Privacy Policy
Vivat Learning PTY LTD TAS Lever – Transfer of Learning Privacy Policy
Updated 2nd March 2021
Commitment to User Privacy
Vivat Learning Pty Ltd, TAS Lever-Transfer of Learning, referred to as (“Lever”) is committed to protecting your privacy. Sometimes we do need information to provide services that you request. Lever chiefly deliveries Coach M services and Turning Learning into Action (TLA) services. This document is designed to give a clear explanation of Lever’s data processing practices in our role as a data controller.
If you have any questions or concerns relating to Lever’s services or would like to find out more about how we collect, store or use your personal data, please contact our Data Protection Officer.
Data Protection Officer contact details:
Name Emma Weber
Address 6/104 Soldiers Avenue, Freshwater NSW, Australia 2096
Email address privacy@leverlearning.com
Telephone +61 8221 8833
About Us
Lever’s services include phone based coaching services to support learning transfer and ‘Coach M’ a learning transfer chatbot, which is deployed via the MobileCoach platform. Lever has offices in Freshwater NSW Australia. Find out more here: www.transferoflearning.com.
Lever is subject to investigation and regulatory enforcement by the Australian Regulation.
Lever’s privacy policy complies with the guidelines and framework published and maintained by The Privacy Shield (www.privacyshield.gov).
The Information We Collect & Methods and Primary Purpose for Collection
The personal information you provide is being collected for legitimate business purposes, which may include providing a Coach M chatbot user experience, a Turning Learning into Action coaching service, site visitation statistics, keeping you informed about product updates, our Transfer Matters community and providing the best possible service. Whenever we process data for these purposes, we ensure that we always keep personal data rights in high regard and in accordance to this privacy policy.
Data is collected either directly from you, or from Lever clients on your behalf. It is provided to us voluntarily. Lever uses non-personal de-identified and aggregated data in a variety of ways, including to evaluate and improve the performance of the Lever product, cater to the general preferences of authorized users, or to generate statistics. We do provide statistics on chatbot usage or TLA services in a format that links usage to an individual user to authorised persons within our enterprise client personnel.
Those who don’t consent to this use of their personal data can request that we remove their data by emailing us at privacy@leverlearning.com or by requesting removal from their employer or the associated vendor through which they are using the Lever TLA or Coach M service. Users who request removal of their personal data will not be able to use Lever services.
Lever only collects the personal information necessary for the purposes mentioned above. Please contact us for more specific details as to the data protection legislation and ‘lawful basis’ of how we process your personal information, at privacy@leverlearning.com. Personal information may include the following (however is not limited to) full name, job title, company name, role, location, phone number, messaging application public ID and email address.
Data provided by Lever enterprise clients for their usage of our service is owned by those clients and processing will be performed in accordance with relevant service agreements.
In partnership with Mobile Coach before the 2020 changes, our Coach M product complied with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and the United Kingdom to the United States. If there was any conflict between the terms in this privacy policy and the Privacy Shield Principles, contracts are now being developed with each customer to maintain the standard of the Privacy Shield. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov.
Use of Cookies & Log Files
When you visit our site, a cookie (a very small text file) is placed on your device. If you accept it, it is used to provide you with a personalized experience and to assist in the collection of the site visitation statistics. You may refuse the cookie in accordance with your browser settings.
Lever collects certain information about your computer hardware and software, this includes (however is not limited to) IP address, browser type, operating system, access times and referring website addresses.
This information is used for the operation of the website, to maintain quality of the service, and to provide general statistics regarding use of Lever’s websites.
Information Sharing: With Whom We Intend to Share Information and Why
Lever does not rent or sell customer e-mail lists or phone numbers. Lever does use third party messaging services for delivery of emails and messages that you have consented to receive. These third parties are contractually bound to limit the use of data passed solely for the purposes to which you have provided consent. If you do not consent to share your personal information with third party organizations, you can request that we not transfer your personal data by emailing us at privacy@leverlearning.com.
We may also use third party service providers to support the provision of our services. This could include coaching services, survey services or chatbot services, and or other, less direct business functions including (without limitation) IT support, hosting our data on cloud platforms, legal, accounting, audit, consulting and other professional service providers, and providers of other services related to our business. Proportions of our services may be provided by organisations which Lever has a contractual relationship with, including subcontractors and accordingly to deliver our services your personal information may be shared with them. We only provide these organisations with the information that they need to be able to perform their services.
Within these third party services we have in place agreements which will restrict how they process your personal information. We specifically ensure that they are GDPR compliant.
Although your privacy is very important to us, due to the existing legal regulatory and security environment, we cannot fully ensure that your private communications and other personally identifiable information will not be disclosed to third parties. Lever is required to disclose personal information about an individual in response to lawful requests by public authorities, including to meet national security, record keeping or law enforcement requirements.
Links to Other Websites
Lever communications may contain links to other sites. Please be aware that Lever is not responsible for the privacy practices of such other sites. This privacy statement applies solely to the information collected by Lever.
Security
Lever takes precautions to protect your information. When users submit sensitive information (such as a phone number) over the internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol. Access to all of our users’ information is restricted in our offices and our team’s devices. Only employees who need the information to perform a specific job are granted access to personally identifiable information. The servers that we store personally identifiable information on are kept in a secure environment.
Transfer of Data for EU Residents
The internet is a global environment. The data that we collect from you may be transferred to, and stored at, international destinations including destinations outside Australia and the European Economic Area (“EEA”). It may also be processed by international staff or data processors outside this area, who may be engaged in, among other things, the fulfilment of services provided to you and/or the provision of support.
Due to the recent invalidation of the Privacy Shield by the CJEU, Lever is working towards adopting Standard Contractual Clauses, reflecting the GDPR Principles with each entity in the European Economic Area prior to transferring personal data outside the EEA. If you would like additional information please contact us at privacy@leverlearning.com.
Lever will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. Lever remains liable under the Privacy Shield Principles if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles, unless Lever proves that it is not responsible for the actions causing the damage.
If you do not consent to this transfer, storing, or processing of your personal information please email privacy@moblecoach.com indicating your wishes.
Correcting, Updating or Removing Your Personal Information
Lever will make every attempt to keep your personal data accurate, complete and up to date. If your personal information is incorrect, changes or if you no longer wish to receive information from Lever, we will endeavour to correct, update or remove your information as swiftly as possible. This can be done by e-mailing privacy@leverlearning.com.
Direct Marketing
If you no longer wish to receive newsletters or promotional materials, you may opt out of receiving these communications. You can do it by following the unsubscribe link placed in the footer of the promotional email, or you can simply contact privacy@leverlearning.com and ask to be unsubscribed.
Notification of Changes
Lever reserves the right to amend the privacy notice. In such cases, the ‘last updated’ date will be amended accordingly and you will be informed via statement prominently displayed on the website.
Data Storage and Retention
The personal data we hold is stored on the servers of cloud-based database management services. Lever retains data for the duration of the client’s business relationship with Lever. Lever implements appropriate technical and organisational measures to ensure personal user data is safeguarded.
For more information on where and how long your personal data is stored, and for more information on exercising your rights of erasure/deletion of data or withdrawing consent that had previously been given, please contact the Lever’s data protection officer at privacy@leverlearning.com.
Data Portability
You have the right to access your personal data; you may request it by contacting us at privacy@leverlearning.com.
Dispute Resolution
To resolve disputes you can contact us, at privacy@leverlearning.com. Lever has a policy of responding to an inquiry or complaint within 21 days. If Lever cannot satisfactorily resolve an issue you can reach out to your Data Protection Authority.
You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances.