PRIVACY AND COOKIE POLICY

This Privacy Policy was last updated on 5 March 2019.

Privacy policy

Webing Ltd (“Webing”, “we”, “us”) respects your privacy and informs you how we collect and use your information. This Privacy Policy covers our data collection practices and describes your rights to access and modify your personal information or to restrict its use.

Unless otherwise provided, this Privacy Policy applies when you visit or use the website or related services (the “Services”) of Webing.

By using the Services, you agree to the terms of this Privacy Policy. Do not use the Services if you do not intend to accept the Privacy Policy or other agreements governing your use of the Services.

What data we collect

We collect certain data directly from you, such as information you enter, data about the courses you take and data from third-party platforms to which you connect with Webing. We also automatically collect certain data, such as information about your device and the parts of our Services that you use or interact with.

1.1 Data provided directly by you

We may collect various data from or about you, depending on how you use the Services. Below are some examples to help you understand what data we collect.

When you create an account and use the Services, including through a third-party platform, we collect data provided directly by you, including:

Account data In order to use certain functions (e.g. course registration), you must create a user account. When you create or update your account, we collect and store the data you provide, such as your e-mail address, password, and company data and assign you a unique identification number (‘Account Data’).
Shared content Some parts of the Services allow you to interact with other users or share content publicly, for example by posting reviews on a course page. This shared content may be publicly visible, depending on where it was posted.
Course data When you enrol for a course, we collect certain data such as the course, the date of enrolment and if it is an online course we may record the lessons you see and the downloads.
Payment Data – Students If you purchase a course, we collect certain information about your purchase (e.g. your name and postcode), which is necessary to process your order. You will be asked to provide certain information such as your name, credit card details, billing address and postcode directly to our payment processing partners. For security reasons, Webing does not collect or store sensitive credit card information, such as your full credit card number or credit card authentication data.
Your account data on other services We may obtain certain information through your social media accounts or your other online accounts if they are linked to your Webing account. If you access Webing through Facebook or another third-party platform or service, we ask for your permission to access certain information on that other account. For example, depending on the platform or service, we may collect your name, profile picture, account ID number, the email address used to sign in, location, the physical location of your access devices, gender, date of birth, and list of friends or contacts.

These platforms and services allow us to access this information through the APIs they use. The information we receive depends on the information that you (via your privacy settings) or the platform or service decide to provide to us.

If you access or use our Services through a third-party platform or service, or if you click on third-party links, the collection, use and sharing of your information will also be subject to the privacy policies and other agreements entered into with those third parties.

Competitions, promotions and surveys Webing may invite you to take a survey or participate in a promotion (such as sweepstakes) through the Services or through a third-party platform. If you participate, we will collect and store the information you provide for the purposes of this participation, such as your name, email address, date of birth or phone number. The data is subject to this Privacy Policy unless otherwise stated in the official promotion rules or another Privacy Policy. The data collected will be used to administer the promotion or survey, as well as to contact winners and award prizes. In order to receive your prize, you may be required to post certain information (for example, on the winner’s page). In the event that we use third-party platforms to administer the survey or promotion, the Privacy Policy of the third-party in question will apply.
Communication and support When you contact us for support or to report a problem or concern (whether or not you have created an account), we may collect and store your contact information, messages, and other data about you, such as your name, your email address, your location, your operating system, your IP address, and any other data you provide to us or that we may collect through automated means (discussed below). The data collected in this way is used to respond to you and to investigate your question or concern in accordance with this Privacy Policy.

 

The above data may be stored by us and associated with your account.

1.2 Data we collect by automated means

When you access the Services (even if only to consult the courses), we collect by automated means specific data including:

System Data Technical data about your computer or device, device type, operating system type and version, unique device ID, browser, browser language, domain and other system data and platform type (“System Data”).
Usage data Usage statistics about your interactions with the Services, including the courses you select, the time you spend on the pages of the Service, the pages you visit, the functions you use, the searches you perform, the clicks you make, the date and time and other data about your use of the Services (“Usage Data”).
Geographical approximation data Approximate geographic location, including information such as country, city and geographical coordinates.

