Welcome to the StudyLearnGrow privacy policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our online portal. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
StudyLearnGrow available at: https://www.studylearngrow.com/ (our portal) is provided by StudyLearnGrow, a trading name of Webosaurus Limited, a company registered in England and Wales at Companies House under number: 09516516 and with a registered office at: The Broadgate Tower 12th Floor, 20 Primrose Street, London, England, EC2A 2EW (‘we’, ‘our’ or ‘us’). We are registered with the privacy watchdog, the Information Commissioner’s Office in the UK, under number ZA341877.
We are the controller of personal data we obtain about you via our portal, meaning we are the organisation that is legally responsible for deciding how and for what purposes it is used.
We collect, use and are responsible for certain personal data about you. When we do so, as we are a business established in the United Kingdom, we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals and our wider operations in the European Economic Area (EEA) and, where applicable, national data protection laws applicable to us and our activities in the countries in which we operate and/or where users access and use our portal.
Given the nature of our portal, we do not generally expect to collect the personal data of anyone under 13 years of age. If you are under 13 years of age, your parent or guardian must allow you and authorise you to allow you to use our portal, which they must attest to when you sign up, or log-in or interact with any of the services or other users on our portal. Your parent or guardian is responsible for your overall use of our portal. This version of our privacy policy is primarily written for adults, including parents and guardians of child users.
This privacy policy is divided into the following sections:
This privacy policy relates to your use of our portal only.
This privacy policy applies to you whether you are a student, a jobseeker, an education provider or an employer. Any specific parts which apply to you depending on your user-status on the portal will be indicated in the relevant part. Otherwise, the entire privacy policy applies to you, regardless of your user-status.
Throughout our portal we may link to other websites owned and operated by certain trusted third parties to make their training, education and recruitment services available to you). Those other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.
The personal data we collect about you depends on the particular activities carried out through our portal and whether you are a student, a jobseeker, an education provider or an employer.
If you are a student, we will collect and use the following personal data about you:
If you are a job seeker, we will collect and use the following personal data about you:
If you are an education provider or an employer, will collect and use the following personal data about you:
If you do not provide personal data we ask for required, it may delay or prevent us from providing our services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
We collect personal data from you:
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Create and manage your account with us | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Providing services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: To comply with our legal and regulatory obligations In other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others |
| Customise our portal and its content to your particular preferences based on a record of your selected preferences or on a record of your selected preferences | Depending on the circumstances: Your consent as gathered by the separate cookies tool on our portal —see ‘Cookies and other tracking technologies’ below Where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as possible we can so we can deliver the best services to you, to provide you with services you have requested and to be able to ensure that our portal is being used correctly by the various users |
| Retaining and evaluating information on your recent visits to our portal and how you move around different sections of our portal for analytics purposes to understand how our users use our portal so that we can make it more intuitive or to check our portal is working as intended, and that users are respecting the terms of use of our portal or the terms of our underlying agreements with them | Depending on the circumstances: Your consent as gathered by the separate cookies tool on our portal —see ‘Cookies and other tracking technologies’ below Where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as possible we can so we can deliver the best services to you, to provide you with services you have requested and to be able to ensure that our portal is being used correctly by the various users |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to our services and the services available via our portal or other important notices | Depending on the circumstances: To comply with our legal and regulatory obligations In other cases, for our legitimate interests or those of a third party, i.e. to be as efficient as possible we can so we can deliver the best services to you, to provide you with services you have requested and to be able to ensure that our portal is being used correctly by the various users |
| Protecting the security of systems and data and our portal including through the use of third party providers to do so, who assist us with verification of IP addresses, email addresses and telephone numbers as part of our fraud prevention exercise. | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e. to protect systems and data and to prevent and detect criminal activity or other fraudulent or dishonest behaviour or practices that could be damaging for you and/or us |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, our services and offerings or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as possible we can so we can deliver the best services to you, to provide you with services you have requested and to be able to ensure that our portal is being used correctly by the various users |
| Updating and enhancing user records | Depending on the circumstances: To perform our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations Where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with you about any posts you have made, any offers you submit or any applications you make, as well as of any courses you may purchase or offer for sale on or via the portal |
| Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business | To comply with our legal and regulatory obligations |
| Marketing our services to existing and former users | "For our legitimate interests or those of a third party, i.e. to promote our business to existing and former users See ‘Marketing’ below for further information" |
| External and internal audits and quality checks, e.g. for the audit of our accounts and to ensure our contracts are being respected | For our legitimate interests or a those of a third party, i.e. to operate at the best possible standards and to ensure our users do the same |
| We may need to share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances: To comply with our legal and regulatory obligations In other cases, for our legitimate interests or those of a third party, i.e. to protect, realise or grow the value in our business and assets |
We do not generally process any special category data about you (also known as sensitive data), and if we do so, this will be on the basis of your consent (which you may withdraw at any time).
