SoftEd (we, us, our) complies with all applicable privacy and data protection laws when dealing with personal information. Personal information is information about an identifiable individual (a natural person).

SoftEd includes Skills Consulting Group Limited and its wholly-owned subsidiaries.

This policy sets out how we will collect, use, disclose and protect your personal information when you access and use our website at www.softed.com, or our services, or have other dealings with us.  

If you are based in the European Union and use our website and/or services, the additional terms in the addendum to this policy (GDPR Addendum) apply to you.

This policy does not limit or exclude any of your rights under applicable laws.  
 

Changes to this policy

We may change this policy by uploading a revised policy onto the website.  The change will apply from the date that we upload the revised policy. 

This policy was last updated on 13 July 2018.  

 

Who do we collect your personal information from?

We collect personal information about you from:

  • you, when you provide that personal information to us, including via the website and any related service, through any registration or subscription process or the creation or administration of a customer account, through any contact with us (e.g. telephone call or email), or when you buy or use our services and products, including participation in and of our Courses (as defined in our terms and conditions, available here)
  • third parties where you have authorised this including our partners (e.g. our events and advertising partners), social networks, third party analytics services or the information is publicly available. 

If possible, we will collect personal information from you directly. 

When you visit or use the website or services, we may collect information about you:

  • by recording clickstream data, which is non-personal information that is recorded when you click anywhere in a webpage and is used for the purposes of collecting, analysing and reporting data about how you use the website
  • through the use of cookies. Please refer to our Cookies Policy for more information. 

 

What personal information do we collect?

When you visit the website or use our services we collect the following information:

  • usage data – e.g. your IP address, geographical location, device type, browser type, website engagement
  • profile data – e.g. your name, job role, address, phone number, email address
  • enquiry data – e.g. information contained in any enquiry you submit to us regarding our services
  • account data – e.g. your name and email address
  • transaction data – e.g. your purchase history and other information relating to your transactions with us
  • learning record – e.g. the courses you have attended and any certifications gained
  • billing data – e.g. credit card and other information you submit to us to billing purposes. We use Payment Express in New Zealand and Australia and PayPal in all other locations to process credit card transactions.  We do not have access to your credit card information. 
  • subscription data – e.g. information you provide to us for the purposes of subscribing to our newsletters 

 

How we use your personal information?

We will use your personal information: 

  • to verify your identity
  • to provide our website and our services and products to you
  • to market our services and products to you, including contacting you electronically (e.g. by email for this purpose) that you may choose (or opt in) to receive.  You can stop receiving our promotional emails by following the unsubscribe instructions included in those emails.
  • to improve our website and the services and products that we provide to you
  • to confirm accreditation eligibility and distribute applicable certifications to you
  • to tailor content or advertisements to you
  • to respond to communications from you, including a complaint
  • to conduct research and statistical analysis (on an anonymised basis)
  • to protect and/or enforce our legal rights and interests, including defending any claim
  • for any other purpose authorised by you, the NZ Privacy Act or other applicable law
  • to respond to lawful requests by public authorities, including to meet law enforcement requirements

  • to transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition  

Disclosing your personal information

We may disclose your personal information to: 

  • another company within the SoftEd Group for the purposes described in this policy
  • any business that supports our services, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the website or other services and products or that we use to process payments
  • accreditation bodies for the purposes of gaining accreditation associated with the courses delivered by SoftEd
  • our trusted licensing partners where necessary for providing our services to you
  • other third parties (for anonymised statistical information)
  • a person who can require us to supply your personal information (e.g. a regulatory authority)
  • any other person authorised by applicable law (e.g. a law enforcement agency)
  • our professional advisers e.g. accountants, lawyers, auditors
  • any other person authorised by you
  • any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition
  • (for some courses), another specialist training provider, with whom we act as a reseller partner, this is to ensure you access the course with ease and obtain relevant certification

We share information about your use of the website with our trusted social media, advertising and analytics partners through the use of cookies and similar storage technologies.  Please refer to our Cookies Policy for further information. 
 


Transfers of personal information

A business that supports our services and products may be located outside of the countries in which we operate or the European Economic Area (EEA).  This may mean your personal information is held and processed outside of the areas in which we operate or the EEA. Please see the GDPR Addendum for further information about personal data transfers from the EEA.  

 

Protecting your personal information

We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse.  We implement appropriate technical and organisational measures to ensure a level of security appropriate to risks inherent in processing personal information.

You can play an important role in keeping your personal information secure by maintaining the confidentiality of any password and accounts used in relation to our products and services.  Please do not disclose your password to third parties.  Please notify us immediately if there is any unauthorised use of your account or any other breach of security. 

 

Accessing and correcting your personal information

Subject to certain grounds for refusal set out in applicable law, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information.  Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction.  If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.

If you want to exercise either of the above rights, email us at [email protected].  Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting). 

 

Internet use

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.

If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal information.  We suggest you review that site’s privacy policy before you provide personal information. 