The above-mentioned data is collected through Google Analytics and tracking technologies, as detailed in the following section ‘Cookies and data collection tools’. This data is not associated with your account.

2. How we collect data

We use tools such as cookies, web beacons, analytics services and advertising service providers to collect this information. Some of these tools allow you to disable data collection.

2.1 Cookies and data collection tools

As detailed in our Cookie Policy, Webing and service providers acting on its behalf (such as Google Analytics and third-party advertisers) make use of server logs and automatic data collection tools, such as cookies, tags, scripts, custom links, device or browser fingerprints, and web beacons (collectively, “Data Collection Tools”) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (described in more detail in Section 1) when you use the Services. In some cases, we link the data collected through these Data Collection Tools to other information that we collect in accordance with the procedures described in this Privacy Policy.

We use cookies (small files that websites send to your device to uniquely identify your browser or device or to enter data into your browser) for various purposes, such as to analyse your use of the Services, personalise your experience, facilitate your access to the Services and recognise you when you log in again. We use web beacons (small objects that allow us to measure the actions of visitors and users of the Services) for various purposes, such as to learn whether a page was visited or an email was opened, and provide more targeted advertising by excluding certain users from certain promotional messages.

Webing uses the following types of cookies:

  • Preferences: cookies that remember information about your browser and your preferred settings that determine the appearance and behaviour of the Services.
  • Security: cookies that enable you to access the Services, protect your account from unauthorised access and detect and prevent misuse or unauthorised use of your account.
  • Session Status: cookies that track your interactions with the Services to help us improve them and your browsing experience, remember your login details and allow processing of course purchases. These cookies are strictly necessary for the proper functioning of the Services, so if they are disabled, some features may no longer work or may not be available.

You can set your browser to alert you when cookies are being placed on your computer, limit the type of cookies allowed, or reject them altogether. However, if you do so, you may not be able to use some or all features of the Services and your experience may be different or less functional.

Some of the third-party partners who provide certain functions on our site may also use Local Storage Objects (also known as LSOs or Flash cookies) to collect and store data.

2.2 Analysis

In its Services, Webing uses third-party analytics services for browsers and mobile devices, such as Google Analytics. These services use Data Collection Tools that allow us to analyse your use of the Services by providing information regarding, for example, the third-party website from which you arrived at us, the frequency of your visits, events that occur on the Services, usage and performance data, and the source from which the application was downloaded. We use this data to improve the Services, better understand how the Services work across devices and provide information that may be of interest to you.

2.3 Online Advertising

We use third-party advertising services such as Facebook, Google and other ad networks and ad servers to advertise our Services on other websites or other applications that you use. Advertisements may be based on things we know about you, such as your Usage Data and System Data (as detailed in Section 1) and things these advertising service providers know about you based on their tracking data. Advertisements may be based on your recent activity or activity over time on other sites and services and may be tailored to your interests.

Depending on the type of advertising service you use, cookies or other tracking technologies may be placed on your computer, phone or another device to collect data about your use of the Services and these tracking technologies may be used to serve you personalized advertisements. To help personalize advertisements, Webing may provide these advertising service providers with a hashed version (in a non-human readable format) of your email address and the content you publicly share on the Services.

If you use mobile applications, you may also receive customised in-app advertisements. Apple iOS, Android OS and Microsoft Windows all provide their own instructions on how to control this type of advertising. For other devices and operating systems, we recommend you consult your privacy settings or contact your platform operator.

3. What do we use the data for

We use your information for a variety of purposes, such as to offer our Services, communicate with you, troubleshoot problems, prevent fraud and abuse, improve or update the Services, analyse your use of our Services, and provide you with personalised advertisements, as required by law or necessary to protect your security and integrity.

We use the data we collect through your use of the Services to:

  • offer and manage the Services, e.g. to display personalised content and facilitate communication with other users;
  • process your requests and orders concerning courses, products, specific services, information or functions;
  • communicate with you about your account:
    • answering your questions and doubts;
    • sending you administrative messages and information, including coach messages, notifications of changes to the Services and updates to our agreements;
    • sending you information and messages about your progress in courses, rewards programmes, new services, new features, promotions, newsletters and other available courses (which you can deactivate at any time);
  • manage your account preferences;
  • facilitate the technical operation of the Services, including troubleshooting, securing the Services and preventing fraud and abuse;
  • request feedback from users;
  • distribute and administer surveys and promotions managed or sponsored by Webing;
  • learn more about you by linking your data to other information through third-party data providers or by analysing the data with the help of analysis service providers;
  • uniquely identify users on different devices;
  • customise advertisements on different devices;
  • improve Services and develop new products, services and functions;
  • analysing trends and traffic, tracking purchases and tracking Usage Data;
  • advertise the Services on third-party websites and applications;
  • as required or permitted by law; or
  • as deemed necessary by Webing, in its sole discretion, to ensure the safety or integrity of its users and employees, third parties, the public or its Services.

4. With whom we share data

Webing shares certain information about you with coaches, other students, analytics and data enrichment providers, your social media providers and advertising companies that help Webing promote its Services. Webing may also share data about you for security or legal compliance purposes. Finally, it may share data in other ways if it is aggregated or anonymised or if it obtains your consent.

Webing may share your data with third parties in the following circumstances or as otherwise described in this Privacy Policy:

  • With your coaches: We share data about you (excluding your e-mail address) with coaches about the courses you enrol in or request information about, to enable them to improve the courses for the benefit of you and other students.
  • With other students: Depending on your settings, your profile data and shared content may be publicly visible, including to other students and coaches. If you pose a question to a coach, your information (including your name) may also be visible to other users, depending on your settings.
  • With service providers, and contractors: We share your data with third party companies that perform services on our behalf, such as payment processing, data analysis, marketing and advertising services (including retargeting), customer service and support. These service providers have access to your personal data and are only obliged to use it in accordance with our guidelines, in order to provide the service we have requested.
  • To improve social media features: The social media features of the Services (such as the Facebook Like button) may allow the third-party social media provider to collect items such as your IP address and the page of the Services you are visiting and set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s Privacy Policy.
  • To administer promotions and surveys: we may share your data, if necessary, to administer, advertise or sponsor promotions and surveys in which you have chosen to participate, as required by applicable law (e.g. by providing the list of winners or depositing the required documentation) or in accordance with the rules of the promotion or survey.
  • For reasons of security and legal compliance: Webing reserves the right to disclose your data to third parties if (in its sole discretion) it believes in good faith that such disclosure is:
    • permitted or required by law;
    • requested as part of a judicial, governmental or legal investigation, order or proceeding;
    • reasonably necessary following a valid subpoena, warrant or other legally valid requests;
    • reasonably necessary to enforce our Terms of Use, this Privacy Policy and other legal agreements;
    • required to identify, prevent or resolve cases of fraud, abuse, misuse, a potential violation of the law (or rules/regulations) and/or technical or security problems; or
    • reasonably necessary, in its sole discretion, to ensure protection from imminent harm to the rights, property or safety of Webing, its users and employees, members of the public and/or the Services.
    • Webing may also disclose information about you to its auditors or legal advisors to assess your rights and/or disclosure obligations under this Privacy Policy.
  • During a Change in Control: In the event of a change in Webing’s corporate structure, such as a merger, acquisition, divestiture or dissolution or the sale of all or a portion of its assets, Webing may share, disclose or transfer all of your information to its successor organisation during or in anticipation of such a transition (including during the due diligence phase).

5. Security

Webing takes security measures appropriate to the type and sensitivity of the data being stored. As with any Internet-enabled system, there is always the risk of unauthorised access: it is, therefore, important to protect your password and to promptly report to us any suspicions of unauthorised access to your account.

Webing takes appropriate security measures to ensure protection against unauthorised access, modification, disclosure or destruction of the personal data it collects and stores. These measures vary depending on the type and sensitivity of such data. Unfortunately, however, no system is totally secure, so we cannot guarantee that communications between you and Webing, the Services or any information you provide to us in connection with data we collect through the Services will be immune from unauthorised access by third parties. Your password is an important component of our security system and it is your responsibility to adequately protect it. Do not share your password with any third-party and, if you believe that it or your account has been compromised for any reason, change it immediately and write to [email protected] to make your case.

6. Your rights

You are granted certain rights over your data, including the ability to refuse your consent to the sending of promotional emails, the use of cookies and the collection of data by certain data analysis service providers. You can update or close your account directly from the Services or contact us with enquiries about your rights regarding your personal data.

6.1 Options available to you regarding the use of your data

You may choose not to provide us with certain data, but then you may not be able to use certain features of the Services.

  • If you do not wish to receive promotional communications from us, you may follow the unsubscribe procedure provided in the promotional communication you received. Please note that regardless of your email preferences, we will still send you transactional and relational messages about the Services, including administrative confirmations, order confirmations, important updates about the Services and notices about our policies.
  • The browser or device you use may allow you to control cookies and offer other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared.
  • To obtain information and control the cookies used for personalised advertisements by participating companies, please visit the Network Advertising Initiative and Digital Advertising Alliance opt-out pages or, if you reside in the European Union, visit Your Online Choices. To turn off Google Display advertising or customise Google Display Network ads, visit the Google Ads Settings page.
  • To prevent Google Analytics from using your data for analysis or enrichment purposes, see: Browser add-on for deactivating Google Analytics.

If you have any questions about your data, our use of your information or your rights, please contact us at [email protected].

6.2 Accessing, updating and deleting your personal data

You can access and update the personal data that Webing collects and stores by following these steps:

  • To update the data provided directly by you, log in to your account and update it at any time.
  • To close your account:
    • Email us at [email protected].
    • Note: Even after your account has been closed, some or all of your data may continue to be visible to others, including, without limitation, data that has been (a) copied, stored, or disseminated by other users (e.g., in public comments); (b) shared or disseminated by you or others (e.g., in your shared content); or (c) posted on a third-party platform. Even after your account is closed, Webing will retain your information for as long as it is deemed necessary for any lawful purpose (and in accordance with applicable law), such as fulfilling legal obligations, resolving disputes, and complying with the terms of our agreements. Webing may retain and disclose such data under this Privacy Policy after your account has been closed.
  • To request access, correction or deletion of your personal data, please send an e-mail to [email protected]. It may take up to 30 days to receive a response. For your protection, we may require that the request be sent via the e-mail address associated with your account and we may need to verify your identity before implementing your request. Please note that we retain certain data in cases where there is a legal basis for doing so, such as for mandatory record-keeping and completion of transactions.

6.3 Protection of minors

We recognise the importance of protecting the privacy of children and encourage parents and guardians to play an active role in monitoring the online activities and interests of their children. Children under the age of 13 (or 16 in the European Economic Area) are not allowed to use the Services. In the event that we learn that we have collected personal data from persons under the age of 13, we will take all reasonable steps to delete such data.

If a parent has reason to believe that Webing has collected personal data from a child under the age indicated, he or she may send a request to [email protected] for such information to be removed.

7. Updates and contact information

In the event that we make a material change to this policy, we will notify users by e-mail, by a notice in our products, or by another mechanism required by law. Changes will take effect on the day they are published. If you have any questions, concerns or issues, you may contact us by e-mail or regular mail.

7.1 Amendments to this Privacy Policy

We may periodically update this Privacy Policy. If we make a material change to this Policy, we will notify you by email, by means of a notice posted on the Services or by the mechanism provided by applicable law. We will also include a summary of the major changes. Unless otherwise indicated, changes will take effect on the day they are posted.

To the extent permitted by law, if you continue to use the Services after an amendment goes into effect, your access and/or use of the Services will be deemed an implied acceptance of the amended Privacy Policy and your obligations thereunder. The amended version supersedes all previous versions of the Privacy Policy.

Cookie Policy

This Privacy Policy was last updated on 24 May 2018

What are cookies?

Cookies are small text files that are stored by your browser as you browse the Internet. They can be used to collect, store and share data about your activities on Web sites, including Webing’s Web site. Cookies also allow us to remember certain elements of your visits to Webing.

We often use both session cookies, which expire after a short period or when you close your browser, and persistent cookies, which are stored in your browser for a predefined period of time. Session cookies allow us to identify you during a single browsing session, for example when you log in to Webing. Persistent cookies are used to identify you over a longer period of time, for example when you request us to maintain your access.

Why does Webing use cookies and similar technologies?

We use cookies and other similar technologies, such as web beacons, pixel tags or local shared objects (“flash cookies”), to provide, measure and improve our Services in various ways. We use these cookies when you visit our Site and Services either through your browser or through our mobile app. As we adopt new technologies, we may collect other data through other means.

We use cookies for the following purposes:

Authentication and security
  • To give you access to our websites
  • To protect your safety
  • To detect and combat spam, abuse and other activities that violate Webing’s agreements

For instance, cookies help authenticate your access to our sites and prevent unauthorised parties from gaining access to your accounts.

Preferences
  • To remember your browser data and preferences
  • To remember your settings and other choices you have made

For example, cookies help us remember your preferred language or the country you are in, enabling us to offer you content in that language without requiring it every time you visit us.

Analysis and research
  • To help us improve and understand how people use Webing

For example, cookies help us test different versions of our websites to understand which functions or content are preferred by users, web beacons let us know which e-mail messages have been opened, and cookies help us understand how you interact with our sites, e.g. which links you clicked on, etc.

Webing works with a number of analytics partners, including Google Analytics, who use cookies and similar technologies to help us analyse your use of the Services by, for example, identifying which sites you came from. These service providers may either collect data directly or obtain it from us.

You can deactivate some of these services by visiting the pages Browser add-on for deactivating Google Analytics.

Customised content
  • To customise Webing with more relevant content

For example, cookies help us to show you a personalised list of recommended courses on the home page.

Advertisement
  • To offer you more targeted advertising

 

To learn more about targeting and advertising cookies and how to deactivate them, visit Your Online Choices.

Please note that where advertising technology is integrated into the Services, you may continue to receive advertising on other websites and applications, but it will not be customised to your interests.

If you use mobile applications, you may also receive customised in-app advertisements. Apple iOS, Android OS and Microsoft Windows all provide their own instructions on how to control this type of advertising. For other devices and operating systems, we recommend you consult your privacy settings or contact your platform operator.

What are my privacy options?

You have numerous options to control or limit the use of cookies by us and our partners:

  • Most browsers automatically accept cookies, but you can change your browser settings to refuse cookies by consulting the browser support articles. If you choose to reject cookies, please note that you may not be able to access, customise or use certain interactive features of the Services.
  • Flash cookies work differently from browser cookies, so your browser’s cookie management tools may not be able to reject them. To learn more about flash cookies, please see the Flash Cookie Management article and Adobe’s Web Site Storage Settings page.
  • To obtain information and control the cookies used for personalised advertisements by participating companies, please visit the Your Online Choices opt-out pages. To disable Google Analytics display advertising or customise Google Display Network ads, please visit the Google Ads Setup page.
  • For general information on targeting cookies and how to deactivate them, visit www.allaboutcookies.org.

Updates and contact information

We may update this Cookie Policy from time to time. If we do, we will notify you by posting the policy on our site with a new effective date. If we make any material changes to the policy, we will take reasonable steps to notify you in advance of anticipated changes.

If you have any questions about how we use cookies, you can contact us by writing to [email protected].