Privacy Policy
Last Updated: May 24, 2018
(“Skyward” refers to Skyward Access Training Limited)
1. Introduction
Skyward Access Training Limited values the trust our users and customers place in us when they give us access to their personal data. The Privacy Policy describes how we work to maintain that trust and protect that information.
This Privacy Policy details our collection, use and disclosure of personal and non-personal data you give to Skyward when you access or use Skywards online and/or mobile services and websites, and software provided by Skyward on or in connection with such services or websites (collectively, the “Site”).
1.1 Personal Data and Non-Personal Data
Personal data (“Personal Data”) refers to any information that identifies you as a specific individual, and non-personal data (“Non-Personal Data”) refers to any information that does not identify you as a specific individual. Please note that at all times Skyward will adhere to the applicable statutory definition in determining what is and is not Personal Data for the purposes of this Privacy Policy. Where this Privacy Policy refers to “information” or “your information” this may include both Personal and Non-Personal Data.
1.2 The Scope of Skywards Privacy Policy
This Privacy Policy covers only data that we collect through the Site, and not any other data collection or processing, including, without limitation, the data collection practices of any affiliate or other third party, including any third-party operators of web pages to which the Site links, and any information that we collect offline or through any websites, products, or services that do not display a direct link to this Privacy Policy.
Occasionally, we may refer to this Privacy Policy in notices on the Site, including special purpose web pages, mobile applications, or other resources, for example, if we invite you to submit ideas to improve the Site. This Privacy Policy applies to information collected by us through such special purpose resources, as modified in the particular notice (e.g., with respect to the types of data collected or our uses or disclosures of such information). Skyward may amend this Privacy Policy at any time.
1.3 Changes to the Privacy Policy
Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was last amended. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. By using the Site or providing information to us following such changes, you will have accepted the amended Privacy Policy. If Skyward is going to use Personal Data collected through the Site in a manner materially different from that stated at the time of collection, then Skyward will notify users via email and/or by posting a notice on Skyward Site for 30 days prior to such use or by other means as required by law.
2. Information Collected
You provide different types of information in order for Skyward to provide our services, products and features to you.
2.1 Information You Provide to Skyward
– When Providing Employer Information
If you are an Employer, Skyward may request that you provide certain Personal Data to Skyward in order to verify your account. This information may include but may not be limited to a Business Registration information, or a utility bill, the name and email address of an Employer representative.
This information will be used for internal purposes only, subject to any request by law enforcement or a court order. In connection with chargeable services, we will also collect payment information (e.g., the last four digits of credit card numbers and related verification information). Please note that Skyward only has access to the last four digits of Employer credit card numbers and does not store full credit card numbers.
– When You Log in or Use Skyward from Some Third-Party Sites
You may also create an account or log in to your Skyward account using third-party websites including, but not limited to, Facebook or Google. If you do not already have a Skyward account but log in to Skyward using your Facebook or Google account, this creates a Skyward account using the same email address used in your Facebook or Google account. If you agree to provide this information to Skyward, Facebook or Google will authenticate you and redirect you to Skywards Site. Please note, when you log in to Skyward using your Facebook or Google account, Facebook or Google will cookie you to authenticate you as a Facebook or Google user.
By accessing Skyward through your Facebook or Google account, you understand that Facebook or Google will share certain data detailed above in this paragraph for the purposes of authentication to permit you to access our Site in a secure manner. You may stop this at any point from your Facebook or Google account. This information will be considered Skyward account information for purposes of your use of the Site.
You can disable the connection between your Facebook or Google account and your Skyward account at any time by accessing your privacy settings on your Facebook or Google account. Facebook may also ask for your permission to share certain other details with Skyward, including but not limited to your name, profile picture, public profile information, and email address.
PLEASE NOTE THAT YOUR RELATIONSHIP WITH FACEBOOK OR GOOGLE OR ANY OTHER THIRD-PARTY WEBSITE IS GOVERNED SOLELY BY YOUR AGREEMENT WITH SUCH THIRD-PARTY WEBSITE.
2.2 Any Other Personal Data Skyward May Receive from Third Parties
Any Personal Data that Skyward may obtain from other third-party sources will be processed by Skyward in accordance with this Privacy Policy and all applicable laws.
2.3 Storage of Your Information
Skyward shall retain users’ Personal Data to the extent such retention is adequate, relevant and limited to what is necessary for the purposes for which they are processed. Skyward shall not retain Personal Data for any longer than necessary for the purposes of performing the processing outlined in this Privacy Policy.