 

Contact us

If you have any questions about this privacy policy, our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us at [email protected].

 

GDPR ADDENDUM

If you are based in the European Union (EU) and use our website and/or our services, these additional terms (GDPR Addendum) form part of our privacy policy.

The General Data Protection Regulation (GDPR) regulates the collection, processing and transfer of EU individuals’ personal data (as defined in the GDPR).  The personal information described in our privacy policy is personal data under the GDPR.  We are committed to complying with the GDPR when dealing with personal data of our website visitors and service users based in the EU.

For the purposes of the GDPR, we are the data controller (as defined in the GDPR) when processing personal data collected by us through the website and/or when you use our services, as further described in our privacy policy.

This GDPR Addendum was drafted with brevity and clarity in mind.  It does not provide exhaustive detail of all aspects of our collection and use of personal data.  However, we are happy to provide any additional information or explanation needed.  Any requests for further information should be sent to [email protected]. 
 

Processing personal data

The personal data we may process consists of the personal information described in our privacy policy.  This personal data may be processed for the purposes outlined in our privacy policy. 

We conduct automated decision making, including automated marketing and automated customer communications following course or event registration.

The legal basis for our processing of personal data is your consent, and for certain personal data,  processing is necessary for the performance of a contract to which you are a party or is necessary for the purposes of our legitimate interests (except where such interests are overridden by your fundamental rights and freedoms which require protection of personal data). 

Despite the above, we may process any of your personal data where such processing is necessary for compliance with applicable laws.

You do not have to provide us with usage data to access and use the website.  However, you must provide us with personal data e.g. email addresses when using some of our services such as signing up for our newsletter.  You will also be required to provide personal data e.g. your name, email, role, contact details and dietary requirements and billing data to register a course booking via our website. The consequence of not providing this data is that we will not be able to provide all of our services to you. 
 

Your rights

Your rights in relation to your personal data under the GDPR include:

  • right of access - if you ask us, we will confirm whether we are processing your personal data and provide you with a copy of that personal data.
  • right to rectification - if the personal data we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed.  We will take every reasonable step to ensure personal data which is inaccurate is rectified.  If we have shared your personal data with any third parties, we will tell them about the rectification where possible.
  • right to erasure - we delete your personal data when it is no longer needed for the purposes for which you provided it.  You may request that we delete your personal data and we will do so if deletion does not contravene any applicable laws.  If we have shared your personal data with any third parties, we will take reasonable steps to inform those third parties to delete such personal data.
  • right to withdraw consent - if the basis of our processing of your personal data is consent, you can withdraw that consent at any time.
  • right to restrict processing - you may request that we restrict or block the processing of your personal data in certain circumstances.  If we have shared your personal data with third parties, we will tell them about this request where possible.
  • right to object to processing - you may request that we stop processing your personal data at any time and we will do so to the extent required by the GDPR.
  • rights related to autonomous decision making, including profiling –you have a right to not be subject to a decision based solely on automated processing including processing, which produces legal effects concerning you or similarly significantly affects you, except where such automated decision making is necessary for entering into, or the performance of, a contract with you, is authorised by applicable laws or is based on your explicit consent.
  • right to data portability - you may obtain your personal data from us that you have consented to give us or that is necessary to perform a contract with you.  We will provide this personal data in a commonly used, machine-readable and interoperable format to enable data portability to another data controller.  Where technically feasible, and at your request, we will transmit your personal data directly to another data controller.
  • the right to complain to a supervisory authority - you can report any concerns you have about our privacy practices to the relevant data protection supervisory authority.

Where personal data is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.

If you would like to exercise any of your above rights, please contact us at [email protected] If you are not satisfied by the way your query is dealt with by our data protection officer, you may refer your query to your local data protection supervisory authority e.g. in the United Kingdom, this is the Information Commissioner’s Office. 

 

Children

We do not intend to collect personal data from children aged under 16.  If you have reason to believe that a child under the age of 16 has provided personal data to us through our website and/or by using our services, please contact us at [email protected].  

 

International transfer of data

The personal data we collect through our website and/or the provision of services may be transferred to, and stored in, a country operating outside the European Economic Area (EEA).  Under the GDPR, the transfer of personal data to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection.  In the absence of an adequacy decision, we may transfer personal data provided appropriate safeguards are in place.

Some of the personal data we collect is processed in New Zealand (where our head office is located).  New Zealand is recognised by the European Commission as a country that ensures an adequate level of data protection and we rely on this decision in transferring personal data to New Zealand.

Some of the personal data we collect is processed by third party data processors in other countries, including the United States.  Where personal data is transferred outside the EEA, it will only be transferred where the transfer complies with the GDPR (e.g.  to organisations in the United States under the EU-U.S. Privacy Shield framework or by entering into the European Commission’s Standard Contractual Clauses).  For further information, please contact us using the details set out in set out in our privacy policy. 


Data retention policy

Personal data that we collect and process will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer. 
 

Contacting us

You can contact us at [email protected].