Last revised on May 25 2018
1. Scope of this policy
visitors and subscribers of the websites of HeadGain;
natural persons contacting us through the contact or other forms available on the websites;
subscribers to our newsletter(s);
users signing in to use our courses;
users signing in to download eBooks or diplomas;
users signing in to attend and/or watch webinars;
users signing in to use free content in the platform
This policy includes a description of your data protection rights, including a right to object to some of the processing activities we carry out.
2. Contacting us
Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.
3. Collection of Information
The purpose of the website is to provide users with online education in communication and self leadership and create an online community for users who want to publish and/or assess content in forums connected to HeadGain.
As part of our effort to privide you with the online content and create this online community, we receive and store information about you such as:
a) Personal Information
Content published on the forum of HeadGain.com is accessible by all registered users. However, certain HeadGain features and services ay require registration.. Upon signing-up, an account is created for the user (“Account”). Users who sign-up on-site are required to confirm their registration by clicking on an activation link which is sent to them via email. All active user accounts have the capability to use the forum.
Users are required to provide part or all of the following information below, depending on the features or services they wish to access
First and last name
Company name, size, industry, state and country
Job title, focus, and level
Once you complete activation, and you will be able to create your profile (“Profile”).
b) Other Information
We automatically track and collect certain non-personal information such as website navigation data, Internet Protocol (“IP”) addresses, timestamps and URLs. We use
this information to do internal research on our users’ demographics, interest, and behavior to better understand, protect and serve you and our HeadGain platform.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on our Website, we may store such information on our servers.
To protect you against fraud, unauthorized transactions (such as money laundering), claims and other liabilities, we only collect an identification number and order details which enable us to match each user to the payments he makes. We do not collect credit card information.
4. Use of Information
We use your information to provide, analyse, administer, enhance and personalize our services and marketing efforts, to process your registration, your orders and your payments and to communicate with you on these and other topics. For example, we use information to :
1. We use your Information in order to resolve disputes; troubleshoot problems; help promote safe matching; collect fees owed; measure consumer interest in Services; inform you about offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our TOS; and as otherwise described to you at the time of collection. We may compare and review your Business Information for errors, omissions and for accuracy.
2. We use your e-mail to send you system e-mails about the functionality of our Website that you cannot opt out from and you will have to receive if you want to use our website. If you want to stop receiving our system e-mails, you will have to de-activate your Account by contacting email@example.com.
3. We use your e-mail associated with your Account in order to send you newsletters and promotions in conjunction with your use of our Services. If you do not wish to receive newsletters you may unsubscribe by clicking the unsubscription link in the newsletter e-mail. We may also send you newsletters which include third party’s offers. If you do not wish to receive these third party offers, you may unsubscribe by clicking the unsubscription link in the newsletter e-mail.
4. We may use your Business Information in order to provide benchmark analysis and aggregate statistics. This particular Business Information will be anonymized, will not contain personal identification and will not be transferred or sold to third parties in any way or format that identifies you.
5. We use Website navigation data to operate and improve the Website. We may also use Website navigation data alone or in combination with your Business Information to provide aggregated information about elearning industry.
6. We collect the IP Addresses to track when you use our Website. We use IP Addresses to monitor the regions from which you navigate our Website and sign-up to use our Services. Your IP-address is also registered for statistical purposes and to better our advertising and layout of the Website. In specific, we use your IP Addresses for the following reasons:
a. Send the most appropriate advertising based on geographic area or information derived from your IP address. Many IP addresses are commonly associated with Internet service providers, universities, or major corporations in specific regions or localities. Aggregate information derived from IP addresses may also be reported to advertisers.
b. Estimate the total number of Internet users visiting our Website from specific countries or regions of the world.
c. Assist third party advertisers to track effectiveness of the promotions they run on our Website, visits to and business at third party’s websites.
7. For users other than those only signing in to the free courses or livestream webinar of the website, we do not share your full name, e-mail, phone number and job title with third parties for their marketing purposes as a matter of course. However, if we decide to share such information, you shall be notified and shall have the option to opt-out from providing us with your personal information above for this purpose.
Use of Business Information by other third parties
2. We make reasonable efforts to make sure that our users, who use our Services, will use the information available to them solely for HeadGain ralated purposes. However, we cannot control their use of that information outside this scope and we are not responsible for such unauthorized uses.
3. HeadGain reserves its right to share your Information with a third party in case of sale merger, control changes, reorganization or liquidation of the Company. All actions will naturally be completed in compliance with applicable laws of personal data and privacy.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example to prevent payment fraud or confirm your identity).
For questions about our use of your personal information (including legal basis and transfer mechanisms we rely on) please contact our Data Protection Office/Privacy Office by mail at; [email protected]
5. Protection of Information
We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorised access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Indicatively :
1. All our employees, independent contractors and agents have executed non-disclosure agreements, which provide explicit confidentiality protections. Any employee, independent contractor or agent who violates such privacy and/or security policies is subject to possible termination and civil and/or criminal prosecution.
2. We do not make any of your Information available to third parties for their marketing purposes. HeadGain software runs on individual servers and no data given or
collected is shared with other social media platforms.
If however, we share your Information with third parties, we will notify you. Please note that no transmission over the internet can guarantee confidentiality and non-disclosure, and as such, you transmit at your own risk.
3. We use robust security measures to protect data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of data. When the Services are accessed using the internet, Secure Socket Layer (SSL) technology protects your Information, using both server authentication and data encryption. These technologies help ensure that your Information is safe, secure, and only available to you and to whom you have granted access.
4. We do not tolerate Spam. To report HeadGain –related spam, please contact us at firstname.lastname@example.org. You may not use our communication tools to send spam or otherwise send content that would violate our TOS. We may check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content of the Website, but we will not permanently store messages sent through these tools.
5. HeadGain does its utmost to secure communications and data storage in order to protect confidentiality of your Information against loss and interception by third parties. However, it is important to know that there is no zero-risk against loss or interception by others of your Information. You are responsible for maintaining the security and confidentiality of your Account’s username and password.
6. Storage of Information
We save your Information in our database in order to improve our Website’s and user experience and in accordance with our TOS. If you wish that your Business Information be permanently deleted from our database when you stop using our Services, please notify us at email@example.com.
7. Information and Rights
Once you have provided your Personal Data, you have several rights, which you can in principle exercise free of charge, subject to statutory exceptions. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of your rights, you can file a request here [email protected]
Should you have unresolved concerns, you have the right to lodge a complaint with a Supervisory Authority where you live or where you believe a breach may have occurred. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Supervisory Authority.
1. Right to withdraw consent
Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging into your account on our website (if you have one) or by contacting us at firstname.lastname@example.org. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent.
2. Right to access and rectify your data
3. Right to erasure
4. Right to restriction of processing
Under certain circumstances, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data.Should you wish to have your Personal Data restricted, please file a request here email@example.com.
5. Right to object to processing
Under certain circumstances you may object to the processing of your Personal Data, including where your Personal Data is processed for direct marketing purposes. If you no longer want to receive certain communications from us via email contact us at firstname.lastname@example.org.
6. Right to data portability
Where you have provided your data directly to us and where the processing is carried out by automated means and based on your consent or the performance of a contract between you and us, you have the right to receive the Personal Data processed about
you in a structured, commonly used and machine-readable format, and request portability of your Personal Data.
8. Other websites
We do not knowingly collect or solicit Personal Data from anyone under the age of 18.
In the event we learn that we have collected Personal Data from a child under the age of 18 without verification of parental consent, steps will be taken promptly to remove that information. If you believe that we have or may have information from or about a child under 18 years of age, please contact us at email@example.com.
11. Data Retention
12. Applicable Law
For the purposes described in this policy, your personal data will be transferred to the Sweden. When such transfer happens, we ensure that it takes place in accordance with this policy. For any complaints that cannot be resolved with us directly and fall within the scope of EU legislation, we follow the law of European law on GDPR.