Dulann Privacy Notice
Dulann respects your right to privacy and take seriously our responsibilities in relation to the processing of personal data. We do not collect or process personal data unnecessarily. We do not knowingly attempt to solicit or receive information from children.
This privacy notice will come into effect on the 25th May 2018. And applies to any Website, Learning Management System, Contractor Management System, application or service operated by Dulann, which references this privacy notice.
Please read this privacy notice carefully as it describes our collection, use, disclosure, retention and protection of your personal information.
1. Who we are
Dulann is a limited company incorporated in Ireland with company registration number 528615. Our registered office address is Strandfield Business Park, Kerlogue, Wexford, Co.Wexford, Ireland. This document also applies to products and services provided to you through our network of affiliates, training partners and franchisees.
Dulann’s services comply with the EU and Irelands Data Protection Act 1998 and 2003 Amendment Act and the General Data Protection Regulation (EU) 2016/679.
When it comes to your privacy, we follow 3 main principles
- Transparent. We want to be transparent about the personal information we collect, why we collect it and how we process it.
- Control. We give you control over the Personal Information you provide to us. We let you choose how and when it is used, shared, kept or deleted.
This Privacy Notice also describes Dulann’s privacy practices in relation to individuals’ choices regarding use, access, correction and deletion of personal information.
2. Our Role: controller or processor
Depending on your relationship with us, we will be what’s known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) as either the “controller” and/or “processor” of the personal data provided to us or uploaded to the systems we operate.
Where you interact directly with our websites dulann.com, dulannexpress.com, dulannfranchise.com or elearning.dulann.com, we are both the controller and the processor of your data within the meaning of the GDPR.
Where you interact with a third party who has entered into a contract with us to subscribe to Dulann services, we are the processor within the meaning of the GDPR. In this case we collect, hold or process personal information on behalf of someone else.
3. Why we collect information about you and why we process it
There are a number of grounds (Lawful Bases) under which we collect and process your data. These are:
Contractual – where we need the information to perform our contractual obligations to you or an external data controller.
Legal – where we are legally required to collect and process your data in connection with any of our services.
Legitimate interest – We may process your information to achieve our identified legitimate interests, while applying appropriate safeguards that protect your privacy.
Consent – where you have given us consent to store and process your data (e.g. to market to you).
Please note: we may process your personal data based on any of the above grounds without your prior knowledge or consent, where this is required or permitted by law. If we process your personal data without your explicit consent, we will notify you of this and will explain the legal basis which allows us to do so.
4. How do we collect information and what information do we collect
We collect information about you and any other party whose details you provide to us when you:
- register to use our websites, applications or services (including trials); this may include your name (including business name), address, email address, safe pass number and telephone number. We may also ask you to provide additional information about your business and your preferences;
- place an order using our websites, applications or services; this may include your name (including business name), address, contact (including telephone number and email address) and payment details;
- complete online forms (including call back requests), take part in surveys, post on our Dulann message boards, post any blogs, enter any competitions or prize draws, download information such as white papers or other publications or participate in any other interactive areas that appear on our website or within our application or service;
- For market research purposes information on social media channels such as LinkedIn etc;
- Registering for an event;
- When applying for a job within the company;
- information from other sources, including third parties with whom we have a membership of;
- third parties that we have purchased data from;
- contact us offline, for example by telephone, fax, SMS, email or post;
- provide your contact details to us when registering to use or accessing any websites, applications or services we make available or when you update those details; and
From time to time, a data controller may pass your information to us to process it. We will process this data to fulfill a contractual relationship that we have with them, including producing and communicating to them training records, training certificates etc.
We may also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.
To help keep our databases current and to provide you the most relevant content and experiences, we may combine information provided by you with information from third party sources (such as social media sites), in accordance with applicable law.
We do not collect sensitive information (also known as special categories of information) about you, except when you specifically and knowingly provide it and have consented to this. Examples of sensitive data relates to information concerning an individual’s racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, or details of criminal offences, biometric or genetic data.
Providing us with Information about others
If you provide us with personal information about someone else (e.g. when you share personal data with us under a contractual arrangement or when you make a purchase on someone else’s behalf), you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.
5. What if I don’t provide some or all of the information requested
The impact of this will depend on what information you withhold, but the main impacts may be:
- We will not be able to process or fully process your order.
