Upgrade Education Limited Privacy Policy
Effective Date: 2 February 2023
Upgrade Education Limited and its Affiliates (“Upgrade”, “Thesis Upgrade” “thesisupgrade.com”, “Careers Confidence”, “Doctor Sue Store”, “the Company”, “We”, “Us” or “Our”) take your privacy seriously and your privacy is important to us. We know that you care about how the information we receive from you is collected, used, protected and shared.
This Privacy Policy explains what personal information Upgrade collects from you through our interactions with you and through our products and services, and how we use, protect and share that data. The policy describes Upgrade’s procedures and practices in relation to information that we collect through websites operated by us from which you are accessing this Privacy Policy (collectively, the “Domains”), through the software applications made available by us for use on or through computers and mobile devices that link to this Privacy Policy (the “Apps”), through our social media pages and apps located online, and other products and/or services provided by us, both online and offline; as well as through HTML formatted email messages that we send to you that link to this Privacy Policy (collectively, including the Domains, the Apps and the Social Media Pages, the “Sites”).
“You” or a “user” refers to any individual who visits, accesses or otherwise uses the Sites. By using the Sites, you are accepting and agreeing to the procedures and practices outlined in this Privacy Policy.
This Privacy Policy does not apply to the procedures and practices of third parties that Upgrade does not own or control, or to individuals that Upgrade does not employ or manage.
This Privacy Policy also does not apply to information that we receive or handle on behalf of our subscribers in our role as a service provider, including any apps we make available for use by services subscribers (collectively, the “Services”). Such information is governed by the terms of the applicable services agreement, rather than this Privacy Policy.
What Types of Information Does Upgrade Collect About its Users?
Personal Information: “Personal Information” is information and/or data that identifies you as an individual person or relates to an identifiable individual. This includes your name, title, educational institution, company name, job function, vocational experience, expertise, postal address, telephone number, email address, and/or payment and billing details. If you submit any Personal Information relating to other people to us or to our service providers in connection with the Sites, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Other Information: “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. This might include, for example, browser and device information; App usage data; information collected through cookies, pixel tags, and other technologies; demographic information and other information provided by you; or aggregated information. We use this information to facilitate our operation of the Sites and for other purposes described below.
IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the Sites, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. Upgrade uses IP Addresses to calculate usage levels of the Sites, help diagnose problems with its servers, administer the Sites, and monitor the regions from which you navigate to Upgrade’s Sites.
How Does Upgrade Collect Information?
Personal Information: We and our service providers may collect Personal Information in a variety of ways, including:
Through the Sites: We may collect Personal Information through the Sites, for example, when you create an account with us, purchase a product and/or service, or use an online service, participate in a trial or demo, register for a webinar, contact us, subscribe to our email newsletter, download content (such as electronic publications and digital resources), etc., or register to use our Sites.
Offline: We may collect Personal Information from you offline, such as when you attend one of our events, during phone or virtual calls with our representatives, or when you contact customer service.
Through You: Upgrade may collect information such as your location or your preferred means of communication when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you or any other user of the Sites. Note that there is no legal obligation for you to provide us with Personal Information and any information collected by us will be provided by you at your own will and with your consent.
Information From Other Sources: In order to enhance our ability to provide relevant marketing, offers, and services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.
Other Information: We and our service providers may collect Other Information in a variety of ways, including:
Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Sites (such as the Apps) you are using.
Through Your Use of the Apps: When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Through Cookies and Other Similar Technologies: Cookies, and other similar technologies, may be used to collect Other Information.
Cookies are small data files sent from a server to your web browser. They are stored in your browser’s cache and allow a website, or a third party, to recognise your browser. Cookies store data about your use, but they are helpful because they allow us to help our Sites function and customise your experience. You can configure your desktop, or mobile browser’s settings, to reflect your preference to accept or reject cookies, including how to handle third party cookies.
Upgrade uses Cookie Technologies to recognise your logged-in state on our Sites, to understand what purchases users and visitors are interested in, to make our Sites function for you, and to help your browsing experience and use of the Sites, Services, and Apps feel more customised. We use Cookie Technologies for the following: security and authentication (strictly necessary), account and user preferences, social networks, performance and analytics, and marketing services.
In addition to cookies, there are other similar technologies used by Upgrade and elsewhere on the web or in mobile ecosystems. Examples include web beacons, social widgets, UTM codes, application SDKs, local storage objects, and Internet of Things identifies.
By Aggregating Information: Aggregated Personal Information does not personally identify you or any other user of the Sites (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
How Does Upgrade Use Personal Information?
We may use Personal Information:
To respond to your inquiries and fulfil your requests, such as to send you requested materials, as well as information and newsletters regarding our products and services.
To send administrative information to you, for example, information regarding the Sites and changes to our Terms and Conditions of Use, agreements and policies.
To communicate with you and provide you with related customer service.
To send you marketing communications, including via email and SMS in compliance with applicable laws, which we believe may be of interest to you.
To personalise your experience on the Sites by presenting products, services and offers tailored to you.
To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain extra information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully.
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Sites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions of use and other agreements; (e) to protect our operations or those of any of our Affiliates; (f) to protect our rights, privacy, property, or safety, and/or that of our Affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
How Will Upgrade Share Personal Information It Receives?
Information about our users is an integral part of our business. We only share your Personal Information as described in this Privacy Policy.
Affiliates: We may disclose Personal Information to our Affiliates for the purposes described in this Privacy Policy. Upgrade is the party responsible for the management of the jointly used Personal Information.