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where it needs to be shared with others.
We may use your personal data to send you updates (by email, text message, telephone or post) about our services and our portal, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.
For more information on your rights to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
We routinely share personal data with:
If you are a student or a job seeker, we also will share your personal data with education providers and employers where you have purchased a course online via our portal, or where you show interest in, or apply to a job, employer, course or education provider by interacting with a listing they place on our portal. This allows you to be provided with the service from the relevant education provider or employer as you have requested and also allows us to fulfil the purpose of our portal in general. If you are an education provider or an employer, we may also provide the student or job seeker with information about you – to the extent this is required for us to provide our services and for you to interact with the student or job seeker (such as if your name is provided as a contact person in your listing, or you would like us to share your details with the student or job seek to enable to you take the matter to the next stage). We may also provide your details with third party partners (such as job boards or other online recruitment portals) when you apply to listings which have been supplied by them. When your personal data is supplied to these third party partners, they will become data controller of your personal data so you should always check their privacy policy. The identity of any such third party partners will be identified in the relevant listing.
We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share personal data with:
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not keep your personal data for longer than we need it for the purpose for which it is used and to comply with our accounting, fiscal, legal and contractual obligations. Where possible, we will delete or anonymise your personal data when we no longer need to keep it. For more details, please contact us (see ‘How to contact us’ below).
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to share your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
For example we will transfer your personal data to:
As we are based in the UK, we will also transfer your personal data from the EEA to the UK, if you are based in the EEA.
We will also ensure all protections required by applicable UK and EEA laws are in place before transferring personal data to any organisation or body (or its subordinate bodies) governed by public international law or set up by, or on the basis of, an agreement between two or more countries (international organisations).
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA or to an international organisation where:
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where such is not available), we use legally-approved standard data protection clauses. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.
Where we transfer your personal data outside the EEA we do so on the basis of the UK interim bridge or an adequacy decision or (where such is not available) we use legally-approved standard data protection clauses. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
For further information about such transfers and the safeguards we employ, including to obtain a copy of the legally-approved standard data protection clauses or to find out more about any adequacy regulations or decisions we rely on, please contact us (see ‘How to contact us’ below).
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our portal. We use cookies and other similar technologies on our portal. These help us recognise you and your device and store some information about your preferences or past actions and will help us to monitor your interactions on the portal.
For further information on cookies and similar technologies, our use of cookies and/or relevant similar technologies, when we will request your consent before placing them and how to disable them, please see our https://www.studylearngrow.com/legal-documents/cookie-policy/.
When you are usually resident in the UK or the EEA, you generally have the following rights, which you can usually exercise free of charge:
| Access to a copy of your personal data | The right to be provided with a copy of your personal data |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object to use | The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests. |
| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our portal. |
For further information on each of those rights, including the circumstances in which they apply and circumstances in which they do not apply, please contact us (see ‘How to contact us’ below).
If you would like to exercise any of those rights, please complete a request form—available on our portal at https://studylearngrow.com or email, call or write to us—see below: ‘How to contact us’. When contacting us please:
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here - https://edpb.europa.eu/about-edpb/board/members_en.
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our portal for a reasonable period or by other means, such as email.
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Under UK GDPR , we have appointed an UK Representative to act as our data protection officer. Our nominated UK Representative is :
Melike Kaynak
dataprotection@webosaurus.co.uk
Tel + 44 203 960 7602
Webosaurus Limited
12th Floor, The Broadgate Tower,
20 Primrose Street, London
EC2A 2EW
United Kingdom
Under Article 27 of the GDPR , we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is : Instant EU GDPR Representative Ltd
Adam Brogden
contact@gdprlocal.com
Tel + 353 15 549 700
Instant Eu Gdpr Representative Ltd
Office 2,
12A Lower Main Street, Lucan Co. Dublin
K78 X5P8
Ireland