GDPR

New rules, General Data Protection Regulation, "GDPR", apply from 25th May 2018.

REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 27 APRIL 2016 ON THE PROTECTION OF NATURAL PERSONS WITH REGARD TO THE PROCESSING OF PERSONAL DATA AND ON THE FREE MOVEMENT OF SUCH DATA, AND REPEALING DIRECTIVE 95/46/EC. THE GENERAL DATA PROTECTION REGULATION (GDPR)

These rules replace the Data Protection Act

Is Coracle compliant with the rules?

Yes!

Where Coracle provide services to or via partners, we have been appointed in the role of Data Processor. This means that our partner (the Data Controller) appoints Coracle to process Data in accordance with instructions, as given from time to time, for the purpose of providing the agreed services.

Coracle's services are aimed at adult learners, however, as our mission is to ensure that no-one is isolated from a learning opportunity, we are aware that children and vulnerable people may register for an account on a Coracle website. GDPR ensures that such users must be be kept informed about their data in a manner that they can understand: Coracle apply this level of transparency to everyone. Coracle have, since [DATE] offered a granular approach to user control over which emails you receive.

TERMS AND CONDITIONS FOR CORACLE PROVIDED SERVICES (WEBSITES AND APPS):

Access and use of websites and apps provided by Coracle Online Ltd (“Coracle”) are subject to the following terms:

By using Coracle you agree to be legally bound by these terms. If you do not agree to be legally bound by the following terms please do not access or use Coracle.

We may change these terms at any time. If we do so, we will post the changes online and add a notification.

Things you’re not allowed to do:

• You may not copy, reproduce, republish, download, post, broadcast, transmit, make available to the public, or otherwise use Coracle content in any way except for your own personal use.
• You may not make your Coracle password available for others to use.
• You agree not to adapt, alter or create a derivative work from any Coracle content.
• You agree to use Coracle only for lawful purposes, and in a way that does not infringe the rights of, restrict or inhibit anyone else’s use and enjoyment of Coracle. (Prohibited behaviour includes harassing or causing distress or inconvenience to any person, transmitting obscene or offensive content or disrupting the normal flow of dialogue within Coracle)

Content on Coracle, including the information, names, images, pictures, logos and icons regarding or relating to Coracle, its products and services (or to third party products and services), is provided ”AS IS” and on an ”IS AVAILABLE” basis without any representations or any kind of warranty made (whether express or implied by law) to the extent permitted by law, including the implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security and accuracy.

Under no circumstances will Coracle be liable for any of the following losses or damage (whether such losses where foreseen, foreseeable, known or otherwise): (a) loss of data; (b) loss of revenue or anticipated profits; (c) loss of business; (d) loss of opportunity; (e) loss of goodwill or injury to reputation; (f) losses suffered by third parties; or (g) any indirect, consequential, special or exemplary damages arising from the use of Coracle regardless of the form of action. We do not warrant that functions on Coracle will be uninterrupted or error free, that defects will be corrected, or that Coracle or the server that makes it available are free of viruses or bugs.

The names, images and logos identifying Coracle or third parties and their products and services are subject to copyright, design rights and trade marks of Coracle and/or third parties. Nothing contained in these terms shall be construed as conferring by implication, estoppel or otherwise any licence or right to use any trademark, patent, design right or copyright of Coracle or any other third party.

PRIVACY

From time to time, you will be asked to submit personal information about yourself in order to receive or use services provided by us. We recognise that there may be a difference between ‘data’ and ‘information’. Data relates to clear facts (eg, your date of birth). Before we collect any data, we take time to consider if we can provide the service without having that piece of data. If the data is needed, we won’t collect it. Where we have collected your data, we recognise our responsibility to look after it.

You can visit Coracle without telling us who you are or revealing any information about yourself. When we ask you for information, it will only be in response to you actively applying for or using one of our products or services. By entering your details in the fields requested, you enable us to provide you with the services you select.

We may request certain personal information like your name, picture and phone number. Where these are not absolutely necessary to provide the service, they will be optional fields.

We automatically collect information such as your Internet Protocol (IP) address, operating system, browser type and the address of referring sites and your activity on Coracle. This information is not treated as personal information, unless we combine it with or link it to any personal identifiable information.

Your information will be disclosed to third parties only where we are obliged or permitted by law.

If you post or send offensive, inappropriate or objectionable content anywhere on Coracle, or otherwise engage in any disruptive behaviour on Coracle, we can use whatever information that is available about you to stop such behaviour. This may involve informing relevant third parties such as your employer and law enforcement agencies about the content and your behaviour.

Deleting your information

You have the right to correct and delete your data. To exercise this right please make a request to Coracle, identifying yourself with your name and email address. You can use the contact form or call the office on +44 1638 354600.

We may automatically collect certain information through the use of ”cookies”.

What are ”cookies”?

Cookies are small files that get stored on your computer, tablet or phone when you visit a website.

There are two types of cookie

• Session cookies. These are deleted when you close your browser.
• Persistent cookies. These remain on your device until they expire or you delete them from your cache.

We may use both session and persistent cookies to better understand how you interact with our services, to monitor aggregate usage by all users and to improve our services.

Most browsers automatically accept cookies. You can stop accepting cookies, or instruct the browser to prompt you before accepting a cookie from a website by editing the options in your browser. To find out more about cookies, including how to see what cookies have been set and how to manage or delete them, visit www.allaboutcookies.org

If you delete cookies relating to Coracle, we will not remember things about you (including your cookie preferences) and you will be treated as a first time visitor the next time you visit the site.

To confirm, we use the information collected for the purposes of:

• providing our services or information you request and to process and complete any transactions
• to respond to your emails, submissions, questions, comments, requests and complaints and provide customer service
• to monitor and analyse usage and trends and to personalise and improve your experiences when you use our sites, such as providing content or features that match your profile and interests, and to increase the functionality and user friendliness of the service
• to send you confirmations, updates, support and administrative messages and otherwise facilitate your use of, and our administration and operation of, our services.

What information will we share with third parties?

We will not share the personal information, except:

• with service providers who are working with us in connection with the operation of our site or services (these service providers have access to your personal information only to perform services on our behalf and are obligated not to disclose it or use it for any other purpose)
• when we believe, in good faith, that we are lawfully authorised or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders
• in connection with or during negotiations of any merger, sale of company assets, financing or acquisition, or in any other situation where personal information may be disclosed or transferred as one of our business assets.

We are not responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties.