Privacy Policy

 

At the Academy, we are committed to respecting and protecting your privacy.

Please read this policy carefully to understand how we collect, use and store your personal data.

The Humanitarian Leadership Academy is a charity registered in England and Wales (1161600) and a company limited by guarantee in England and Wales (9395495) (the “Academy”). Registered office 1 St John’s Lane, London, EC1M 4AR.

Email: kaya@humanitarian.academy

The Academy is the data controller of this platform. The Academy believes strongly in protecting your privacy and the confidentiality of your personal information. We acknowledge that you may have privacy and security concerns with respect to the information we collect, use, and disclose to third parties for the purposes of allowing us to offer and provide our platform, products, and services to you. This Privacy Policy sets out how we will process your personal data. It also explains the types of cookies we use on our website. By continuing to use our website, you consent to the use of those cookies.

Why do we collect and process personal information?

The Academy processes personal information for the legitimate interest of furthering its charitable purpose and fulfilling its mission of enabling people around the world to prepare for and respond to crises in their own countries.

We may use your personal information to:

  • facilitate effective access to the Kaya platform and the learning products hosted on the platform;
  • carry out our obligations arising from any contracts entered into by you and us;
  • seek your views or comments on the services we provide;
  • notify you of changes to our services; and
  • send you communications which you have requested and that may be of interest to you. These may include information about the Academy’s activities and promotion of our other platforms, products, and services.

You agree that any information you provide to us about yourself upon registration or at any time is true. See the Terms and Conditions of Use for more information.

How do we collect your personal information?

Registering on Kaya and registering for courses

When you register on our Kaya platform, you will be asked to provide us with personal and employment information such as name, age (as a range), email address, country location, the organisation you work for and other similar information. We will use this information to allow you to use the Kaya platform, including to register for courses.

If you express interest in, or register for, a course, we will record details related to that course including whether you start and/or complete the course, the scores you achieve in assessments, certificates and badges you earn, your responses to evaluation and feedback surveys, and other information relating to your participation in learning. We will use this information for the management and provision of courses.

As well as the information you provide when registering, you will have the opportunity to provide additional data such as interests, profile picture, or additional contact details through your profile. Contributions made through the site, for example through chat sessions or discussion forums, may be stored on the site (and visible by other users).

The information you submit is available to other branches of the Academy which are based in countries outside of the European Union whose laws may not provide the same level of data protection.

We use this information on the basis of your consent. Please note that you can withdraw that consent at any time in the manner set out below.

Information about use of our website

We also obtain information about how people use our website so we can improve it. This information will identify you individually only where it is necessary to do so. In particular, if you visit our website we may record information about:

  • the areas of the website you visit
  • the amount of time you spend on the site
  • whether you are new to the site, or have visited it before
  • how you came to our website – for example, through an email link or a search engine
  • the type of device and browser you use.

This information is recorded within Kaya. Some of this information may also be recorded by using cookies, which are described in more detail later on in our Privacy Policy.

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you.

Who may have access to your personal information?

We will not sell or rent your information to third parties.

We will not share your information with third parties for marketing purposes

Disclosure of information to third parties: course participation

If you register for the Kaya platform, your chosen name will be visible to all other users of the Kaya platform through the messaging system and any in-course discussions. Only those who are taking the same courses as you will be able to see any additional personal details.

If you access an online course through Kaya that was created by a third party provider, we will share data with that provider in anonymised, aggregated form (e.g. the total number of people who started and/or completed the course over a given time). This anonymised, aggregated data may include aggregate information about the gender, age or location of the people who start and/or complete the course.

If you join an instructor-led training (e.g. face-to-face or webinar) given by a third party organisation, you agree we can provide the third party organisation with basic personal information so that they can provide that course (which may require them to contact you), as well as any additional data you provide when you join that course.

As part of a course given by a third party provider, you may be asked to provide personal information about yourself. If you provide that information, you agree that we can provide that information to the third party provider to provide the course.

If you join a course that is administered by a third party, they will be able to access your personal information and may also be able to access your learning history, as part of the standard reporting provided on who has accessed a course and the progress they have made in it.

If you join Kaya through a third-party organisation’s own branded login page, they will be able to access your personal information and learning history.

Please note that some third party providers are based in countries outside of the European Union whose laws may not provide the same level of data protection.

We disclose this information on the basis of your consent. When joining any course that is administered by a third party, the third party’s involvement will be made clear and you will have the option to continue using Kaya without joining that course. When joining Kaya through an organisation’s branded loging page, it will be made clear that the organisation will have access to your data, and you will have the option to register on Kaya through the standard form instead. Please note that you can withdraw that consent at any time in the manner set out below.

We may also need to disclose your information if required to do so by law, a regulator or in the course of legal proceedings.

Disclosure of information to third parties: site management and analytics

The Academy contracts various third parties to provide site management or data analysis services that help ensure the platform provides a high-quality experience. These third parties are:

eSkillz Ltd (https://www.eskillz.com/), Maryland USA – provision of user support services

HT2 Labs (https://www.ht2labs.com), Oxfordshire, UK – provision of data analysis services

Catalyst IT EU (https://catalyst-eu.net), Brighton UK – hosting, maintenance and development of the Kaya platform.

