which you posted a photo or created an event, what you see through features that we provide, so we can do things such as propose masks and filters that you might like or give you guidelines on using the same.

5. Why do we collect and use your Personal Information, and what are our lawful grounds for doing so?
We use your Personal Information for the following purposes:
(a) To process and respond to requests, enquiries and complaints received by you, in accordance with our legitimate interest to provide you with a responsive service.
(b) To track your progress through a Course, to assess your performance in assessments and to determine whether you have reached the standard which is required if you are to earn a certificate.
(c) To provide services and products requested by you. We do this as necessary to carry out our legitimate interest to operate a business which offers training courses.
(d) To communicate with you about services and/or products provided to you. We do this as necessary to carry out our legitimate interest to operate a business which offers training courses.
(e) To update our records and for audit purposes, in accordance with our legitimate interest to operate a business which offers training courses.
(f) To prevent or detect fraud, in accordance with our legitimate interest to do so.
(g) Where legally required or where it is in our legitimate interest to do so, to comply with requests from law enforcement and regulatory authorities.
(h) To analyse trends and profiles, for our legitimate interest to aim to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.
(i) To carry out customer satisfaction research, for our legitimate interest to aim to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.
(j) If you make enquiries through a Site and agree in the contact form to receiving email updates we will send you such updates on the grounds of your consent.
(k) To enable third parties to carry out any of the purposes set out above on our behalf. For this we use our legitimate interest to run our business as efficiently as possible.
(m) To create personalised services with clear recommendations and suggestions that are unique and relevant to users, we use users preferences, interests and activities based on the data that we collect and learn from users.
(n) To communicate with users about our services and let users know about the Policies and Terms as well as to respond to users when user contacts us.
This Policy applies to all Users of the Platform and the term "You" shall include Users. By submitting Personal Information, You are consenting to the collection, use and processing of such information in accordance with this Policy. If You have inadvertently submitted any Personal Information to us prior to reading this Policy statements set out herein, or You do not agree with the manner in which the Personal Information is collected, stored or used,then You may access, modify and delete all information stored about You by deleting your account or by writing to us at compliance@olivegroup.io.
We are keeping User's Personal Information and every User is also entitled to require us to delete and destroy all such information (but not that of other Users). We only collect information about You if we have a reason to do so — for example, to provide our Services on the Platform, to communicate with You, or to make our Services better.

6. Where we store your Personal Information
The Personal Information we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) as it may be processed by staff or service providers outside the EEA who work for us. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy, and that adequate measures are in place if the country in question is not deemed to provide the same level of protection for your data and rights as you would enjoy within the EEA. Personal Information may on occasion be accessed by Olives service providers located in India and Nepal. Contracts are in place with these service providers, incorporating the European Commissions approved model clauses, to ensure that any Personal Information involved is safe.

7. Disclosure of your Personal Information
We may disclose your Personal Information to companies within our corporate group. We will not share Personal Information collected through a Site with unrelated third parties, except as provided in this Policy.
We may disclose to your employer details concerning your progress in taking the Course, up to and including the award of a certificate.
We may share Personal Information with companies that we contract with to perform services for us, such as assisting us with administering or troubleshooting a Site, assisting us with the design of our courses, assisting us with our mailing campaigns, providing us with electronic or physical storage services, or other relevant data processing activities. We will only share your information in these circumstances if it is necessary to do so in order for our service providers to perform the service for us. These companies are not authorised to keep or use your Personal Information for any other purpose.
We may disclose your Personal Information to selected third parties such as law enforcement agencies or our professional advisors if we are under a duty to do so in order to comply with any legal obligation, or in order to enforce or apply our Website Terms of Use or other related contracts with you or your company.
If we sell all or any part of our business, the parties which buy it may have access to your Personal Information.

8. How long do we keep your Personal Information?
We hold your Personal Information for as long as we need to for legitimate legal or business reasons, including to comply with any regulatory obligations. Personal Information collected through a Site may be kept as follows:



If you would like more detailed information about our retention policy, please email us at compliance@olivegroup.io or use one of the other methods in the "Contact us" section below.