Third Party Business Partners: Upgrade partners with a variety of businesses and works closely with them to market and sell products and services. In certain situations, these businesses operate within the Sites. We may disclose Personal Information to our partners for the purposes contained in this Privacy Policy. Some of our third party business partners may co-sponsor events and other offerings with Upgrade. We may share Personal Information with these co-sponsors when you sign up for events or offerings to allow our partners to send you marketing communications and information that may be of interest to you, as permitted under applicable law.
Agents and Service Providers: We contract with other companies and people to perform tasks on our behalf and may share your Personal Information with them to provide products and/or services to you, or to otherwise communicate with you, such as to provide marketing or offers on our behalf. Examples may include removing repetitive information from customer lists, analysing data, providing marketing assistance, conducting billing, processing payments, engaging technical support for our products and/or services, providing customer service, and performing analysis related to our products and/or services. We may also provide your Personal Information to agents and service providers to verify or compile aggregate usage data that we provide to our partners. When we share this information in this way, we seek to require the agent or service provider to maintain the privacy, confidentiality and security of the Personal Information.
Sweepstakes: We may share Personal Information with business partners or other third party sponsors of sweepstakes, contests and similar promotions.
Upgrade Blog and Social Media Pages: Personal Information may also be disclosed by you through the Sites, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our Blogs and Social Media Pages). This information may appear in public ways, such as through search engines or other publicly available platforms, and may be “crawled”, or searched, by third parties. Please do not post any information that you do not want to reveal to the public at large.
Business Transfers: In some cases, we may buy or sell assets or businesses. In these types of transactions, user information is typically one of the business assets that is transferred. Upgrade may disclose Personal Information to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Protection of Upgrade and Others: We may release Personal Information when we believe that release is necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce or apply our terms and conditions of use and other agreements; (e) to protect our operations or those of any of our Affiliates; (f) to allow us to pursue available remedies or limit the damages that we may sustain; and (g) to protect the rights, privacy, property, or safety of Upgrade, our employees, our Affiliates, our users, or any other person or entity. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.
How Does Upgrade Use and Disclose Other Information?
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.
In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we do, we will treat the combined information as Personal Information for as long as it is combined.
How Does Upgrade Secure Personal Information About Me?
We have implemented organisational, technical, physical and administrative measures to protect Personal Information within our organisation, including security controls to prevent unauthorised access to our systems. While we take reasonable steps to secure your Personal Information from loss, misuse, interference and unauthorised access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 per cent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Information online and offline. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your information has been compromised), please immediately notify us in accordance with the Questions, Concerns and Complaints section contained in this Privacy Policy.
How Can I Access and Control My Personal Information?
You have the right to: (a) obtain details about how your Personal Information is processed by Upgrade; (b) obtain copies of Personal Information that we hold on you; (c) have incorrect or incomplete Personal Information corrected; (d) have your Personal Information erased by us, where, for example, we have no legitimate reason for retaining that information; (e) obtain your Personal Information from us and to have that information transmitted to another organisation (data portability); (f) object to the processing of your Personal Information by us in certain circumstances; and (g) not to be subject to (with some exceptions) automated decision making, including profiling.
If you would like to access, correct, amend, remove or limit the use or disclosure of any Personal Information about you that has been collected, used and stored by Upgrade, please notify us at sam@thesisupgrade.com, so that we may respond to your request in accordance with applicable laws.
For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting such access, correction, amendment, removal or limitation.
For How Long Will Upgrade Retain My Personal Information?
Upgrade will not retain your personal information longer than is necessary to fulfil the purposes for which it was collected. However, we may be required by applicable laws and/or regulations to hold your personal information longer than this period.
Can Children Use Upgrade’s Sites?
The Sites are not intended for minors under the age of 18. Upgrade does not knowingly or specifically collect information about minors under the age of 18 and believes that children of any age should get their parents’ or legal guardians’ consent before providing any Personal Information. If you believe that we have mistakenly or unintentionally collected such information, please notify us at sam@thesisupgrade.com, so that we may delete the information from our servers.
Third Party Sites
The Sites may permit you to link to other websites on the Internet through direct links or through applications such as “Share” or “Like” buttons, and other websites likewise may contain links to the Sites. The information practices or content of such other websites is governed by the privacy statements of those websites and not by this Privacy Policy. We encourage you to review the privacy policies found on such other websites, services, and applications to understand how your information may be collected and used.
Similarly, please note that we are not responsible for the collection, use and disclosure policies, procedures and practices (including the data security practices) of other organisations, such as Bluehost, PayPal, Facebook, LinkedIn, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Information you disclose to other organisations through or in connection with the Apps or the Social Media Pages.
Sensitive Information
We request that you not send us or disclose any sensitive Personal Information (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Sites or via other means.
Changes to this Privacy Policy
Upgrade may amend this Privacy Policy from time to time. The “Effective Date” legend at the commencement of this policy indicates when the Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Sites. Your use of the Sites following these changes means that you accept and abide by the revised Privacy Policy.
Compliance
Upgrade complies with the EU General Data Protection Regulation (GDPR) and Irish Data Protection legislation and only collects, uses and shares personal information in strict adherence with those Data Protection laws and principles.
International Transfer of Data
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage third party business partners, and agents and service providers. By using the Sites or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, including Australia, Germany, Ireland, Israel, Japan, Spain, USA and the UK, which may have different data protection rules than those of your country or the country in which you were located when you initially provided the information.
Questions, Concerns and Complaints
Your privacy is important to us. If you have any questions, concerns, or complaints, regarding the way we collect, use, protect and share your personal information, please contact us by email at sam@thesisupgrade.com, or by mail at 30 Delbrook Park, Dundrum, Dublin 16, D16Y2E2, Ireland, ATTN: Data Protection Officer. Because email communications are not always secure, please do not include credit card information or other sensitive information in your emails to us.
Upgrade will take any privacy question, concern, or complaint, seriously and any question, concern, or complaint, will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.