If you create a Skyward account, your information may be collected and stored in a manner that connects to your account email address. Skyward may also create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, email address, or postcode.
2.4 What Personal Data is Required
Skyward will indicate to you at the point of provision as to whether Personal Data provided by you is required in order to provide particular Skyward services or features to you. Where Personal Data that is required is not provided by you then the feature or service may not be available to you.
2.5 The Legal Basis on Which Indeed Collects Your Personal Data
Skyward collects and processes your Personal Data based on different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved. More information is provided on this here.
– Performance of a Contract
Most of the Personal Data processed by Skyward is performed on the basis that it is necessary for the performance of our agreement with you, or to take steps at the request of the user prior to entering such an agreement.
– Legitimate Interest
A second ground relied upon by Skyward for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by Skyward. Such legitimate interests will include where Skyward sends you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention. Skyward will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you.
– Compliance with a Legal Obligation
A third ground relied upon for certain types of processing is that it is necessary in order to allow Skyward comply with a legal obligation. An example of this would be where Skyward is required to retain records for fixed periods of time in order to comply with local legal requirements.
– Consent
Finally, in certain limited situations, Skyward relies on your consent in order to process your Personal Data. Where Skyward requires your consent in order to collect and process certain Personal Data, we seek your consent at the time of provision, and such processing will only be performed where consent is secured.
3. Limitation of Use or Disclosure of Personal Data
Skyward reserves the right to keep any materials in a closed account as necessary to preserve and protect its rights to the extent permitted by law (for example, to preserve records of a dispute) or to comply with its obligations under local law (for example, if requested to retain by law enforcement). A closed account does not mean that all of the data is expunged from the Skyward systems, although it will not be readily available under the customers original account name. When the customer presses the close account button on the dashboard, Skyward will begin to process that instruction within 24 hours and will have completed the operation within 40 days.
3.1 Where an Employer Wants to Close an Employer Account
Employers may close an account at any time by contacting Skyward. Please note that Skyward must preserve business records pertaining to that account to comply with its obligations under law. Alternatively, if an Employer agent wishes to access or delete their Personal Data held by Skyward, they should follow the steps listed in section 10 of this Privacy Policy, and such a request will be processed in accordance with applicable rules.
3.2 Where the Employer Contact Details Provided to Skyward Are Incorrect
In the event, that the electronic destination provided to Skyward is incorrect, your application materials will not be sent to the intended recipient of the application. Skyward has no liability for such applications. If you do not wish to send your application materials in this manner, you should send them directly to the Employer.
3.3 Minimum Age of our Users
Skyward limits its processing of Personal Data to users that are of a legal working age and adopts a range of measures to try to ensure that we do not accept such users. Legal working age levels vary in different countries. Consequently, Skyward may vary this minimum age, as required, to comply with any applicable local laws.
4. Purposes, Uses and Disclosures of Information
We may use any information collected pursuant to this Privacy Policy, including Personal Data, for the purposes set forth in this sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. Skyward uses such information to help:
1) provide our services, products and features to you;
2) to measure and improve those services, products and features; and
3) to protect our users and provide them with customer support.
More detail on these purposes, uses and disclosures of your information is set out below.
4.1 Creating an Account, Sending You Other Promotional Materials
If and to the extent permitted by applicable law, Skyward may use your contact information to (i) create an account; (ii) send you training alerts? and (iii) send you information about Skyward, including promotional materials. Skyward may use third-party partners to perform these activities on Skywards behalf.
Skyward may also share your information with third parties (including operators of third-party websites and/or social networking sites) to show you targeted advertisements and other content that has been customized for you. Such advertisements will only relate to Skywards services, products, and features, all of which focus on helping candidates progress their careers. If you wish to opt out of receiving any marketing messages from Skyward, please see section 14 of this Privacy Policy.
4.2 Your Contact Information
When you give Skyward contact information (such as your name and email address) and other forms of Personal and Non-Personal Data, you agree that Skyward may utilize this information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. You agree that Skyward may, as part of its services to you, communicate with you, or initiate communication with you on behalf of a third party, through your Skyward account or through other means such as email, telephone (including mobile phone), including using contact information that you may provide to Skyward or that Skyward may otherwise obtain from third-party resources.
4.3 Sending You Text Messages About Training Programs
Skyward may offer you the opportunity to receive a text message from Skyward when an Employer has scheduled a training program or event for you. Phone numbers on the Skyward consent form and by entering your phone number you are representing and confirming it is your number and you have the right to accept text messages at the number. Skyward will only send you a text message reminder for training programs through Skywards email relay, and you agree to accept such text messages on your mobile phone including messages sent by automated telephone dialling system.
