PRIVACY NOTICE FOR AVALOQ’S LEARNING MANAGEMENT SYSTEM
(“LMS”) A-LEARNING

Last modified 14 November 2019

This privacy notice including our cookie policy describes how Avaloq Group AG and its affiliates may process your personal data when you use our LMS and the LMS App.

We may modify this privacy notice from time to time and will place any updates on this website.

RESPONSIBLE PARTY FOR THIS SERVICE

We determine the data processing purpose regarding our LMS in accordance with the applicable data protection laws.

In this privacy notice the term ‘we’, ‘us’ or ‘our’ means the Avaloq entity with whom you are interacting, for example the entity managing the LMS you are using.

We use G-Cube Webwide Software Pvt Ltd (“G-Cube”) to process your personal data in accordance with our instructions. G-Cube may only process your personal data insofar as this is necessary for technical support purposes (e.g. to investigate, respond to and resolve technical complaints). G-Cube will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. This data is hosted in the United States. G-Cube is located in India.

SERVICE DESCRIPTION

Our LMS is a web-based software application for the administration, documentation, tracking, reporting, and delivery of educational courses, training programs, or learning and development programs.

Registered LMS users (e.g. learners, trainers, mentors, administrators etc.) may share their work profile information, take learning courses and accumulate learning credits. Your profile and your data on our LMS (i.e. Login ID, User Title, First Name, Last Name, Gender, Time Zone, Email, Location, Job Title, and Reporting Authority) are visible to registered administrators of our learning platform. In the Gamification section (Competition & Leaderboard) of the LMS, your name and earned points are visible to registered competitors and team mates. Additionally, posts on the forum are also visible to our LMS users and administrators.

DEFINITION OF PERSONAL DATA

Personal data is any information related to an identified or identifiable individual (e. g. a name, an address, a telephone number, date of birth or an e-mail address). We will only collect your personal data for the purposes of providing you with the LMS.

PREFACE

Your personal data will be pre-populated into the LMS and the LMS App to create a user profile that will enable you to access to the LMS and LMS App, and allow you to receive notifications on the availability of new courses and similar communications.

The personal data we will pre-populate into the system includes:

  • Your name and contact details (first name and last name, email address);
  • Your account details (username and password); and
  • Your work profile data (job role, reporting manager, office location, business area).

WHAT PERSONAL DATA WE MAY OBTAIN AND WHEN

We may obtain and process your personal data when you use our LMS, including:

  • Your name and contact details (e.g. first name and last name, email address, phone number);
  • Your account details (such as username and password);
  • Your work profile data (e.g. job role, qualifications, experience, information relating to your employment history, reporting manager, office location, skills and experience);
  • Your correspondence details if you contact us;
  • LMS traffic data (such as your internet usage);
  • Information to investigate possible fraud or other violations of this privacy notice and/or attempts to harm others; and
  • Information on your use of the LMS and the LMS App. If you use our LMS from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

Additional personal data may be collected should you wish to provide further information to get better recommendations from our LMS. Moreover, if you opt in to a “Competition and Leaderboard” function, your user profile, picture, rank, points and badges obtained will be displayed to other Avaloq users.

All personal data under the LMS can be changed at any time and any voluntary information can be removed.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We rely on legitimate interests as the lawful basis on which we collect and use your personal data. Our legitimate interests are the training of our staff for business purposes, compliance requirements and employee retention.

PURPOSES OF PROCESSING

How we use your personal data will depend on how you use the LMS, and the choices you make in your LMS settings.

We use information held about you for the following purposes:

  • To authorize your access to our LMS;
  • To track your learning progress and history and to keep you updated about new learning opportunities;
  • To provide and personalize our LMS so that it can be more relevant and useful to you;
  • To send you messages about the availability of our LMS, security, or other service-related issues. We also send messages about how to use our LMS, learning updates, and reminders;
  • For invitations and communications promoting learning opportunities, engagement and skill development; and
  • To help us improve our LMS.

ERASURE AND STORAGE OF DATA

The use of the LMS can be discontinued by us or you at any time.

We retain your personal data while your LMS account is active or as needed to provide you with learning services. If you have not accessed your account or availed of learning services for over one (1) year, we will contact you to re-activate your account. If your account is not re-activated within thirty (30) days, we will proceed to close your account.

Personal data that must be retained by us for legal reasons will be blocked in accordance with the applicable data protection regulations.

COMMUNICATION PREFERENCES

You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving certain mandatory service-related messages from us (e.g. legal and security notices).

ACCOUNT CLOSURE

If you choose to close your LMS account, your personal data will generally stop being visible to others on our LMS within seventy-two (72) hours. We generally delete closed account information within thirty (30) days of account closure, except as noted in this privacy notice. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source.

We retain your personal data even after you have closed your LMS account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

COOKIES AND GENERAL INFORMATION ABOUT COOKIES

The LMS uses so-called "cookies" to offer you an extensive range of functions and to make the use of the websites more comfortable. Cookies are small text files that are stored on your computer with the help of your Internet browser. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.

Further information on cookies can be found at: http://www.allaboutcookies.org/. Find out more about online advertising and data protection at: www.youronlinechoices.eu.

By using our LMS, you agree that we may use cookies as described here.

INFORMATION SECURITY

We use a variety of technical and organizational security measures, including encryption, to maintain the safety of your personal data.

Your personal data is transmitted over a secure connection with 128-bit encryption and contained behind secured networks and is only accessible by a limited number of people who have special access rights to these systems.

We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

INTERNATIONAL DATA TRANSFERS

The personal data we process in the context of this LMS will be hosted from the United States. We will use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers out of the EU/EEA/Switzerland.

The laws the of the recipient countries may not provide the same level of data protection compared to the country in which you initially provided your data. Nevertheless, when we transfer your personal data to recipients in other countries, we will protect that personal data as described in this privacy notice and in compliance with applicable laws.

Your personal data shall not be sold, rented or traded.

YOUR RIGHTS

To the extent required by applicable laws and subject to legal limitations, you have the right to:

  1. Have access to your personal data;
  2. Have inaccurate data corrected or removed;
  3. The erasure of your personal data;
  4. Restrict the processing of your personal data;
  5. Lodge a complaint with a competent data protection authority; or
  6. Object to the processing of your personal data on compelling legitimate grounds relating to your situation.

If you would like to exercise some of those rights, please:

  • Use the self-service portal; or afterwards
  • Contact us using our contact details below and:
    • ‒ let us have enough information to identify you,
    • ‒ let us have proof of your identity and address, and
    • ‒ let us know the information to which your request relates.

FEEDBACK

If you wish to provide feedback or if you have questions or concerns, or wish to exercise your rights related to your personal data, please contact our Data Protection Officer at: dataprotection@avaloq.com.