Privacy Policy
At the Humanitarian Leadership 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 (the 'Academy') is part of the Save the Children Fund - a charity registered in England and Wales (213890) and Scotland (SC039570), and a registered company limited by guarantee (178159). Registered office 1 St John’s Lane, London, EC1M 4AR.
Email: kaya@humanitarian.academy
The Academy (the Save the Children Fund) 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 platform. By continuing to use our platform, 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 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 your email address, name, age (as a range), gender, 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 enrol onto courses.
If you express interest in, or enrol onto, 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 the 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 platform
We also obtain information about how people use our platform 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 platform 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 platform – 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 name will be visible to other users of the Kaya platform through any in-course discussions. Only those who are taking the same courses as you will be able to see any personal details.
If you access an online course through Kaya that was created by a third party provider, we may 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 your 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, you agree to provide the third party organisation with direct access to your 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.
If you join Kaya through a third party organisations' portal, they will be able to access your personal information and learning history and will also be able to assign specific courses to you for your completion. You can join a portal by either using the third party organisation's branded login page, through the organisation's Single-Sign-On Solution (SSO), or on request to a portal administrator.
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 a course or a portal 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 or portal. 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
Learning Pool (https://learningpool.com/), Derry, 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) and Hotjar (https://www.hotjar.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 for the site).
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 platform, 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 platform.
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
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. The 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 17 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 platform.
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 platform. 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 platform so we can make it more effective. Google Analytics, a web analytics service provided by Google, Inc. (“Google”) uses cookies to analyse how users use the platform. The information generated by the cookie about your use of the platform (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 platform, compiling reports on site activity for site operators and providing other services relating to site 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 platform. By using this platform, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
We also use Hotjar in order to better understand our users’ needs and to optimise this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (eg. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
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 enrol onto 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 Kaya. Some of our pages contain embedded content such as Youtube video, Twitter feed, Facebook likes or LinkedIn 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 platform.
How do I disable cookies?
- 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.