4.4 Preventing Fraud and Spam
Skyward may also use information collected pursuant to this Privacy Policy to help diagnose problems with the Site and Skywards service, to prevent potentially fraudulent or illegal activities, and to protect individuals from other activities that may be detrimental to you or others. Skyward may investigate and disclose information from or about you or your use of Skyward if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process (including, search warrants, court orders) and law enforcement instructions and orders? (b) is helpful to prevent, investigate, or identify possible wrong doing in connection with the use of the Site? or (c) may protect our rights, reputation, property, safety, or that of the public? or (d) as necessary to meet European Directive security requirements.
We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as spam or fraud. However, such detection methods are not perfect and false positives may occur. These efforts may on occasion result in a temporary or permanent suspension or termination of some functions for some users.
– Preventing Fraud and Spam in Messages
Skyward also reserves the right to drop messages from our relay system that Skyward determines do not adhere to Site Rules or any of the terms of this agreement. Skyward further reserves the right to conduct investigations to determine whether you are perpetrating a scam, spamming Skyward or its users, or otherwise conducting fraudulent activity on Skyward by various means, including but not limited to investigating your functionality by setting up profiles and names that belong to Skyward. Skyward also reserves the right to turn over any information gathered via such investigations to the police or other third party if Skyward has a good faith belief that you are using the Site in violation of these terms.
Skyward reserves the right to verify and confirm the identity of any party associated with an email relay. This includes but is not limited to verifying the identity of the sender of an email with the Employer agents associated with that email address.
4.5 Facilitating Payment
If you provide credit, debit or other payment card and related details to us in order to make a payment, Skyward will use such information only for the purpose of processing the payment (e.g., the last four digits of credit card numbers and related verification information).
4.6 Automated Processing of Your Personal Data
In order to optimize the performance of the Skyward Site and services for users, Skyward, performs automated processing of Personal Data evaluating certain specific aspects relating to a user, in particular to analyse or predict aspects concerning a user’s personal preferences or interests in terms of Skywards Site and services. Where it occurs, such processing is carried if it is necessary for the performance of our agreement with our users, to allow Skyward to provide its services to Employers, or in other cases based on a user’s consent.
For example, this allows Skyward to match training programs with Employers effectively that they are more likely to be interested in. Such processing is subject to the safeguards detailed in this Privacy Policy.
4.7 Transfer of Information to Skyward Affiliated Entities
Any information shared by you with Skyward may be shared with or transferred to any Skyward affiliated entity (including Hire Access Limited, Skyward Training Limited), no matter where located, for providing you services and improving the Site. Such transfers are performed in full compliance with applicable data protection rules and subject to appropriate safeguards, primarily through the use of extensive data protection agreements, in order to ensure adequate protection of users’ Personal Data. The services provided to you and the functionality of the Site could not be provided without such a transfer. If you do not wish your information to be transferred in this way you should not use this Site.
4.8 Transfer of Information to Third Parties
– Transfers to Employers
Employers agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing and storage of Personal Data, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.
– Transfers to Service Providers and Vendors
We may use third parties to perform services in connection with our operations, to improve the Site and our services, products and features, and to protect our users. These third parties may include (but are not limited to) service providers and vendors.
Skyward may also transfer your Personal Data in limited situations to certain third-party vendors that assist Skyward with protecting our users and maintaining the quality of our services, products and features provided to those users. An example would be vendors Skyward uses for fraud detection purposes. When providing these services, those companies may have access to Personal Data, and this may involve transfers of such Personal Data to other countries. Such transfers are only made for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. Those companies are also contractually required to treat such Personal Data in accordance with this Privacy Policy, and in accordance with all applicable laws with respect to such transfers and any processing performed by those third parties on such Personal Data.
– Transfers to Cloud Service Providers
Please also be aware that we may also use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable? these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (fully permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.
– Transfers of Publicly Available Information
When users post content on Skyward in a manner that is intended to make that content publicly available and searchable by individuals, Skyward reserves the right to aggregate and share that information with third parties.
– Third-Party Sites You Link to from Skyward
You may also use certain third-party sites or services that you link to from Skywards Site. In such cases, all information you provide to a third party is provided to that third party and not to Skyward and is subject to the third-party’s privacy policy and terms of service. Please see section 8 of this Privacy Policy titled Links to Third-Party Sites for more information.
– Transfers of Personal Data for individuals in the EU
Please see sections 11 and 12 of this Privacy Policy for information related to this.
5. Additional Uses and Disclosures of Non-Personal Data
In addition to the other uses and disclosures of information set forth in this Privacy Policy, and not withstanding anything in this Privacy Policy to the contrary, we may use and disclosure, for any purpose, any Non-Personal Data, except where we are required to do otherwise under applicable law. If we combine any Non-Personal Data with Personal Data, then we will only use and disclose such combined information for the purposes described in sections 4 and 9 of this Privacy Policy while it is so combined.
6. Security
Skyward seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under Skywards control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security.
Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable? these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (fully permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies. Please see section 11 of this Privacy Policy for liabilities pertaining to the transfer of Personal Data of individuals in the EU.
7. Cookies
“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Please see our Cookie Policy for further information regarding Skywards use of Cookies.
8. Links to Third-Party Sites
The Site may make available links to other websites. When you click on such links, you may leave our Site. The Site may also make available Company Pages, which may contain information provided by third-parties.
WE ARE NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, THIRD-PARTY SERVICE PROVIDERS, ANY EMPLOYERS (INCLUDING ANY EMPLOYER THAT PROVIDES A COMPANY PAGE), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITE IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITE CONTAINS A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES, SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.
9. Acquisitions and Other Reorganizations
Information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any change of ownership or control in Skywards business (whether by merger, sale, or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding), and any such information may be used by such third party in accordance with this Privacy Policy. Equally, information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any acquisition or merger carried out by Skyward of such third parties.
10. Exercising Your Rights with Respect to Your Personal Data
Skyward users that provide their Personal Data in the EU, and those that provide their Personal Data in any other jurisdictions that adopt laws affording equivalent protections to those in the EU, may avail of the rights detailed below.
10.1 The Right to Rectify Your Personal Data
Skyward users are able to edit and update most of their Personal Data held by Skyward on the Site, and if you have any queries or complaints we encourage you to contact us.
Alternatively, if you do not wish to do this you may make a formal request to have Skyward rectify any inaccurate Personal Data on your behalf by sending an email to training@skywardtrainiung.co.uk from the email address associated with your account.
10.2 The Right to Object to or Restrict the Processing of Your Personal Data
If you have any queries or complaints about how we process your Personal Data, we encourage you to contact us.
Alternatively, if you do not wish to do this you may make a formal request to object to, or restrict, processing of your Personal Data by Skyward. To do so please send an email to training@skywardtrainiung.co.uk from the email address associated with your account.
10.3 The Right to Delete Your Personal Data
Skyward users are able to edit and update most of their Personal Data held by Skyward on the Site, and if you have any queries or complaints we encourage you to contact us.
Alternatively, if you do not wish to do this, you may make a formal request delete your Personal Data held by Skyward. In order to do so, please email to training@skywardtrainiung.co.uk from the email address associated with your account and paste the following sentence in your email: “I am requesting to delete my personal data.” Once your request has been confirmed, Skyward will initiate the necessary steps to execute this exercise, including the deletion of your Skyward account.
PLEASE NOTE: by requesting the deletion of your Personal Data, you will no longer be able to create an account with Skyward using the same email address. If you simply wish to close your account, please click the “close my account” button in your account page.
10.4 Some Limitations
Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of Skyward confirming your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by Skyward and only imposed to the extent permitted by applicable law.
11. Personal Data from Individuals in the EU
11.1 Principle of Onward Transfer
In the context of an onward transfer of data to a third party, a Privacy Shield organization has responsibility for the processing of Personal Data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Skyward shall remain liable under the Principles if its agent processes such Personal Data in a manner inconsistent with the Principles, unless Skyward proves that it is not responsible for the event giving rise to the damage.
12. Opting Out
If you no longer want to receive marketing materials from us based upon your Personal Data, going forward, you may opt out of receiving such marketing related messages by sending an email to training@skywardtrainiung.co.uk (remove spaces when sending email). Please note that we may still send other messages to you, such as administrative messages. We will comply with your request as soon as reasonably practicable, and in accordance with applicable laws.
13. General Inquiries and Complaints
13.1 Contacting Indeed
If you wish to contact Skyward Access Training Limited for any reason associated with this policy, please use the following email address training@skywardtrainiung.co.uk
13.2 Complaints
If you believe your data protection rights have been infringed by Skyward, you have the right to complain to the appropriate data protection supervisory authority in your jurisdiction. UK data complaints should be sent directly to;
The Information Commissioners Office
Water Lane, Wycliffe House
Wilmslow – Cheshire SK9 5AF
01625 545745
International.team@ico.org.uk
(“Skyward” refers to Skyward Access Training Limited)
1. Introduction
Skyward Access Training Limited values the trust our users and customers place in us when they give us access to their personal data. The Privacy Policy describes how we work to maintain that trust and protect that information.
This Privacy Policy details our collection, use and disclosure of personal and non-personal data you give to Skyward when you access or use Skywards online and/or mobile services and websites, and software provided by Skyward on or in connection with such services or websites (collectively, the “Site”).
1.1 Personal Data and Non-Personal Data
Personal data (“Personal Data”) refers to any information that identifies you as a specific individual, and non-personal data (“Non-Personal Data”) refers to any information that does not identify you as a specific individual. Please note that at all times Skyward will adhere to the applicable statutory definition in determining what is and is not Personal Data for the purposes of this Privacy Policy. Where this Privacy Policy refers to “information” or “your information” this may include both Personal and Non-Personal Data.
1.2 The Scope of Skywards Privacy Policy
This Privacy Policy covers only data that we collect through the Site, and not any other data collection or processing, including, without limitation, the data collection practices of any affiliate or other third party, including any third-party operators of web pages to which the Site links, and any information that we collect offline or through any websites, products, or services that do not display a direct link to this Privacy Policy.
Occasionally, we may refer to this Privacy Policy in notices on the Site, including special purpose web pages, mobile applications, or other resources, for example, if we invite you to submit ideas to improve the Site. This Privacy Policy applies to information collected by us through such special purpose resources, as modified in the particular notice (e.g., with respect to the types of data collected or our uses or disclosures of such information). Skyward may amend this Privacy Policy at any time.
1.3 Changes to the Privacy Policy
Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was last amended. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. By using the Site or providing information to us following such changes, you will have accepted the amended Privacy Policy. If Skyward is going to use Personal Data collected through the Site in a manner materially different from that stated at the time of collection, then Skyward will notify users via email and/or by posting a notice on Skyward Site for 30 days prior to such use or by other means as required by law.
2. Information Collected
You provide different types of information in order for Skyward to provide our services, products and features to you.
2.1 Information You Provide to Skyward
– When Providing Employer Information
If you are an Employer, Skyward may request that you provide certain Personal Data to Skyward in order to verify your account. This information may include but may not be limited to a Business Registration information, or a utility bill, the name and email address of an Employer representative.
This information will be used for internal purposes only, subject to any request by law enforcement or a court order. In connection with chargeable services, we will also collect payment information (e.g., the last four digits of credit card numbers and related verification information). Please note that Skyward only has access to the last four digits of Employer credit card numbers and does not store full credit card numbers.
– When You Log in or Use Skyward from Some Third-Party Sites
You may also create an account or log in to your Skyward account using third-party websites including, but not limited to, Facebook or Google. If you do not already have a Skyward account but log in to Skyward using your Facebook or Google account, this creates a Skyward account using the same email address used in your Facebook or Google account. If you agree to provide this information to Skyward, Facebook or Google will authenticate you and redirect you to Skywards Site. Please note, when you log in to Skyward using your Facebook or Google account, Facebook or Google will cookie you to authenticate you as a Facebook or Google user.
By accessing Skyward through your Facebook or Google account, you understand that Facebook or Google will share certain data detailed above in this paragraph for the purposes of authentication to permit you to access our Site in a secure manner. You may stop this at any point from your Facebook or Google account. This information will be considered Skyward account information for purposes of your use of the Site.
You can disable the connection between your Facebook or Google account and your Skyward account at any time by accessing your privacy settings on your Facebook or Google account. Facebook may also ask for your permission to share certain other details with Skyward, including but not limited to your name, profile picture, public profile information, and email address.
PLEASE NOTE THAT YOUR RELATIONSHIP WITH FACEBOOK OR GOOGLE OR ANY OTHER THIRD-PARTY WEBSITE IS GOVERNED SOLELY BY YOUR AGREEMENT WITH SUCH THIRD-PARTY WEBSITE.
2.2 Any Other Personal Data Skyward May Receive from Third Parties
Any Personal Data that Skyward may obtain from other third-party sources will be processed by Skyward in accordance with this Privacy Policy and all applicable laws.
2.3 Storage of Your Information
Skyward shall retain users’ Personal Data to the extent such retention is adequate, relevant and limited to what is necessary for the purposes for which they are processed. Skyward shall not retain Personal Data for any longer than necessary for the purposes of performing the processing outlined in this Privacy Policy.
If you create a Skyward account, your information may be collected and stored in a manner that connects to your account email address. Skyward may also create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, email address, or postcode.
2.4 What Personal Data is Required
Skyward will indicate to you at the point of provision as to whether Personal Data provided by you is required in order to provide particular Skyward services or features to you. Where Personal Data that is required is not provided by you then the feature or service may not be available to you.
2.5 The Legal Basis on Which Indeed Collects Your Personal Data
Skyward collects and processes your Personal Data based on different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved. More information is provided on this here.
– Performance of a Contract
Most of the Personal Data processed by Skyward is performed on the basis that it is necessary for the performance of our agreement with you, or to take steps at the request of the user prior to entering such an agreement.
– Legitimate Interest
A second ground relied upon by Skyward for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by Skyward. Such legitimate interests will include where Skyward sends you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention. Skyward will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you.
– Compliance with a Legal Obligation
A third ground relied upon for certain types of processing is that it is necessary in order to allow Skyward comply with a legal obligation. An example of this would be where Skyward is required to retain records for fixed periods of time in order to comply with local legal requirements.
– Consent
Finally, in certain limited situations, Skyward relies on your consent in order to process your Personal Data. Where Skyward requires your consent in order to collect and process certain Personal Data, we seek your consent at the time of provision, and such processing will only be performed where consent is secured.
3. Limitation of Use or Disclosure of Personal Data
Skyward reserves the right to keep any materials in a closed account as necessary to preserve and protect its rights to the extent permitted by law (for example, to preserve records of a dispute) or to comply with its obligations under local law (for example, if requested to retain by law enforcement). A closed account does not mean that all of the data is expunged from the Skyward systems, although it will not be readily available under the customers original account name. When the customer presses the close account button on the dashboard, Skyward will begin to process that instruction within 24 hours and will have completed the operation within 40 days.
3.1 Where an Employer Wants to Close an Employer Account
Employers may close an account at any time by contacting Skyward. Please note that Skyward must preserve business records pertaining to that account to comply with its obligations under law. Alternatively, if an Employer agent wishes to access or delete their Personal Data held by Skyward, they should follow the steps listed in section 10 of this Privacy Policy, and such a request will be processed in accordance with applicable rules.
3.2 Where the Employer Contact Details Provided to Skyward Are Incorrect
In the event, that the electronic destination provided to Skyward is incorrect, your application materials will not be sent to the intended recipient of the application. Skyward has no liability for such applications. If you do not wish to send your application materials in this manner, you should send them directly to the Employer.
3.3 Minimum Age of our Users
Skyward limits its processing of Personal Data to users that are of a legal working age and adopts a range of measures to try to ensure that we do not accept such users. Legal working age levels vary in different countries. Consequently, Skyward may vary this minimum age, as required, to comply with any applicable local laws.
4. Purposes, Uses and Disclosures of Information
We may use any information collected pursuant to this Privacy Policy, including Personal Data, for the purposes set forth in this sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. Skyward uses such information to help:
1) provide our services, products and features to you;
2) to measure and improve those services, products and features; and
3) to protect our users and provide them with customer support.
More detail on these purposes, uses and disclosures of your information is set out below.
4.1 Creating an Account, Sending You Other Promotional Materials
If and to the extent permitted by applicable law, Skyward may use your contact information to (i) create an account; (ii) send you training alerts? and (iii) send you information about Skyward, including promotional materials. Skyward may use third-party partners to perform these activities on Skywards behalf.
Skyward may also share your information with third parties (including operators of third-party websites and/or social networking sites) to show you targeted advertisements and other content that has been customized for you. Such advertisements will only relate to Skywards services, products, and features, all of which focus on helping candidates progress their careers. If you wish to opt out of receiving any marketing messages from Skyward, please see section 14 of this Privacy Policy.
4.2 Your Contact Information
When you give Skyward contact information (such as your name and email address) and other forms of Personal and Non-Personal Data, you agree that Skyward may utilize this information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. You agree that Skyward may, as part of its services to you, communicate with you, or initiate communication with you on behalf of a third party, through your Skyward account or through other means such as email, telephone (including mobile phone), including using contact information that you may provide to Skyward or that Skyward may otherwise obtain from third-party resources.
4.3 Sending You Text Messages About Training Programs
Skyward may offer you the opportunity to receive a text message from Skyward when an Employer has scheduled a training program or event for you. Phone numbers on the Skyward consent form and by entering your phone number you are representing and confirming it is your number and you have the right to accept text messages at the number. Skyward will only send you a text message reminder for training programs through Skywards email relay, and you agree to accept such text messages on your mobile phone including messages sent by automated telephone dialling system.
