PRIVACY AND COOKIES POLICY

September 2020 

1. Introduction  

​1.1 We, uQualio ApS, are committed to safeguarding the privacy of our website members and visitors; in this policy we explain how we will treat your personal information. 

1.2 By agreeing to this policy, you consent to our use of cookies, and to the processing of your personal information in accordance with the terms of this policy.

1.3 In addition to this policy, our Terms and conditions of use and possibly also Commercial terms - Additional terms of use - apply which include general rules for your use of the website, services and products. Our Terms and conditions of use can be found here and the Commercial Terms - Additional terms of use - can be found here.

1.4 When using our platform as a member, you decide whether you want to use the available social networking services.

1.5 When accessing a course, you can be asked to give the publisher of the course permission to follow your progress, analyze and use your learning and/or test results for documentation, to communicate with you, and to contact you with regard to future courses. You can at any time withdraw the permission.

2. Data Controller or joint data controller

​2.1 When using and registering as a member with our website, uQualio is data controller with respect to the personal data mentioned in section 3.1, 3.2.2 - 3.2.6. 

2.2. When accessing a course, uQualio and the company that offers the specific course are joint data controllers with respect to the personal data processed in connection with the accessing, participation and completion of a course.

2.2.1 In our capacity as joint data controller we process the personal data mentioned in section section 3.2.1 and 3.2.7. You can read more about this in the Agreement on Joint Data Controllership.

2.2.2 You acknowledge that uQualio has no control over, and are not responsible for, the privacy policy of the company, that offers the specific course, and practices of third parties. ​

2.2 All enquiries to us must be made via the contact information stated under section 20.

3. Collecting personal information 

3.1 When you visit our website


​Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.

3.1.1 Geographical location, language, browser type etc.


We collect the following information about your computer and about your visits to and use of this website: Geographical location, language, browser type and version, operating system type and version, type of device and screen resolution.


We process this personal information to administer our website and business and to personalize our website for you. 


Our processing of these data is necessary to fulfill our agreement with you and to deliver the website, services and products.


The legal basis for the processing is according to Article 6(1)(b) and Article 6(1)(f) of the GDPR.  

3.2 When you create a profile


Personal information submitted to us when you create a profile on our website will be used for the purposes specified in this policy or on the relevant pages of the website.

3.2.1 E-mail address or phone number


We collect your email address or phone number that you provide to us when you create a profile on our website.


Our processing of these data is necessary to fulfill our agreement with you to deliver the website, services and products, including dealing with inquiries and complaints made by or about you relating to our website and to verify compliance with the terms and conditions governing the use of our website.


The legal basis for the processing is according to Article 6(1)(b) of the GDPR. 

3.2.2 Type of device, time zone, language, browser etc.


We collect information that you provide to us when using the services on our website, or that is generated in the course of the use of those services including type of device, time zone, language, browser type, browser version, operation system type, operation system version, screen resolution and user ID. 


These data are collected in order to provide us with information to offer you better service and to provide third parties with statistical information about our users. However, the third parties will not be able to identify any individual user from that information. 


The legal basis for the processing is according to Article 6(1)(f) of the GDPR. 

3.2.3 Information about your identity, interests and hobbies, profile pictures etc.


We collect information that you freely provide to us when creating your profile on our website including your name, user name, profile pictures, interests and hobbies and the content of your posts.


Our processing of these data is necessary to fulfill our agreement with you to deliver the website, services and products and in order to send you marketing communications which we think may be of interest to you, by post or, where you have specifically agreed to this, by email, SMS or similar technology.


The legal basis for the processing is according to Article 6(1)(b) and Article 6(1)(f) of the GDPR.  

3.2.4 Communication content and metadata


We collect information contained in or relating to any communication that you send to us or send through our website including the metadata associated with the communication.


We process this information to keep our website secure and prevent fraud. The legal basis for our processing of these data is according to Article 6(1)(f) of the GDPR. 

​3.2.5 Information in connection with support


If you use our support in connection with questions regarding the use of our service, e.g. in relation to solving technical problems or similar questions, we use your e-mail address and/or phone number and the other information you provide to us.


The collection of these personal data is necessary in order to fulfill the agreement with us regarding your use of our service. If you do not wish to provide us with this data, do not use our support. 


The legal basis for our processing of these data is according to Article 6(1)(b) of the GDPR.  

3.2.6 Name, e-mail address, phone number


We collect information that you provide to us for the purpose of subscribing to our email/SMS notifications and/or newsletters and/or social networking services including your name, email address and phone number.


Our processing of these data is necessary to enable your use of the social networking services available on our website, to send you non-marketing commercial communications and to send you email notifications that you have specifically requested.


The legal basis for the processing of these data is according to Article 6(1)(b) and Article 6(1)(f) of the GDPR.

​3.2.7 Test and learning results


We collect your test and learning results registered on your profile.


Our processing of these data is necessary to propose elearnings and/or test and is necessary to fulfill our agreement with you to deliver this the website, services and products.


We also process these data to analyze and use your learning and/or test results for analytical purposes and, if you have chosen to use the social networking services, make it available on our website, visible for other members and for the publisher of a course, which you have accessed in our system, and who you have granted permission. 


The legal basis for the processing is according to Article 6(1)(b) of the GDPR.  

​3.3 Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

3.4 If you submit personal information for publication on our website, we may publish and otherwise use that information in accordance with the license you grant to us. 

3.5 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.

3.6 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing, unless actively approved by you.

4. Disclosing personal information 

4.1 Disclosure of your personal information to another entity, natural person or the like ("recipient") means that the recipient of the information becomes data controller regarding their processing of your personal information. You acknowledge that we cannot be held responsible for the processing of your personal information by another data controller. 

4.2 We may disclose your personal information, including your test and learning results, to the organization, who has published the specific course or the like and you have given them permission to do so, insofar as reasonably necessary for the purposes set out in this policy.

4.3 If your privacy settings limit the publication of your information on your “public profile”, we may nevertheless disclose your personal information, including your test and learning results, to the organization, who you actively have given permission to do so and who has published the specific course test or the like to our website, insofar as reasonably necessary for the purposes set out in this policy.

​5. Use of data processors 

5.1 We may transfer your personal information to any of our suppliers or subcontractors to undertake the operation of our website and other assistance related hereto and insofar as reasonably necessary for the purposes set out in this policy. 

5.2 We may transfer your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

5.3 We may transfer your personal information: ​

​a. to the extent that we are required to do so by law;

b. in connection with any ongoing or prospective legal proceedings;

c. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

d. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and

e. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

​5.4 Except as provided in this policy, we will not transfer your personal information to third parties.

6. International data transfers 

​6.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy. ​

6.2 Information that we collect is only transferred to countries within the European Economic Area. 

6.3 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

7. Retaining personal information  

​7.1 This section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information. 

7.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 

7.3 Without prejudice to section 7.2, we will generally delete personal information when a member deletes his/her membership, cf. however section 7.4.

7.4 Notwithstanding the other provisions of this section 7, we will retain personal information: 

a. to the extent that we are required to do so by law;

b. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

c. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

8. Security of personal information  

​8.1 We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.

​8.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers. ​

8.3 All electronic financial transactions entered into through our website will be protected by encryption technology. 

8.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. 

8.5 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

9. Amendments 

​9.1 We may update this policy from time to time by publishing a new version on our website. ​

9.2 You should check this page occasionally to ensure you are happy with any changes to this policy. 

9.3 We will notify you of changes to this policy by email or through notification on our website.

10. Your rights  

​10.1 Your right of access 

10.1.1 You are at any time entitled to by a written request to receive information about our processing of your personal information, e.g. which information we have registered about you, the processing purpose, the categories of personal information concerned and the recipients to whom the information have been or will be disclosed.

10.1.2 You are entitled to receive a copy of the personal information we process about you. For delivery of more than one copy, we are entitled to charge a reasonable fee based on the administrative costs. Request to exercise this right must be sent in writing to us via the contact information stated under section 20 together with documentation that you are the person in question.

​10.2 Your right to rectification 

10.2.1 You have the right to have incorrect personal information about you rectified by us without undue delay. If you become aware that there are errors in the information we have registered about you, we urge you to contact us in writing in order for us to rectify the information. See contact details under section 20.

