last updated: May 2018
For the purposes of this policy, SeSE defines the term “User” as an entity with which SeSE has an established relationship, the term “Applicant” as any individual who applies for a course or who is included as a contact in a User’s account and the term “Visitor” as an individual that visits our front-end website.
Any information stored on SeSE’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. Appropriate technical, security and organizational measures are implemented to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.
- Collection and use
The following sections cover the specifics of each of the three groups from which data is collected: website Visitors, Applicants and Users.
2.2 Website Visitors
If you are a Visitor to our website only, and not a Applicant to a course or a user of our platform, then this section is relevant for you.
By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website may not be possible.
SeSE gathers data about visits to the website, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or where Visitors have come.
2.2.1 Purpose of processing personal data
SeSE uses the collected data to for statistical purposes, to customize content for Visitors.
2.2.2 Sharing personal data
SeSE does not share any information with third parties.
2.2.4 Links to other sites
Applicants should be aware that by applying to a course, they could be disclosing information that could make them personally identifiable to SeSE Users. The security and privacy protection implemented on SeSE’s platform does not cover this type of transfer or disclosure of personal information. Applicants responding should be aware that they alone are responsible for the content of their responses. For more detailed information concerning the protection of privacy when responding to surveys or survey invitations, Applicants may contact the course responsible. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. SeSE will not process Personal Data of Applicants for other purposes or by other means than instructed by its Users.
If you wish to inquire about your Personal Data that may have been collected in a SeSE application, we recommend that you contact the course responsible. As SeSE is a Processor, it does not control the Personal Data used or stored in the survey, but processes it on behalf of its User.
In order to provide services to its Users, SeSE collects certain types of data from them. Furthermore, SeSE Users collect information from Applicants when they register for a course. This section will describe how these data are collected and used by SeSE as well as geographical differences that effect this policy. Data entered or transferred into SeSE by Users such as texts, questions, contacts, media files, etc., remains the property of the User and may not be shared with a third party by SeSE without express consent from the User.
2.4.2 Collection of User data
During a User’s registration and later on SeSE;s platform, they provide information minimum information such as name, company name, email. This information is used by SeSE to identify the User and provide them with support, services, mailings.
SeSE Users can at any time access and edit, update or delete their contact details by logging in with their username and password to SeSE’s platform. SeSE Users may create more Users with different privilege levels within their account. It is the responsibility of the User that creates other User accounts, to choose the level of access each User should have. Once these new Users log into SeSE, they meet the definition of User in this policy. SeSE will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
2.4.3 Collection of Applicants data
Application forms or surveys are used for gathering feedback are created by Users, who make them available to relevant individuals. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. SeSE will not process Personal Data for other purposes or by other means than instructed by its Users.
Applicants data includes data from individuals uploaded, transferred or manually entered by a SeSE User into their account for the purpose of providing feedback to the User by responding to a course. Personal Data may include, personal contact information such as name, email address, employment details, education/qualification, and other sensitive Personal Data. Answers to questions by Aplicants, may also include Personal Data.
The purpose of collecting Personal Data as part of a registration will vary depending on the course, as set up by SeSE’s Users. As SeSE provides courses to a wide group of students, the purpose may vary. For Users in the EEA, or for Users providing courses to students in the EEA, the User will be the “controller”, as defined in the Directive and the GDPR. The purpose will consequently be defined by SeSE’s User.
2.4.4. Geographical location
SeSE is located in one center where User and Applicants data is stored.
188.8.131.52 Processing in the European Economic Area (EEA)
SeSE has only User located in the Nordic countries and all processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and SeSE processing will take place in accordance with the GDPR.
SeSE processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR:
The SeSE entity which you as a User entered an agreement with when using SeSE platform, will be the Controller for User data, as outlined above in “Collection of User data” section.
For Applicants data, as outlined in the “Collection of Applicants data” section, the User will be the Controller in accordance with Directive and GDPR, and SeSE will be the Processor.
SeSE adheres to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently, SeSE processes all data provided by its Users with accounts in its European Data Region, in the European Economic Area (EEA) only.
All data collected by SeSE Users through surveys will be stored exclusively in secure hosting facilities provided by Loopia Web Services. SeSE has a data processing agreement in place with its provider, ensuring compliance with the Directive. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.
184.108.40.206 Processing in the United States Of America (US)
SeSE do not operate with Users located in United States Of America (US)
220.127.116.11 Processing in Canada
SeSE do not operate with Users located in Canada.
18.104.22.168 Processing in other regions
SeSE do not operate with Users located from other regions.
- Retention and deletion
SeSE will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Applicants data, SeSE’s Users have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For Applicants data, Users with an active account will therefore have the responsibility to delete data when required. When a users’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.
- Acceptance of these Conditions
- Our Legal Obligation to Disclose Personal Information
We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to SeSE or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.
- SeSE’s Data Protection Officer
SeSE has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:
- For Further Information
If you have any further questions regarding the data SeSE collects, or how we use it, then please feel free to contact us by email at: firstname.lastname@example.org