All the Academy’s third party suppliers are contractually obliged to abide by UK law in the processing and storage of your data, which includes compliance with the General Data Protection Regulation of the European Union.

The Academy also makes use of tracking and analysis tools from Google (http://analytics.google.com) as described below.

Retention of your personal information

We will hold your personal information on our systems for as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with the Academy (including, but not limited to, any Terms and Conditions of Use for a website).

Protection of your personal information

We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as is reasonable and necessary.

Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet is never completely secure. We do our best to protect personal information, but we cannot guarantee the security of information transmitted to our website, so any transmission is at the user’s own risk.

Your credit card information

If you use your credit card to donate to us, buy something or make a booking online, we pass your credit card details securely to our payment processing partner as part of the payment process. We do this in accordance with the Payment Card Industry Security Standard, and don’t store the details on our website.

Sending information by email

Emails aren’t always secure, and they may be intercepted or changed after they have been sent. The Academy does not accept liability for any damage or loss caused or suffered in connection with any such communications. The contents of emails reflect their author’s views and not necessarily those of the Academy.

Please do not send the Academy any confidential information, financial or other sensitive personal data through email.

The information in emails is confidential, so if you’ve received one by mistake, please delete it without copying, using, or telling anyone about its contents.

Your rights and choices

Data protection laws provide you with various rights. In particular, you have a right to:

  • Be removed from our marketing mailing lists, or to change your marketing preferences
  • Request a copy of the information we hold about you, for which we may charge a small fee
  • Ask that we update the information we hold for you, or correct information you think is incorrect or incomplete
  • Ask that we delete the information we hold about you
  • Withdraw consent to our processing of your information (to the extent such processing is based on consent) or otherwise object to our processing of your information

The Company Secretary
Humanitarian Leadership Academy
1 St John's Lane
London
EC1M 4AR

If you are unhappy with the way we have handled your information you have a right to complain to the Information Commissioner. Her website is available at https://ico.org.uk.

18 or under

When you register with us, you are stating that you are over 18 years of age. If you are aged 16 or under‚ please get your parent/guardian's permission beforehand whenever you provide us with personal information.

Other websites

We are not responsible for the privacy of data collected by websites not owned or managed by the Academy, including those linked through our website.

Changes to this privacy policy

We may change this Privacy Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using Kaya, you’re agreeing to be bound by this Policy.

Cookies

What are cookies?

Cookies are small files, typically of letters and numbers, downloaded on to a device when you access certain websites or emails, including the Academy’s website. Cookies allow a website to recognise your device and provide the user with a more tailored experience within the website.

For more information, see: http://www.allaboutcookies.org/

Do we use cookies?

Yes. We use cookies to improve the users’ experience whilst visiting Kaya.

Types of cookies we use

We use strictly necessary, performance, functionality and targeting cookies on our website. We have assessed our cookies based on the International Chamber of Commerce Cookie Guide (http://www.iccwbo.uk/pages/privacy).

Website statistics analytics

We use Google Analytics and Google Tag Manager, as well as other appropriate systems, to understand how people use our website so we can make it more effective. Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google does not receive any personal, identifying information from Kaya. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

In email

Although not through cookies, we do measure the success of the emails we send – so we know what subject lines and stories people liked the most. We receive this information anonymously; we don’t share this information.

Online registration

If you register for a course or purchase any products or services through an Academy website, we will use cookies to remember the items you have selected until you check out and buy them (if applicable). We also use cookies to remember the information you type into our forms, until you finish and submit the form.

Third party cookies

You may notice some cookies that are not related to the Academy whilst visiting https://kayaconnect.org. Some of our pages contain embedded content such as Youtube video, Twitter feed, Facebook likes or Google plus share, and you may receive cookies delivered from these websites. The Academy does not govern the publication of third party cookies. Details of our use of Google Analytics is set out above. To understand more about their cookies and privacy statements, please visit the relevant sites.

If you do not want cookies to be stored on your PC it is possible to disable this function, though this may limit your experience of using the site.

How do I disable cookies?

If you are using Microsoft Internet Explorer and you wish to block the Academy’s website cookies, you can perform the following:

  1. On your browser tools menu, select ‘Internet Options’
  2. Click on the ‘Privacy’ tab and then on the ‘Sites’ button
  3. Type into the ‘Address of website’ field: www.humanitarianleadershipacademy.org
  4. Click on the ‘Block’ button
  5. Click on the OK button
  6. Repeat the process, typing www.kayaconnect.org into the box in step 3.

Other browsers:

  • Firefox cookie management: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
  • Chrome cookie management: https://support.google.com/chrome/answer/95647
  • Safari cookie management: https://support.apple.com/kb/PH19214

Other browsers have similar cookie management abilities in their preferences settings, please refer to your browser’s ‘Help’ facility.

 

 

 

April 2018

 

 

 

Last modified: Monday, 21 May 2018, 5:30 PM