Privacy Policy 

At IO-Sphere we appreciate that your privacy is extremely important to you, and we take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

IMPORTANT INFORMATION AND WHO WE ARE 

Purpose of this privacy policy 

This privacy policy aims to give you information on how IO-Sphere collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our communications or apply for any of our courses. 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. 

Controller 

IO-Sphere Limited is the controller and responsible for your personal data (collectively referred to as “IO-Sphere”, “we”, “us” or “our” in this privacy policy). 

Contact details 

All queries regarding this privacy policy are welcomed and should be addressed to the Compliance Director, IO-Sphere Ltd at 102 Middlesex Street, London, E1 7EZ or you can e-mail: info@io-sphere.io  

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review. This version was last updated on 21 October 2022. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

Third-party links 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

THE DATA WE COLLECT ABOUT YOU 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

  1. Identity Data includes first name, surname, marital status, title, date of birth, gender, racial and ethnic origin. 
  2. Contact Data includes billing address, delivery address, email address and telephone numbers. 
  3. Financial Data includes bank account, payment card details and credit score. 
  4. Transaction Data includes details about payments to and from you and other details of courses which you signed up to. 
  5. 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.
  6. Profile Data includes your proof of education, qualifications and any related certificates, your CV, your feedback and survey responses, any usernames or login details which you are provided with or use during the Course. 
  7. Usage Data includes information about how you use our website. 

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy. 

HOW IS YOUR PERSONAL DATA COLLECTED? 

We use different methods to collect data from and about you including through: 

Direct interactions. You may give us your Identity, Contact, Profile and Financial Data by filling in application forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 

  1. apply for and participate on our courses; 
  2. request marketing to be sent to you; or 
  3. give us feedback or contact us. 

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see section below on Cookies for further details. 

Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below: 

  1. Identity and Contact data from any of IO-Sphere’s network of employers. 
  2. Technical Data from analytics providers such as Google based outside the UK; 
  3. Contact, Financial and Transaction Data from providers of technical, payment and delivery services. 
  4. Profile Data from higher education providers or previous employers.

HOW WE USE YOUR PERSONAL DATA 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

  1. Where we need to perform the contract we are about to enter into or have entered into with you. 
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 
  3. Where we need to comply with a legal obligation. 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. 

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground which we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest 
To register you as a student (a) Identity (b) Contact (c) Financial (d) Transactional (e) Profile Performance of a contract with you 
To enrol you onto a course: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile (f) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) 
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you for reviews, feedback or take a survey (c) Liaising with you in relation to the course and any jobs with our network of employers (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how the suitability of our courses) 
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) (b) Necessary to comply with a legal obligation 
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study the suitability of our courses, to develop them, to grow our business and to inform our marketing strategy) 
To use data analytics to improve our website, courses, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of students for our courses, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) 
To make suggestions and recommendations to you about courses or jobs that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Necessary for our legitimate interests (to develop our courses and grow our business) 
To collect and report on our diversity statistics Identity We will only process for this purpose with your explicit consent. 

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which courses and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or enrolled onto or signed up to receive information about a course and you have not opted out of receiving that marketing. 

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting out 

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you enrolling in a course. 

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

DISCLOSURES OF YOUR PERSONAL DATA 

We may share your personal data with the parties set out below for the purposes set out in the table above. 

  1. Specific third parties including the network employers who IO-Sphere work with as may be notified to you from time to time for the purposes of providing you with networking or job opportunities above. 
  2. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

INTERNATIONAL TRANSFERS 

We do not transfer your personal data outside the UK. 

DATA SECURITY 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

DATA RETENTION 

How long will you use my personal data for? 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to: 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

  1. If you want us to establish the data’s accuracy. 
  2. Where our use of the data is unlawful but you do not want us to erase it. 
  3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 
  4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the training, courses, or other services. We will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

COOKIES 

Throughout our website we may link to other websites owned and operated by certain trusted third parties to such as IO-Sphere’s network of employers. These other third-party websites may also use cookies or similar technologies in accordance with their own separate policies. For privacy information relating to these other third-party websites, please consult their policies as appropriate. 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.  

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions. 

For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. 

For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below. 

For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org. 

How to control and delete cookies 

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of our website. 

For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org. 

Please be aware that restricting cookies may impact the functionality of the website. 

Cookie categories 

The type of cookie used on this website can each be put into 1 of 4 categories, based on the classification presented in The International Chambers of Commerce (ICC) Cookie Guide.  

Strictly Necessary Cookies: These cookies are essential, as they enable you to move around a website and use its features, such as accessing secure areas. Without these cookies, certain services you’ve asked for (such as access to secure areas) cannot be provided. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet. These cannot be restricted or blocked.  

Performance Cookies: These cookies collect information about how you use a website, for example which pages you go to most often and if you get any error messages from certain pages. These cookies don’t gather information that identifies you. All information these cookies collect is anonymous and is only used to improve how a website works. These cookies are not used to target you with online advertising. Without these cookies we cannot learn how our website is performing and make the necessary improvements that could enhance your browsing experience. These can be restricted or blocked.  

Functionality Profile Cookies: These cookies allow a website to remember choices you make (such as your username, language or the region you are in) and tailor the website to provide enhanced features and content for you. For instance, they remember your log-in details and allow you to watch videos. They also ensure the onsite marketing and experience is relevant to you. These cookies can also be used to remember changes you’ve made to text size, font and other parts of pages that you can customise. The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites. Without these cookies, a website cannot remember choices you’ve previously made or personalise your browsing experience. These can be restricted or blocked. 

Targeting Cookies: These cookies gather information about your browsing habits. They remember that you’ve visited a website and share this information with other organisations such as advertisers. They do this in order to provide you with adverts that are more relevant to you and your interests. Although these cookies can track your visits to other websites, they don’t usually know who you are. Without these cookies, online advertisements you encounter will be less relevant to you and your interests. These can be restricted or blocked.

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