This policy was reviewed on 30 April 2018, and will come into force on 25 May 2018.
Advanced Skills Initiative Ltd (“ASI”, “we”, “us” or “our”) respect the privacy of its users (“User”, “you” or “your”) and is committed to protect the information that you share with us, whether it’s directly, through using our Services such as our Data Science Platform SherlockML (“SherlockML”), or through a third party (“Third Party” or “Third Parties”). We want to be transparent about our practices regarding the data we may collect when you use our Sites and our Services.
Our Services are primarily used by Companies and Organisations. Where we are providing Services to you under a Company or Organisation contract (for example where a company holds a licence enabling you to use SherlockML), any data held about you personally is controlled by your Company or Organisation. If this applies to you, you can find further information below in the section entitled “Notice to End Users”.
ASI collects information from individuals who visit our Sites and individuals who register to use the Services, either directly on our Sites or on third party Sites.
We may collect two types of data from our Users:
ASI will not request any “Sensitive Personal Data” (that is, information concerning an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health condition, criminal offences or related proceedings, or any other data considered as sensitive under applicable law) unless it is in connection with your employment by ASI or an application for employment or is related to our bespoke services which are covered by separate Privacy Policies.
As a User you may choose to ask us to process Sensitive Personal Data where you do so we will only use that data as you have requested as explained below (see Data Added or Collected by you).
When you register to use our Services, or amend your previous registration details, we collect your username, first name, last name, company name, email address and in some circumstances where it is necessary to contact you about the Services, a postal address and phone number (“Registration Information”).
When purchasing Services which require payment, we collect billing information such as billing name, address, credit/debit card information. Sometimes we require some additional information to calculate and verify your bill, such as the number of people in your Company that require licences, your VAT registration number, and your Company registration number (“Billing Information”).
When you request help from us to use our Sites or Services through the Contact Form or Chatbot, you may choose to submit information about your usage of our Services. We will require an email address and name to provide you with assistance, and may ask you to provide further information in order to be able to solve your query (“Support Information”).
Whilst using our Sites and Services, you may provide us with additional information that is not required (“Optional Information”). Such Optional Information might include your job title, survey answers, feedback, or additional information in your support requests. We may ask you for feedback on our Support Service, but such information is optional and you do not have to give it to us. If we ask for this information from you and it is not required for use of our Services, such information will be clearly marked as optional. All such Optional Information shall be treated as Personal Data for the purposes of this policy.
As a User of our Services, in particular SherlockML, you may choose to add / invite other Users to our Services. Where you do so, we will only use that data as you have requested, to invite the User to our Services. Such data will be retained in our system until you remove it and will not be used other than for the purposes specified by you. You may also upload or ask us to collect (via APIs - application program interfaces - or other means) various types of information or data for processing and hosting (“Customer Material”). We will only process such Customer Material for the purposes set out in the Terms of Services.
In some situations we may use a third party (that is, a separate organisation) to register your information so that you can use our Services, for example invitees to our events are asked to register via Eventbrite. You can find out more information about these “Third Parties” and their activities in the section entitled “Third Party Processing”.
If you provide us with any information not covered in the above, we will still use such information in accordance with this policy, or as permitted by you.
We use your Registration Information, Billing Information and Optional Information in order to:
We require your Registration Information and Billing Information in order to provide you with secure Login credentials (username and password) and to receive payments for Services provided.
We will require Registration Information and Optional Information in order to provide technical assistance, answer your queries, send you updates on account (for example if your payment is overdue), and to provide other support where it is requested from you.
We may use Support Information, Optional Information, and Navigational Information to improve delivery of our Services to you. For example to identify common issues and fix them, or to identify bugs. Where we collect such data, such as bugs, your Personal Information will be removed, so we only have statistical information. Where we ask for Optional Information such as User feedback or surveys, such data helps us improve our Services in the future, and is anonymised when stored.
In some cases we use third party contractors to assist us in providing our Services, for example, we use Stripe to process your payments, and Zendesk to process your Support requests. A list of the third parties we work with is provided in the Third Party Processing section below.
We may use your Registration Information, Billing Information and Navigational Information to ensure that your use falls within our Acceptable Use Policy and Terms and Conditions, or to identify any cases of fraudulent or criminal activity.
Where you have given us your specific consent, we will send you information about our Services in general, such as our newsletter. You may withdraw your consent at anytime by clicking the link in any of the correspondence, or by clicking here.
The legal bases for collecting and using your data vary depending on the way in which you are interacting with our Services. We collect and use your data only where:
We do not sell, share or transfer your data to Third Parties, except in the following specific situations:
You may request for us to share your Customer Material with a Third Party for the purposes of collaborating on our Services. An example of this is when you invite a User to collaborate on a SherlockML project, they will be sent an invitation by us which includes your user name and the name of your organisation (if appropriate), and if accepted, they will get access to any of your Customer Material that you choose to share with them.
You may request us to share information with Third Parties where you are interacting with our Services as an organisation and wish us to share Customer Material with other people in your organisation. An example might be where you ask us to share training information via our Sites to your employees, or where you ask us to issue licences for SherlockML to your employees.
You may request that we link other Third Party Services to your Services with us. An example of this is when you create an API (Application Program Interface) on SherlockML. You may be required to include your Registration credentials for such Third Parties in order to operate the API.
We may share your data with Third Parties where it is necessary for the operation, integration, hosting, or support of our Services. We ensure that each Third Party has the same stringent confidentiality and security measures as ASI.
We use the following Third Party processors for the following reasons and copies of their respective Privacy Policies are available if you follow the links provided:
Where you are accessing our Services under a licence in the name of your Organisation, we may provide your Customer Material and your Registration Information to your Company where they request us to do so.
We may be required to share your Personal Data with a Third Party for a legal reason, for example
Where you consent for us to share your Data, as for marketing purposes. For example, you may consent to us using a testimonial from you in our marketing material, or to our listing you as one of our customers.
We may share aggregate Non-Personal Data publicly or with Third Parties, for example through displaying marketing trends on our Sites, or for a Third Party to analyse usage statistics.
If for any reason you would like to Modify or Delete the Personal Data we hold for you, you can do one of the following:
Please note that if you delete or request deletion of your Personal Data, we may still retain Non-Personal Data for the purposes of operating the Service, for example to provide historical user levels. We will also retain a single copy of your Registration Information to ensure that you are not re-added to our systems.
ASI will hold your Personal Information as long as it is required for you to enjoy the use of our Services. Upon termination of any of our Services for any reason, we will retain the data mentioned below for the following time periods:
In all cases, you may ask us to remove or modify your data in accordance with the section “Deletion or Modification of Information”, although in some cases this may compromise our ability to deliver our Services.
Where your data is provided to us through a Third Party (e.g. Eventbrite), the same deletion periods will apply as above, but the Third Party may have different policies, and you should use the links provided in “Sharing with Third Parties” and contact those Third Parties directly to ensure deletion of your Data. Where we transfer your data to a Third Party, we will be responsible for the deletion of your data with such Third Parties, as outlined above.
ASI takes great care in implementing, enforcing and maintaining security policies to help ensure the security of our Services, Sites and our User’s Personal Data. You can find out more information about our Security procedures here.
ASI takes steps to ensure as far as possible that it’s staff are honest, reliable and take all due care in the processing, care and handling of all Data.
ASI limits access to any Personal Data we hold to staff who:
Customer Material in SherlockML (with the exception of Customer Material in the form of Registration Information) is hosted on AWS in Ireland which provides advanced security features and is compliant with ISO 27001. All Customer Material is stored with logical separation from information of other customers. ASI limits access to Customer Material to the following ASI staff and contractors:
ASI shall notify the User without undue delay, in the event that any Personal Data held by ASI on the User or on behalf of the User is lost, stolen, or where there has been any unauthorised access to the Personal Data which is likely to result in a high risk to the User’s rights or freedoms. Furthermore ASI undertakes to cooperate with the User in investigating and remedying any such security breach. In any security breach involving Personal Data, ASI shall immediately take remedial measures, including without limitation, reasonable measures to restore the security of the Personal Data and limit unauthorised or illegal dissemination of the Personal Data or any part thereof. ASI maintains documentation regarding compliance with the requirements of the law, including but not limited to documentation of any known breaches and holds reasonable insurance policies in connection with data security.
Personal Data submitted may be transferred by us to Third Parties (as set out under the heading “Sharing with Third Parties”), including service providers that may be situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. Where this is the case we will take reasonable steps to ensure that your privacy rights continue to be protected. In countries where they do not have similar data protection laws to the UK, we will take reasonable steps to ensure that the Third Parties have policies, terms and conditions that provide similar protection to that offered within the EEA as a minimum. By using the Site you agree to this storing, processing and/or transfer.
Customer Data is hosted on AWS in Ireland, and is not transferred outside of the EEA without specific and independent permission.
ASI does not transfer any personal data outside of any jurisdiction in a manner incompatible with the requirements of applicable law.
Upon termination of any of our Services for any reason, you may request a copy of your Personal Data, which ASI will provide in a reasonably acceptable format.
Organisation account holders are able to:
Where the Services are not provided under the control of an Organisation, if you register for our Services with an email address owned by an Organisation, that Organisation may assert control over your Registration Information and Customer Material at a later date. You will be notified if this happens.
If you do not want your Organisation to have control over your access to our Services, please register with a personal email address and do not add a Company name to your Registration Information.
We use them in the following circumstances:
Most browsers allow you to opt out of accepting cookies through their settings and will also allow you to delete cookies already stored on your computer, however, blocking or deleting all cookies may have a negative impact on your use of our Services, and might prevent them from working altogether.
You can opt-out of Google Analytics on all websites by following this link.
Our Services are not directed towards children under the age of 16, and therefore (other than in Customer Material controlled by you) we do not hold any Personal Data relating to Children under 16. If you have reason to believe that we may have been provided with Personal Data on a child under 16, please contact us immediately via our contact form.
You have the right to object to the processing of your Personal data by ASI:
If you would like to object to the above, you can contact us via our contact form here.
If you have a concern about our use of your Personal Data or our information rights practices please let us know. You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), the UK data protection authority, via this link or by calling 0303 123 1113.
The changes will take effect seven (7) days after notice has been provided.
For any queries or comments on the Policy or its content, or for any other purposes you can contact us by using our contact form, or by:
Sending an email to: firstname.lastname@example.org
Advanced Skills Initiative Ltd
54 Welbeck Street
By telephone on: +44 (0)203 637 9415