4.4 Preventing Fraud and Spam
Skyward may also use information collected pursuant to this Privacy Policy to help diagnose problems with the Site and Skywards service, to prevent potentially fraudulent or illegal activities, and to protect individuals from other activities that may be detrimental to you or others. Skyward may investigate and disclose information from or about you or your use of Skyward if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process (including, search warrants, court orders) and law enforcement instructions and orders? (b) is helpful to prevent, investigate, or identify possible wrong doing in connection with the use of the Site? or (c) may protect our rights, reputation, property, safety, or that of the public? or (d) as necessary to meet European Directive security requirements.
We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as spam or fraud. However, such detection methods are not perfect and false positives may occur. These efforts may on occasion result in a temporary or permanent suspension or termination of some functions for some users.
– Preventing Fraud and Spam in Messages
Skyward also reserves the right to drop messages from our relay system that Skyward determines do not adhere to Site Rules or any of the terms of this agreement. Skyward further reserves the right to conduct investigations to determine whether you are perpetrating a scam, spamming Skyward or its users, or otherwise conducting fraudulent activity on Skyward by various means, including but not limited to investigating your functionality by setting up profiles and names that belong to Skyward. Skyward also reserves the right to turn over any information gathered via such investigations to the police or other third party if Skyward has a good faith belief that you are using the Site in violation of these terms.
Skyward reserves the right to verify and confirm the identity of any party associated with an email relay. This includes but is not limited to verifying the identity of the sender of an email with the Employer agents associated with that email address.
4.5 Facilitating Payment
If you provide credit, debit or other payment card and related details to us in order to make a payment, Skyward will use such information only for the purpose of processing the payment (e.g., the last four digits of credit card numbers and related verification information).
4.6 Automated Processing of Your Personal Data
In order to optimize the performance of the Skyward Site and services for users, Skyward, performs automated processing of Personal Data evaluating certain specific aspects relating to a user, in particular to analyse or predict aspects concerning a user’s personal preferences or interests in terms of Skywards Site and services. Where it occurs, such processing is carried if it is necessary for the performance of our agreement with our users, to allow Skyward to provide its services to Employers, or in other cases based on a user’s consent.
For example, this allows Skyward to match training programs with Employers effectively that they are more likely to be interested in. Such processing is subject to the safeguards detailed in this Privacy Policy.
4.7 Transfer of Information to Skyward Affiliated Entities
Any information shared by you with Skyward may be shared with or transferred to any Skyward affiliated entity (including Hire Access Limited, Skyward Training Limited), no matter where located, for providing you services and improving the Site. Such transfers are performed in full compliance with applicable data protection rules and subject to appropriate safeguards, primarily through the use of extensive data protection agreements, in order to ensure adequate protection of users’ Personal Data. The services provided to you and the functionality of the Site could not be provided without such a transfer. If you do not wish your information to be transferred in this way you should not use this Site.
4.8 Transfer of Information to Third Parties
– Transfers to Employers
Employers agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing and storage of Personal Data, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.
– Transfers to Service Providers and Vendors
We may use third parties to perform services in connection with our operations, to improve the Site and our services, products and features, and to protect our users. These third parties may include (but are not limited to) service providers and vendors.
Skyward may also transfer your Personal Data in limited situations to certain third-party vendors that assist Skyward with protecting our users and maintaining the quality of our services, products and features provided to those users. An example would be vendors Skyward uses for fraud detection purposes. When providing these services, those companies may have access to Personal Data, and this may involve transfers of such Personal Data to other countries. Such transfers are only made for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. Those companies are also contractually required to treat such Personal Data in accordance with this Privacy Policy, and in accordance with all applicable laws with respect to such transfers and any processing performed by those third parties on such Personal Data.
– Transfers to Cloud Service Providers
Please also be aware that we may also use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable? these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (fully permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.
– Transfers of Publicly Available Information
When users post content on Skyward in a manner that is intended to make that content publicly available and searchable by individuals, Skyward reserves the right to aggregate and share that information with third parties.
– Third-Party Sites You Link to from Skyward
You may also use certain third-party sites or services that you link to from Skywards Site. In such cases, all information you provide to a third party is provided to that third party and not to Skyward and is subject to the third-party’s privacy policy and terms of service. Please see section 8 of this Privacy Policy titled Links to Third-Party Sites for more information.
– Transfers of Personal Data for individuals in the EU
Please see sections 11 and 12 of this Privacy Policy for information related to this.
