Privacy Policy - Development Beyond Learning

1. Who we are

Development Beyond Learning Pty Ltd (“DBL”, “we” or “us”) a company registered in Australia, whose registered office is at Suite 7, Level 22, 227 Elizabeth St, Sydney, NSW 2000 understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our employees, agents, contractors, or other parties working on behalf of DBL and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

This Notice covers our use of personal information when we provide soft skill learning and development services to you or your organisation, engage you to provide services to us, when you browse our website, or otherwise interact with us (collectively, the “Services“). If any of these apply to you, please read this Notice carefully. Except as specified in the next paragraph below, DBL is the data controller in respect of the personal information that it collects, uses and otherwise processes as described in this Notice.

Group companies covered by this Privacy Notice:

DBL Europe Limited registered (CRN: 0909 4141) in the United Kingdom
DBL Australia Pty Limited registered (ACN:112 714 922) in Australia
DBL Asia PTE LTD registered (CRN: 202104136R) in Singapore

Development Beyond Learning contact details are as follows:

Address: Suite 7, Level 22, 227 Elizabeth St, Sydney, NSW 2000

If you have questions, please contact the Privacy & Security Officer at:

Email: support@developmentbeyondlearning.com
Telephone: +61 2 8898 9703
Postal: Suite 7, Level 22, 227 Elizabeth St, Sydney, NSW 2000

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (“GDPR”), UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means. You can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

5. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children.

Contact data

DBL processes the following categories of personal data as contact data: first name, last name, email addresses, postal address/location (country, state/province, city), telephone numbers, and your employer’s details.

Personal data related to providing our service

In the context of DBL providing the service to its customers, DBL processes the customers company name, industry, your job title and role, department and function and your company’s relationship history to DBL. If you provide a credit card number or bank details to order products or services, DBL will collect this information to process your payment for the requested products or services.

Compliance related personal data

If required by statutory law or regulation, DBL may process data categories like academic credentials, customer-relevant information about e.g., significant litigation or other legal proceedings, and other export control or custom compliance relevant information.

Data generated through your use of, or participation in, DBL’s internet pages, web, or online offerings.

Usage data

DBL processes certain user related information, e.g., info regarding your browser, operating system, or your IP address when you visit DBL’s web properties. We also process information regarding your use of our web-offerings, like the pages you visit, the amount of time you spend on a page, the page which has referred you to our page and the links on our sites you select.

Registration data

DBL may process your contact data as set out above and other information which you may provide directly, or is provided by your employer, to DBL if you register for any of DBL’s services or events, such a webinars.

Participation data

When you participate in webinars, virtual seminars, events, or other DBL web services, DBL may process your interactions with the relevant web service to organise the event including its sessions, polls, surveys, or other interactions between DBL and/or its participants. Depending on the event and subject to a respective notification of the participants, DBL may collect audio and video recordings of the event or session.

Special categories of personal data

In connection with the registration for an event, DBL may ask for your dietary preferences or information about potential disabilities for purposes of consideration for the health and well-being of our guests. Any collection of such information is always based on the consent of the participants. Kindly note that if you do not provide such information about dietary preferences, DBL may not have the opportunity to respond to such requests at the time of the event.

Personal data received during an application for a job at DBL

DBL processes personal data of individuals applying for a job at DBL.

Personal data received by third parties, including publicly available sources

DBL generally aims to collect personal data directly from the data subjects. If you or applicable law allows DBL to do so, DBL may obtain personal data also from third party sources. These third-party sources may include:

your employer in the context of its business dealings with DBL and its Group companies;
third parties you directed to share your personal data with DBL;
third party sources and publicly available sources like business oriented social networks.

When we collect personal data from third party sources, established internal controls aim to ensure that the third-party source was permitted to provide this information to DBL and that we may use it for this purpose. DBL will treat this personal data according to this Privacy Notice, plus any additional restrictions imposed by the third party that provided the personal data to DBL or by applicable national law.

Personal data necessary for customer satisfaction

To the extent permitted by law or based on your consent, DBL may combine the information we collect either directly or indirectly about specific users to ensure the completeness and correctness of the data and to help us better tailor our interactions with you and determine the information which best serves your respective interest or demand.

Newsletter and Marketing Communications

When you sign up for our newsletters or marketing communications, we collect and process the following personal data:

Your name
Your work email address

We use this information to:

Send you newsletters and marketing communications about our products and services
Personalise our communications based on your interests and interactions with us
Analyse the effectiveness of our marketing efforts

By signing up for our newsletters or marketing communications, you consent to the collection and use of your personal data for these purposes. You can withdraw your consent at any time by unsubscribing from our communications or contacting us at info@developmentbeyondlearning.com.

We will retain your personal data for marketing purposes until you unsubscribe or request deletion of your data. We may retain certain information as required by law or for legitimate business purposes.Your rights regarding your personal data, including the right to access, correct, or delete your information, are outlined in Section 4 of this Privacy Policy.

We do not sell or share your personal data with third parties for their marketing purposes without your explicit consent.

6. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data:

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary. Your personal data will therefore be kept for as long as is required to:

To make products and services requested by you or your employer available to you;
For DBL to comply with statutory obligations to retain personal data;
To fulfil DBL’s legitimate business purposes as further described in this Privacy Notice, unless you object to DBL’s use of your personal data for these purposes;
Until you revoke a consent you previously granted to DBL to process your personal data.

DBL may retain your personal data for additional periods if necessary for compliance with legal obligations to process your personal data or if the personal data is needed by DBL to assert or defend itself against legal claims. DBL will retain your personal data until the end of the relevant retention period or until the claims in question have been settled.

8. How and Where Do You Store or Transfer My Personal Data?

We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.

Please contact us using the details below in Part 11 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

9. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may share your personal data with other selected companies in our group for mutually agreed access to learning and assessment platforms. This includes subsidiaries our holding company and its subsidiaries.

We may sometimes contract with third parties to supply products and/or services to us.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: Support@developmentbeyondlearning.com

Telephone number: +61 2 8898 9703

Postal Address: Suite 7, Level 22, 227 Elizabeth St, Sydney, NSW 2000

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website.