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This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting http://whahc-community.kenes.com (the “Website”) you are accepting and consenting to the practices described in this policy.
Last updated: 09 September 2019
Who we are
Kenes Education (of the Kenes Group) is the appointed eLearning support provider for the World Hospital at Home Community (WHAHC). Kenes Education (“Kenes”) (”We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting https://whahc-community.kenes.com/ (the “Website”) you are accepting and consenting to the practices described in this policy.
For the purpose of the Dutch Data Protection Act (the Act), the data controller is Kenes Education (registered in Amsterdam, The Netherlands), on behalf of WHAHC (registered in Switzerland).
Information we collect from you
We will collect and process the following data about you:
Information you give us
This is information about you that you give us by filling in forms on our Site. It includes information you provide when you register to use our Site, enrol into the site’s activities, search for a topic, update your user profile on our Site, participate in discussion boards or any social media functions on our Site, complete a survey, participate in an online educational event and when you report a problem with our Site.
Identity Data may include first name, last name, username, title, date of birth, personal description and photograph.
Contact Data may include postal address of either you or your institution, email address and telephone numbers.
Profile Data may include your username and password (which is stored in an encrypted form), your interests, preferences, feedback and survey responses
Information we collect about you
With regard to each of your visits to our Site we will automatically collect the following information:
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
Usage Data includes information about how you use our website and services, (including date and time), activities you viewed or searched for, or participated in, page response times, length of visits to certain pages, page interaction information, and any documents (including certification downloads) obtained from this Site.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered personal data in law as these data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, gender, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web Site and stored on your computer's hard drive.
Our Site may use Google Analytics, an optional web analytics tool provided by Google, 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 to find out more about Google Analytics.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, this Site will not recognise you when you return to the Site, and some Site functionality may be lost.
The Help section of your browser will tell you how to prevent your browser from accepting cookies. Although cookies do not normally contain personally identifiable information, if you are a registered user, we may associate your registration information with cookies our Site places on your computer's hard drive. Associating a cookie with your registration data allows us to offer increased personalisation and functionality. For example, you can elect to have our Site "remember" your username and password and bypass the sign-in process on each visit to the Site. Without cookies, this functionality is not possible.
Purpose of collection
We process your data for purposes of administering your learning and gaining relevant accreditations required. We use the information we hold about you to give you the best user experience and educational service that we can.
The lawful basis of the data processing is your registering to the site (contract), and it is necessary in order to deliver the educational service to you.
Uses made of the information
We use information held about you in the following ways:
Information you give to us. We will use this information:
· to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
· to provide you with information about other community materials and services we offer that are similar to those that you have already participated in or have enquired about;
· to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing registered user and WHAHC member, we will only contact you by electronic means (e-mail). If you do not want us to use your data in this way, please notify us at firstname.lastname@example.org
· to ensure that content from our Site is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
· to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
· to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
· to allow you to participate in interactive features of our service, when you choose to do so;
· as part of our efforts to keep our Site safe and secure;
· to measure or understand the effectiveness of information we serve to you
· to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them.
Please note: we will not pass your details on to third parties for marketing purposes.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
By using this website, you agree that we have the right to share your personal information with:
· Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
· Selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
· analytics and search engine providers that assist us in the improvement and optimization of our Site
· Certifying institutions and accreditation bodies
Please note: we will not disclose your personal details on to third parties for marketing purposes. We will ensure that site analytics shared with external businesses remain anonymous.
We will disclose your personal information to third parties only in the event:
· If Kenes or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets.
· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Kenes, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.]
We share your personal data within the WHAH team. This will involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
All information you provide to us is stored on secure servers hosted via OpenEdu (Learning Management System host) in Germany, maintaining ISO-27001 Certification.
The security of your Personal Information is important to us but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For an inactive period of more than one year, your personal data will be removed from the Website.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by contacting us at email@example.com.
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
The Dutch Data Protection Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. We will endeavor to respond in a timely manner to all reasonable written requests to view, modify or delete Personal Data.