​10.3 Your right to deletion 

10.3.1 You have a right to have your personal information deleted by us without undue delay if, for instance, we no longer have a valid processing purpose or you withdraw your consent on which the processing is based etc. If we can demonstrate compelling, legitimate reasons for continued processing which precede your interests, rights and freedoms or the processing is necessary for a legal claim to be established, exercised or defended, we are not obliged to delete your personal information. ​

​10.4 Your right to restrict processing 

10.4.1 You have a right to restrict our processing of your personal information, e.g. if you contest the accuracy of your personal data.

10.5 Your right to data portability 

10.5.1 You have a right to receive the personal information provided to us in a structured, commonly used and machine readable format and to transfer these data to another data controller if our processing of the information, for instance, is based on your consent or the processing is carried out by automated means. 

10.6 Your right to object 

10.6.1 You are at any time for reasons concerning your particular situation entitled to object to our processing of your personal data if the processing, for example, is based on legitimate interests or profiling. ​​

​10.6.2 If you object to the processing, we will no longer process your personal information unless we can demonstrate compelling, legitimate reasons for continued processing which precede your interests, rights and freedoms or the processing is necessary to establish, exercise or defend a legal claim. ​

10.6.3 You also have a right not to be the subject of a decision based exclusively on automated processing, including profiling, which has legal effect on you or similarly affects you significantly. 

10.7 Your right to withdraw consent 

10.7.1 You are at any time entitled to withdraw your consent to our processing of your personal information. If you withdraw your consent, you must be aware that we under certain circumstances, for example where we have another legal basis for processing your information are entitled to continue processing, cf. also section 8. We will inform you in such cases. 

10.8 Your right to complain 

10.8.1 You are at any time entitled to file a complaint to the supervisory authority about our processing of your personal information. The supervisory authority is Datatilsynet, Borgergade 28,5, 1300 Copenhagen K, e-mail: dt@datatilsynet.dk. ​

11. Automated decisions, including profiling 

​11.1 Normally, we do not use your personal information with the purpose of making automated decisions. However, we may be obliged hereto according to law, in which case we will inform you about such processing and give you the opportunity to object within reasonable time.  ​

12. Third party websites 

​12.1 Our website includes hyperlinks to, and details of, third party websites. 

12.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties. ​

13. About cookies  

13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

14. Our cookies

14.1 We use our own cookies to make the application work easier for the users. The cookie is only used by our application and not shared with any third party.

14.2 On your first visit to the website, you will be asked to accept that we place one or more cookies on your device. If you do not accept our use of cookies, some of the functionalities of the website will not be available to you. 

14.3 In addition, we use cookies that are strictly necessary for the functionality of the platform and thus do not require your consent. Therefore, we always set cookies that are required for the following features:

15. First party cookies 

15.1 uQualio uses cookies to store user information and to track system usage (app.uqualio.com), and to track website usage (www.uqualio.com).

15.2 The following first party cookies are used and stored on the user’s device:

First party cookies

16. Third party cookies 

16.1 The following third party cookies are used and stored on the user’s device:

Third party cookies

17. Blocking cookies 

17.1 Most browsers allow you to refuse to accept cookies. 

17.2 Blocking all cookies will have a negative impact upon the usability of many websites. 

17.3 If you block cookies, you will not be able to use all the features on our website.

18. Deleting cookies 

18.1 You can delete cookies already stored on your computer.

​18.2 Deleting cookies will have a negative impact on the usability of many websites. 

19. Hosting and data processor agreement  

​19.1 Our website and your personal information is stored with Amazon (AWS) in Germany. 

19.2 AWS, our hosting partner’s privacy policy is available here

19.3 We have a signed agreement with AWS covering data processing and sub data processing. 

20. Our details 

20.1 This website is owned and operated by uQualio ApS. 

20.2 We are registered in Denmark under registration number 39072858, and our registered office is at Egedalsvej 9, DK-3670 Veksoe Sjaelland, Denmark. 

20.3 Our principal place of business is at Egedalsvej 9, DK- 3670 Veksoe Sjaelland, Denmark.

20.4 You can contact us by writing to the business address given above, or by using our website contact form.

September 2020