- We will not be able to contact you to let you know of problems regarding your order or the goods/services provided.
- We will not be able to respond fully to requests and queries you may have.
- We cannot personalise the service you receive.
- We may be unable to issue valid certification for the training you have completed.
6. How do we use your information
We will only use your information for the purpose we collected it for. We may use your information to:
- provide you with any information and services that you have requested or any applications or services that you have ordered;
- compare the information you provided for accuracy and to verify it with third parties;
- manage and administer your use of applications, products and services you have asked us to provide;
- manage our relationship with you (for example, customer services and support activities);
- provide, maintain, protect and improve any applications, products, services and information that you have requested from us;
- monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you;
- undertake internal testing of our website, applications, systems and services to test and improve their security, provision and performance. In this case, we may pseudonymise any information and ensure is it only displayed at aggregated levels which will not be linked back to you or any living individual;
- provide you or an authorised third party with any information that we are required to provide to comply with our contractual, regulatory or legal obligations;
- detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
- contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications, products and services);
- to monitor, carry out statistical analysis and benchmarking. For this purpose, data is used on an aggregated basis which will not be linked back to you or any living individual;
- deliver marketing information (including in-product messaging), promotions, competitions, updates and new products, services or information that may be of interest or useful to you;
- deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers), and
- Where we have your consent to do so, we may use email marketing service providers, including MailChimp to send information to you. For more information please refer to their separate Privacy Policies.
From time to time, we may decide to process your data for a purpose that is different from the original purpose the data was collected for, but only if this is compatible with the original purpose. If you wish to get information as to how this processing is compatible with the original purpose, please contact us at firstname.lastname@example.org.
7. Sharing your information
Sharing with other Data Controllers
We may share your personal information with the Dulann family of companies for the purposes identified previously. The types of third parties your information may be shared with include, our clients, our resellers, our franchisees and other sales and advertising partners.
Sharing with Data Processors
We will also share your personal information with companies that help us to run our business by processing personal information on behalf of Dulann for the purposes identified above. Such companies may include providers of payment processing services, fraud monitoring and prevention, customer relations services, email, social media, and other marketing platforms and service providers, and web hosting services.
From time to time, Dulann may partner with other companies to jointly offer products, services, or programs. If you purchase, specifically express interest in, or register for a jointly–offered product, service, or program from or through Dulann, we may share the data you have provided in connection with your purchase or your expression of interest with our partner(s).
Dulann does not control our business partners’ use of the Data about Dulann Customers that we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.
Other Information Sharing
Dulann may also share your personal information:
- When you agree to the sharing;
- When we are required to provide information in response to a subpoena, court order, or other applicable law or legal process (learn more);
- When we have a good faith belief that the disclosure is necessary to prevent or respond to fraud, defend our apps or websites against attacks, or protect the property and safety of Dulann, our customers and users, or the public;
- If we merge with or are acquired by another company or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to our advisers and any prospective purchaser’s advisers and will be one of the assets that is transferred to the new owner.
- We may share or publish aggregate information that doesn’t specifically identify you, such as statistical information about visitors to our websites or statistical information about how customers use the Dulann Experience Cloud.
8. Is my information secure and where does Dulann store my personal information
Dulann primarily stores the data we collect from or hold about you in data centres in Ireland. Depending on the service you use, your personal information may be stored on Microsoft Azure, Amazon Webservices or Blacknight Web Services, Dulann’s own servers and/or the servers of other companies we may have contracted to provide services to us. Depending on the service, Dulann may transfer your data to servers that are located outside the EU.
We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information, but we cannot guarantee the security of your information which is transmitted to our website, applications or services or to other website, applications and services via an internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe – we will not share this password with anyone.
If you believe your account has been compromised, please contact us at Info@Dulann.com.
From time to time, we may use your information to contact you with details about our applications, products and services which we feel may be of interest to you.
We may also share your information with our group companies and carefully selected third parties so that they (or we) may contact you with information about their products or services which we feel may be of interest to you.
We or they may wish to contact you for this purpose by telephone, post, SMS or email.
You have the right at any time to stop us from contacting you for marketing purposes. You may also request at any time that we do not share your information with third parties for marketing purposes. If you wish to exercise these rights, you can do so by sending us an email to info@Dulann.com. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your information for other purposes. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have the right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time.