9. Security We aim to ensure that your Personal Information is secure. In order to prevent unauthorised access or disclosure, we have appropriate physical, technical and organisational measures to safeguard and secure the Personal Information we collect. Our service providers are required to do the same. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information once we receive it, we cannot guarantee the security of your data transmitted to a Site; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and use leading technologies and encryption software to safeguard your data, and keep strict security standards to prevent any unauthorised access.
While using some third parties services for the purpose of payment processing, research or statistical data analysis, some personal information may be transferred to those third parties. We remain responsible for your information when shared with third parties, and shall instruct such third parties to abide by the GDPR rules.
All private information like User’s email address, access log-in can be accessed only by providing User’s password.

10. Cookies
Each Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse a Site and also allows us to improve the Site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

11. Links to other Website
A Site may contain links to the website of other companies and organisations which may be of interest (“Third Party Site”). If you decide to leave the Site and access the Third Party Sites or to use or install any Third Party Applications, Software or Content, you do so at your own risk and you should be aware that our terms and policies no longer govern. You should review the applicable terms and policies, including privacy and data gathering practices, of any site to which you navigate from the Site or relating to any applications you use or install from the site.

12. Controlling your Personal Information
You have the right to ask us not to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your Personal Information, by clicking "unsubscribe" in any of our marketing emails to you, or by contacting our Privacy Officer at any time at compliance@olivegroup.io. We will not sell your Personal Information collected through a Site with any third party.

13. Access to your Personal Information, deletion, restriction, rectification and transfer
You have the right to request details (and a copy of) the Personal Information we hold about you and to ask us to delete, restrict (stop using), correct (rectify) or transfer (port) your Personal Information. Our response to your requests may depend on which legal grounds we are using to process the data in question (see section above). For more information about your rights under the General Data Protection Regulation please see the UK Information Commissioners Office guidance here.
You can exercise your rights by sending us a written request using our contact form, or by contacting our Privacy Officer, Thomas Cullen: by email at compliance@olivegroup.io; by telephone at +353 (0)1 411 1011; by post at The Glasshouse, GH1, Dun Laoghaire, Harbour Court, George’s Place, Dun Laoghaire, A96 P0A4 Co. Dublin, Ireland. With each request please include identification information (a copy of your passport or driving licence and a recent utility bill). Please be as specific as possible in your request about your requirements, so that we can respond to you as quickly as possible.

14. Complaints to the ICO
If you are unhappy with us, our service, or with the way that we treat your Personal Information, please contact us. You also have the right to contact the UK data protection authority, the Information Commissioner's Office (ICO), or your local data protection authority if you are not based in the UK. You can contact the ICO through its website at https://ico.org.uk/global/contact-us/, or on its helpline on 0303 123 1113 (if calling from the UK) or +44 1625 545 745 (if calling from outside of the UK).
However, we would appreciate it if you would contact with us first so that we can endeavour to resolve any issues that you might have. Our contact details are set out below.

15. Changes to this privacy policy
Any changes we may make to our Policy in the future will be posted on this page and, where appropriate and feasible, notified to you by email. Please check these Terms and any policies periodically for changes. User’s continued use of the Site after the changes become effective constitutes the binding acceptance of such changes. Except as stated elsewhere, such amended Terms will automatically be effective upon the earliest of (a) the User’s ongoing use of the Site with actual notice of the new terms, or (b) 30 days after we have posted notice of the new terms on this page.

16. Contact us
If you have any questions or comments about this Policy, or if you wish to exercise your rights, please contact Olive’s Privacy Officer for queries or requests relating to taking a Course: Olive’s Privacy Officer for queries or requests relating to taking a Course:

By email: compliance@olivegroup.io
By telephone: +353 (0) 1 411 1011
By post: Thomas Cullen, Upskill Online Limited, The Glasshouse, GH1, Dun Laoghaire, Harbour Court, George’s Place, Dun Laoghaire, A96 P0A4 Co. Dublin, Ireland.