Privacy & cookies policy
gomo Learning Limited and its group companies (“we” or “us”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, through this website (“our site”) or as otherwise indicated to you by us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We are responsible for operation of the site at gomolearning.com (“our site”). Our corporate details are: Gomo Learning Ltd, 52 Old Steine, Brighton, East Sussex, BN1 1NH, UK, Tel. +44(0)1273320631.
Information we may collect from you
We may collect and process the following data about you:
- Information that you provide. This may be by filling in forms on our site, providing us with your business card or contact details, providing us with your information in registering to use our client support tools, and/or or by corresponding with us by phone, email or otherwise. This includes information provided at the time of registering to use our site, subscribing to our services, posting material or requesting further information and/or services. We may also ask you for information if you report a problem with our site. The information that you provide to us may include name, email address, company and position, address and telephone number and other such information as may be communicated to, or provided by you, as well as the details contained in your query;
For additional details of transactions carried out through our site or other types of information collected you may contact us at firstname.lastname@example.org.
Our site may use session and persistent cookies. The cookies placed by the gomo server are readable only by us, and cookies cannot access, read or modify any other data on your computer. We may use web beacons alone or in conjunction with cookies to compile information about your usage of our site and interaction with emails from gomo. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our site, in order to improve our site and email communications.
Our site may contain links to other websites including share and/or “like” buttons. These other websites, services and applications may set their own cookies on users’ computers, collect data or solicit personal information. You should refer to their privacy policies to understand how your information may be collected and/or used.
Here is which cookies gomo uses on our site:
We use preference cookies to collect information about your choices and preferences, and to allow us to remember language or other local settings and customize our site accordingly. Specific preference cookies used by us are the following:
|COOKIE NAME||COOKIE TYPE||COMPANY||EXPIRATION||DESCRIPTION|
|strPaperSize||Session||gomo||Immediately after browser closes||Takes in a value of “a4” or “ltr” to determine which type of collateral is suitable to our website audience based on their preferred language. All English US users will get the “ltr” value, while the rest will get “a4”.|
|pi_opt_in||Persistent||Pardot||3650 days (unless restricted)||This Cookie is set by Pardot. It allows visitors to opt in to the “Do Not Track” initiative, meaning their data will not be stored by Pardot.|
We also use analytics cookies to collect information about your use of our site, and to enable us to improve the way our site works. For example, analytics cookies show us which are the most frequently visited pages on our site, help us record any difficulties you have with our site, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on our site, rather than the usage of a single person. We use the information to analyse the site traffic, but we do not examine this information for individually identifying information. Specific analytical cookies used by us are the following:
|COOKIE NAME||COOKIE TYPE||COMPANY||EXPIRATION FROM WHEN IT IS FIRST PLACED||DESCRIPTION|
|_utma||Persistent||Google Analytics||24 months||Keeps track of the number of times a visitor has been to the site pertaining to the cookie, when their first visit was, and when their last visit occurred.|
|_utmb||Session||Google Analytics||30 minutes||Takes a timestamp of the exact moment in time when a visitor enters a site.|
|_utmc||Session||Google Analytics||Immediately after browser closes||Takes a timestamp of the exact moment in time when a visitor leaves a site.|
|_utmv||Persistent||Google Analytics||24 months||Used to store visitor-level custom variable data. The cookie is updated every time data is sent to Google Analytics.|
|_utmt||Session||Google Analytics||after 10 minutes||This cookie is set by Google Analytics. According to their documentation it is used to throttle the request rate for the service – limiting the collection of data on high traffic sites.|
|_utmz||Persistent||Google Analytics||6 months||Keeps track of where you came from, what search engine you used, what link you clicked on, what keyword you used, and where they were in the world when you accessed a website. It expires in 6 months.|
|visitor_id||Persistent||Pardot||3650 days (unless restricted)||This Cookie is set by Pardot. It gives a unique identifier for each visitor, the first four digits of which identify the account, and the second four digits of which identify the user. This tracks which users are using which parts of the site.|
We use Remarketing with Google Analytics to advertise online. Third party vendors, including Google, may show our ads on sites across the internet.
We, and third party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to our website. Remarketing cookies used by us expire after 30 days. To opt out of Remarketing or to control your ad preferences, please click here. Specific marketing cookies used by us are the following:
|COOKIE NAME||COOKIE TYPE||COMPANY||EXPIRATION||DESCRIPTION|
|Google Remarketing||Persistent||Google DoubleClick||30 days from when it is first placed||This cookie is placed in your computer so after you leave our website Google can show you advertisements about Gomo that you might be interested in, based on your previous behaviour on our website|
Most web browsers have a “help” menu where you can review how to prevent your browser from accepting new cookies, how to have your browser alert you when you receive a new cookie or how to fully disable cookies on your browser. You can learn more about cookies at sites like www.aboutcookies.org. If you use your browser settings to block all cookies, you may not be able to access all or parts of our site.
Where we store your personal data and how long for
Our site is hosted on servers located in the UK and support being provided by gomo staff based in the UK however the personal information that we collect from you is input directly into our Salesforce database, which is hosted and supported in the EEA, and our Pardot database, which is hosted and supported in the US. For users based in the European Economic Area (EEA), this means that the data that we collect from you via our site will be transferred to, and stored outside the EEA. It may also be processed by staff operating outside the EEA who work for us. We have signed EU Model Clauses with our relevant group entities and with Pardot, which means that such transfers would be lawful transfers of personal data outside the EEA, in accordance with EU Data Protection legislation.
Unfortunately, the transmission of information via the internet is almost never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We will keep a copy of your personal data for as long as you remain registered with our site/the applicable service or the contact person at any organisation we are dealing with and thereafter for such period as may be required for legal, audit and compliance purposes. This does not affect your right to opt out from receiving marketing communications, as outlined in the section “Your rights” below. If at any time after you are no longer registered with our site/the applicable service or are no longer the contact person at the applicable organisation that we are dealing with, you may request that your details are deleted from our CRM systems, however you should be aware that if your details are deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future.
Uses made of the information
We use information held about you in the following ways:
- To provide you with information via post, email or telephone, about our products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
- To carry out our obligations arising from any contracts entered into between you and us or to enable us to deal with any query you have raised;
- To allow you to participate in interactive features of our service, when you choose to do so;
- To notify you about changes to our service;
- To administer our site and for internal operations, including trouble shooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure.
This will include your details being included in our Salesforce and Pardot databases.
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, provided however that we shall remain responsible for the treatment of such group members of your personal data in accordance with this policy. As stated above, where such disclosure involves the transfer of personal data outside of the EEA, gomo has entered into EU Model Clauses with its relevant group entities to ensure any such disclosure is on a legal basis.
Our general policy is not to disclose any personal data to a third party except with your prior consent. However, we may disclose your personal information to third parties:
- If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If gomo or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of business and other agreements; or to protect the rights, property, or safety of Gomo, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Purchases made through our website
If you make a purchase via our website, you will be required to provide us with your payment details. These details will be made available in part to both the payment gateway and merchant bank involved.
Your personal data will only be used by Recurly and Stripe for the purposes of processing your payment, and will be securely encrypted. Recurly and Stripe are both based in the US, so your transaction may involve your personal data being transferred outside of the EEA directly to them. Both Recurly (https://recurly.com/legal/privacy) and Stripe (https://support.stripe.com/questions/stripe-and-european-data-transfers) self-certified under the EU-U.S. Privacy Shield framework.
Legal basis of our processing of your personal data.
We process your personal data on the basis of your consent (in relation to sending you marketing information following your submitted request through our site), (alternatively or additionally) for our legitimate interests of promoting, growing and developing our business and, where you are a customer, in order to perform our obligations under the contract between us.
You have the right to ask us not to process your personal data for marketing purposes. You may also choose not to receive publications or certain other communications from us by explicitly indicating so in the appropriate section of the Registration Form or by opting-out by phone, email or via direct marketing emails sent to you.
We will inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to, or may disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by (un)checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com or by unsubscribing per the method outlined in any emails sent or during any phone calls with you.
Our site may, from time to time, contain links to and from the websites of our partner networks, clients, and/or affiliates. If you follow a link to any of these websites, please note that these websites are subject their own privacy policies and that we do not accept any responsibility or liability for these sites and policies. Please check these policies before you submit any personal data to these websites.
You also have the right to ask us to amend inaccurate personal data or to delete it. However you should be aware that if you request your details to be deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future. If you send us any personal information in digital format, such as photographs, you are entitled to ask for a copy of this to be sent to you.
Where you are based in the EU you have the right to contact your local data protection authority and you can request details of how to do this by contacting us at firstname.lastname@example.org.
Any queries concerning your rights or the exercising of them and any complaints concerning the processing of your personal data should be sent to email@example.com.
Access to information
We are subject to the Data Privacy Act in the UK and, for our processing activities in Europe, the Data Protection Directive 95/46/EC and e-Privacy directive 2002/58/EC (together with national implementing legislation), and, effective May 25, 2018, the General Data Protection Regulation 2016/670 (together referred to as “Applicable Legislation”) The Applicable Legislation gives you the right to verify whether we hold your personal data and (have) access your personal data. Any data access request may be subject to a reasonable fee to meet our costs in dealing with your request.
This policy may be updated by us from time to time, so please check this policy periodically to ensure you are aware of our latest policies.