Emails we send you may include a technology that tells Dulann whether you have received or opened the email or clicked a link in the email. If you do not want us to collect this information, you can request not to be included in our automated processing of your data or to be removed from our database.
We use MailChimp and other email marketing service providers.
We may send service emails to you as part of our service administration. Service emails can include registration and payment confirmations and emails that provide useful information about how to use a service or feature when you sign up or start using it. This includes email notifications when course certificates and validations are about to or indeed have expired.
We will also send you a service email if we make a fundamental change to the website, or to our terms & conditions that we think we need to make you aware of, or to let you know important information about your account.
11. Links to other websites
Dulann’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy statements of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.
12. Your Information and your rights
If you are resident in a member state of the EU or in the EEA, and depending on the circumstances of our data collection or processing, you have all or some of the following rights:
- the right to be told how we use your information and obtain access to your information;
- the right to have your information rectified or erased or place restrictions on processing your information;
- the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
- the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
- where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
- the right to object to any decisions based on the automated processing of your personal data, including profiling; and
- the right to lodge a complaint with the supervisory authority responsible for data protection matters (E.g. in Ireland, the Data Protection Commissioner’s Office).
If you request a copy of your information, in certain circumstances, you may be required to pay an administrative fee.
If we hold any information about you which is incorrect or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.
If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, and services.
13. Changes to this privacy notice
We may change this Privacy Notice from time to time. However, we will not reduce your rights under this Privacy Notice. We will always keep an updated version of this Privacy Notice on our website, so please read it when you visit the website (the ‘last updated’ reference tells you when we last updated this Privacy Notice).
14. Data backup
Your personal data is backed up on a daily basis. Data Backups are also held in data centres that are located in the EU. Backup servers and data centres are protected by physical barriers and guarded 24/7.
15. Other sites and social media
If you follow a link from our website, application or service to another site or service, this Privacy Notice will no longer apply. We are not responsible for the information handling practices of third party sites or services or other data controllers and we encourage you to read the privacy notices appearing on those sites or services.
16. Public forums, refer a contact, and customer testimonials
Dulann may provide bulletin boards, blogs, or chat rooms through the services offered or operated by us. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Dulann is not responsible for the personal information you choose to submit in these forums.
Dulann posts a list of customers and testimonials on the Company’s Web sites that contain information such as customer names and titles. Consent has been sought from all individuals concerned prior to publishing their personal information.
17. Cookies, analytics and traffic data
Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services which will stay on your computer or device after you close your browser or leave your session in the application or service).
The table below explains the cookies we use and why
|These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.||Click here for an overview of privacy at Google|
|Whoson||Whoson||This cookie is issued by the WhosOn live chat application. This cookie holds a random number to uniquely identify a visitor. It’s used to link a visitor to a ‘visitor record’ which stores the IP address and UserAgent.||Click here for an overview of privacy at Whoson|
|Dulann||gr_session||This cookie holds the session ID. It expires after 24 hours.|
If you use our live chat
We use Parker Software’s WhosOn product to supply live chat, which we use to handle customer enquiries in real time. We will collect the name you provide, company name (optional), email address (optional) and the contents of your live chat session. This information will be retained for a maximum of 7 years and will not be shared with any other organisation. You can receive a copy of your chat transcript if you provide your e-mail address at the end of the session.
Who sets the cookies
The cookies stored on your computer or other device when you access this website are set by Dulann.
Cookies may also be set by third parties who participate with us in affiliate marketing programmes. None of these third parties collect any personal data from which they would be able to identify individual customers.
How can I control what cookies are set
By using our services, you consent to having the above cookies stored on your computer or device.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
Please note that if you choose to disable any or all of the cookies set by this website, some website functionality may no longer be available to you.
18. How long does Dulann retain my information for
We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with the Dulann Data Retention, Marking and Destruction Policy or as otherwise permitted by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).
Should you request deletion of your data, where we are legally allowed, we will delete your personal information as soon as possible after we receive your request. Please note that in certain circumstances we may not be able to delete your data, even when you request this. In any case, we will respond to your request within 30 days.
19. Further Information
If you have any queries about how we treat your information, the contents of this Privacy Notice, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please write to us at Strandfield Business Park Kerlogue, Wexford, Co.Wexford, Ireland or send an email to info@Dulann.com