5. Additional Uses and Disclosures of Non-Personal Data
In addition to the other uses and disclosures of information set forth in this Privacy Policy, and not withstanding anything in this Privacy Policy to the contrary, we may use and disclosure, for any purpose, any Non-Personal Data, except where we are required to do otherwise under applicable law. If we combine any Non-Personal Data with Personal Data, then we will only use and disclose such combined information for the purposes described in sections 4 and 9 of this Privacy Policy while it is so combined.
6. Security
Skyward seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under Skywards control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security.
Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable? these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (fully permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies. Please see section 11 of this Privacy Policy for liabilities pertaining to the transfer of Personal Data of individuals in the EU.
7. Cookies
“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Please see our Cookie Policy for further information regarding Skywards use of Cookies.
8. Links to Third-Party Sites
The Site may make available links to other websites. When you click on such links, you may leave our Site. The Site may also make available Company Pages, which may contain information provided by third-parties.
WE ARE NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, THIRD-PARTY SERVICE PROVIDERS, ANY EMPLOYERS (INCLUDING ANY EMPLOYER THAT PROVIDES A COMPANY PAGE), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITE IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITE CONTAINS A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES, SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.
9. Acquisitions and Other Reorganizations
Information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any change of ownership or control in Skywards business (whether by merger, sale, or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding), and any such information may be used by such third party in accordance with this Privacy Policy. Equally, information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any acquisition or merger carried out by Skyward of such third parties.
10. Exercising Your Rights with Respect to Your Personal Data
Skyward users that provide their Personal Data in the EU, and those that provide their Personal Data in any other jurisdictions that adopt laws affording equivalent protections to those in the EU, may avail of the rights detailed below.
10.1 The Right to Rectify Your Personal Data
Skyward users are able to edit and update most of their Personal Data held by Skyward on the Site, and if you have any queries or complaints we encourage you to contact us.
Alternatively, if you do not wish to do this you may make a formal request to have Skyward rectify any inaccurate Personal Data on your behalf by sending an email to training@skywardtrainiung.co.uk from the email address associated with your account.
10.2 The Right to Object to or Restrict the Processing of Your Personal Data
If you have any queries or complaints about how we process your Personal Data, we encourage you to contact us.
Alternatively, if you do not wish to do this you may make a formal request to object to, or restrict, processing of your Personal Data by Skyward. To do so please send an email to training@skywardtrainiung.co.uk from the email address associated with your account.
10.3 The Right to Delete Your Personal Data
Skyward users are able to edit and update most of their Personal Data held by Skyward on the Site, and if you have any queries or complaints we encourage you to contact us.
Alternatively, if you do not wish to do this, you may make a formal request delete your Personal Data held by Skyward. In order to do so, please email to training@skywardtrainiung.co.uk from the email address associated with your account and paste the following sentence in your email: “I am requesting to delete my personal data.” Once your request has been confirmed, Skyward will initiate the necessary steps to execute this exercise, including the deletion of your Skyward account.
PLEASE NOTE: by requesting the deletion of your Personal Data, you will no longer be able to create an account with Skyward using the same email address. If you simply wish to close your account, please click the “close my account” button in your account page.
10.4 Some Limitations
Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of Skyward confirming your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by Skyward and only imposed to the extent permitted by applicable law.
11. Personal Data from Individuals in the EU
11.1 Principle of Onward Transfer
In the context of an onward transfer of data to a third party, a Privacy Shield organization has responsibility for the processing of Personal Data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Skyward shall remain liable under the Principles if its agent processes such Personal Data in a manner inconsistent with the Principles, unless Skyward proves that it is not responsible for the event giving rise to the damage.
12. Opting Out
If you no longer want to receive marketing materials from us based upon your Personal Data, going forward, you may opt out of receiving such marketing related messages by sending an email to training@skywardtrainiung.co.uk (remove spaces when sending email). Please note that we may still send other messages to you, such as administrative messages. We will comply with your request as soon as reasonably practicable, and in accordance with applicable laws.
13. General Inquiries and Complaints
13.1 Contacting Indeed
If you wish to contact Skyward Access Training Limited for any reason associated with this policy, please use the following email address training@skywardtrainiung.co.uk
13.2 Complaints
If you believe your data protection rights have been infringed by Skyward, you have the right to complain to the appropriate data protection supervisory authority in your jurisdiction. UK data complaints should be sent directly to;
The Information Commissioners Office
Water Lane, Wycliffe House
Wilmslow – Cheshire SK9 5AF
01625 545745
International.team@ico.org.uk