Privacy, Data Protection and Cookies Policy 
 
Overview 
 
Haynes Oliver Ltd, trading as Titan Learning (Titan) is committed to protecting and respecting your privacy. This policy together with our terms of use and any other documents referred to on it, set out the basis on which any Personal Data (as defined below) we collect from you or which you provide to us will be processed by us as a result of using or interacting with our software platform as set out below. We aim at all times to process and collect your data lawfully, transparently, fairly and without adversely affecting your rights as a Data Subject (as defined below). Please read the following carefully to understand our practices and procedures. The software platform we operate is: app.titanlearning.co.uk, its related domains and sub domains (our Platform) which is hosted by Inforox Ltd, using Cloudways servers located in the UK. 
 
Please note: 
 
By giving your consent, you are accepting and consenting to the practices described in this policy. If you do not give your consent, please navigate away from the Our Platform. 
You may withdraw your consent at any time. An explanation of your rights is set out below. 
For the purpose of the Data Protection Legislation (as defined below), the data controller is Haynes Oliver Ltd, a limited liability company with company number 12148160 whose registered office is at 1 Edward Road, Bedworth, Warwickshire CV12 8PS. 
Our nominated representative, for the purpose of the Data Protection Legislation is Dave Bownes. We have determined that we are not required to appoint a Data Protection Officer. We can be contacted at info@haynesoliver.com 
If you are not satisfied with any action taken by us or response given, you have the right to complain to Information Commissioner at www.ico.org.uk, or help line telephone number: 0303 1231113. 
 
Definitions 
 
In this policy the following terms shall have the following meanings: 
Cookie: a small file placed on your computer or device by our Platform and/or when you use certain features of our Platform. 
Cookie Law: means the relevant parts of the Privacy and Electronic Communications Regulations 2003. 
Data Protection Legislation: the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003, as amended, updated or superseded from time to time, in the UK. 
Data Subject: a natural identifiable person. 
Personal Data: has the meaning set out in the Data Protection Legislation, being as at the data of this policy, any data which identifies a natural person (by way of example, name, address, phone number and so on). 
 
What this policy also covers 
 
This policy also explains: 
 
What personally identifiable information of yours is collected: 
on our Platform when you create an account and interact with it; and 
when you download from our Platform. 
What organisation is collecting the information; 
How the information is used; 
With whom the information may be shared; 
What choices are available to you regarding collection, use and distribution of the information; 
What kind of security procedures are in place to protect the loss, misuse or alteration of information under Titan’s control; 
How you can correct any inaccuracies in the information; and 
How you can request the information we process and store to be removed. 
 
There are other terms that may apply to you 
 
In addition to this policy, please refer to our terms of use. 
 
We may make changes to these terms 
 
We may update and change these terms and our terms of use from time to time for a variety of reasons. By way of examples: to reflect changes to the services we offer, user’s needs, regulatory or legal requirements. Every time you wish to use our Platform, please check these terms to ensure you understand the terms that apply at that time. These terms were updated in December 2021. 
 
Persons under the age of 16 
 
Persons under the age of 16 are not eligible to use our Platform and we ask that minors do not submit any personal information to us. We will not knowingly accept any data from a person who is under the age of 16 years. 
 
Information we collect from you 
 
We will collect and process the following information: 
 
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform (Technical Data); 
 
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us. 
 
• Information about how you use the Platform (Usage Data); 
 
• if you: (a) create an account; (b) report a problem with our Platform; or (c) otherwise correspond with us, we may collect your first name, last name or similar identifier (Identity Data) and your email address and contact number (Contact Data). 
 
We do not collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose nor do we collect any “Special Categories” of Personal Data about you (for example any details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect information about criminal convictions and offences. 
 
If do not input your Identity Data you will not be able to use the Platform. 
 
How is your personal information collected? 
 
We only collect your Identity Data and Contact Data via direct interaction which means we only collect your Personal Data when you contact us or interact with our Platform. 
 
Use of your information 
 
We will use the data collected about you to enable you to access and use the learning resources on our Platform. We may also use your data to improve the efficiency of our Platform, to administer and update our Platform to ensure it runs smoothly on your hardware and to offer you support in the event that you have a problem or issue with our Platform. We will also collect your data to understand our users’ requirements and preferences, perform analysis and comparisons. 
Please also see below under “Cookies”. 
 
Purpose/ Activity Type of Data Lawful basis for processing including basis of legitimate interest 
To deal with your enquiry (a) Identity 
(b) Contact You have given us your consent 
To create a user account for you (a) Identity 
(b) Contact Performance of a contract 
To enable you to use and interact with the Platform (a) Identity 
(b) Contact Performance of a contract 
To administer and protect our Platform (including troubleshooting, data analysis, testing, maintenance, hosting ad support) (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 and in the context of a business re-organisation or group restructuring exercise) 
(b) Necessary to comply with a legal obligation. 
To use data analytics (including Cookies), to improve our Platform and your experience of it. (a) Technical 
(b) Usage (a) Necessary for our legitimate interests (to define types of users, to keep our Platform updated and to develop our business and to inform our marketing strategy). 
 
Purpose/ Activity 
Type of Data 
Lawful basis for processing including basis of  
legitimate interest 
To deal with your enquiry 
(a) Identity 
(b) Contact 
You have given us your consent 
To create a user account for you 
(a) Identity 
(b) Contact 
Performance of a contract 
To enable you to use and interact with the Platform 
(a) Identity 
(b) Contact 
Performance of a contract 
To administer and protect our Platform (including  
troubleshooting, data analysis, testing, maintenance,  
hosting and support) 
(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 and in  
the context of a business re-organisation  
or group restructuring exercise) 
(b) Necessary to comply with a legal obligation. 
To use data analytics (including Cookies), to improve our Platform and your experience of it. 
(a) Technical 
(b) Usage 
(a) Necessary for our legitimate interests (to define  
types of users, to keep our Platform updated and 
to develop our business and to inform our marketing strategy). 
 
Where we store your personal data 
 
· The data we collect from you is stored in the European Economic Area ("EEA"). By submitting Personal Data on our Platform, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. 
· We use SSL (Secure Sockets Layer) technology to encrypt the data on Our Platform. 
· You are responsible for ensuring that the password you have entered to enable you to create your account and access our Platform is and remains confidential at all times. Do not share your password with anyone. 
· We take all reasonable technical, organisation and security steps to ensure that the information you supply to us over the internet is secure. 
 
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 purpose 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 that there is a prospect of litigation. 
 
Your rights 
 
As a Data Subject under the Data Protection Legislation you have the following rights: 
 
· You have the right to ask us not to process your Personal Data for marketing purposes. We will not share your information with third party marketing agencies without your prior consent. 
· You have the right to ask us to supply to you the information we hold, this is known as a data subject access request. For further details please contact us on: email: info@haynesoliver.com 
· You have the right to ask us to rectify the data we hold in the event that it contains inaccuracies or is incomplete. To discuss this please contact us on: email: info@haynesoliver.com or in writing to: 1 Edward Road, Bedworth, Warwickshire CV12 8PS. 
· You have the right to ask us to erase the Personal Data we hold if: (i) it is no longer necessary for us to hold the data; (ii) you wish to withdraw your consent to us holding the data; (iii) you object to us holding or processing the data; (iv) you believe that we have processed the data unlawfully; or (v) the data needs to be erased for us to comply with a particular legal obligation. To make a request please contact us on: email: info@haynesoliver.com or in writing to: 1 Edward Road, Bedworth, Warwickshire CV12 8PS. 
 
Disclosure of your information 
 
You agree that we have the right to share your Personal Data with: 
· Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. 
· Selected third parties including: 
• Our sub processors Inforox Ltd, Cloudways, business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; 
• analytics and search engine providers that assist us in the improvement and optimisation of Our Platform; 
· To a prospective buyer or seller if we sell or buy any business or assets. 
· If any of the shares in Titan are sold 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 to comply with any legal obligation, or to enforce or apply our terms of business or terms of use, and other agreements; or to protect the rights, property, or safety of Titan, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud detection and credit risk reduction. 
 
Cookies 
All Cookies used by Titan on our Platform are used in accordance with current Cookie Law. We may from time to time use some or all of the following types of Cookie: 
 
• Strictly Necessary Cookies (SNC) - a Cookie falls into this category if it is essential to the operation of Our Platform, supporting functions such as logging in. 
• Analytics and Flash Cookies (AFC) - Analytics Cookies might enable us to gather this information, helping Titan to improve our Platform and your experience of it. 
• Functionality Cookies (FC) - enable us to provide additional functions to you on our Platform, such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category. 
• Persistent Cookies (PC) - any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Platform. 
• Session Cookies (SC) - any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit our Platform until you close your browser. Session Cookies aren’t deleted when you close your browser, to delete these cookies you will need to clear your browser history. 
• Web beacons (WB) - certain pages on our Platform and e-mails may contain small electronic files known as web beacons. Web beacons permit Titan to monitor the volume of users of our Platform and the popularity of certain pages. 
 
The only Cookies we currently use on our Platform are strictly necessary Cookies to enable our Platform to work. Details are set out below. 
 
Suppliers and Other Service Providers 
 
From time to time we use third party suppliers and service providers to facilitate our services. Where any service provider collects information directly from you will be notified of the involvement of the supplier or service provider, and all information disclosures you make will be strictly optional. 
 
Control of your password 
 
You must not disclose your password to any third parties nor share it with any third parties. If you lose control of your password, you may lose control over your Personal Data which in turn may commit you to legally binding obligations without your consent. Therefore, if your password has been compromised for any reason, you should immediately contact us at: info@haynesoliver.com 
 
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