Privacy Policy & GDPR

WE ARE COMMITTED TO RESPECTING AND PROTECTING YOUR PRIVACY.

This Policy explains what we do with your personal data after we collect it, when and why you will be required to give us your personal information and what we use it for.

We also explain under what conditions we need to disclose your personal information to others and how we keep it secure.

We change this policy from time to time to stay compliant with relevant laws in Europe and to make sure we are on top of our game. We process data in accordance with its responsibilities under the GDPR (see below). By using our website and services you are agreeing to be bound by this policy.

If you have any questions about our policy, please contact us here.

WHAT IS THE GDPR?

The GDPR is a regulation brought into effect for all companies doing business in, or operating from, Europe. The goal is to provide broader protection to personal data. 

Article 5 of the GDPR requires that personal data shall be:

  • Processed lawfully, fairly and in a transparent manner in relation to individuals;

  • Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

  • Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

  • Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

  • Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

  • Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”

WHO ARE WE?

Swivel Skills is a brand of Disrupt Design, a Limited Liability Company registered in New York City. Disrupt Design manages the Swivel Skills Online services.

WHY DO WE COLLECT INFORMATION?

We offer online services for educational programs so we need to collect enough information about you to keep your account secure, make sure we comply with all regulations and to design the best fit programs for your needs.

HOW DO WE PROTECT YOUR PRIVACY AND DATA?

  • We never sell or share your data with other organizations that are not needed to provide you with the services we offer.

  • We will take all measures possible to protect your data from external abuse or access.

  • Individuals have the right to access their personal data and any such requests made shall be dealt with in a timely manner.

  • When we send you communications, such as a newsletter, we will always give you the option to opt out and unsubscribe from the service.

  • You can always request us to delete all your data.  

WHERE DO WE COLLECT INFORMATION?

We only collect information that you agree to give us when you are on our website through our “Contact Us”, sign up and registration forms, along with any applications you or your company completes on your behalf, when you purchase a product or sign up for our newsletter. We also collect information when signing agreements for our services.

HOW IS THIS INFORMATION USED?

We use this information to design and deliver our services, communicate with you regarding our services, process orders, issue certificates and manage your account.

WHAT TYPE OF INFORMATION IS COLLECTED AND HOW?

The general personal information that we collect when you sign up to our online services or purchase a product includes your name, email, phone, address, location and credit card information.

We cannot provide you with our services or communicate with you about the programs you are attending without the requested personal information.

Online classes

When you sign up to our online learning site, we collect the personal information you give us (such as name and email address). We use two third party services provided by Absorb LMS and Thinkific which allows us to create and sell our online products/services. Your data is stored through Absorb and Thinkific’s data storage, databases and programs on a secure server behind a firewall. You can read Absorb’s privacy policy here, and access Thikific’s here.

Email marketing

We may send you emails about our site and related course(s), registration, course content, general information, your course progress or other updates. We use Covertkit as our email communication system, you can read their privacy statement here. 

We may also use your email to inform you about changes to the courses you are enrolled in, survey you about your usage, or collect your opinion.

You can always unsubscribe at the bottom of any email we send you.

HOW DO WE PROCESS PAYMENTS?

We do not store your credit card information, we use a third party service called Stripe, which you can view the privacy information for here. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.

WEB ANALYSIS TOOLS

We may use web analysis tools to measure and collect anonymous session information such as Google Analytics.

WHAT ABOUT THIRD PARTY SERVICES?

In general, the listed third-party providers that we use will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

However, certain third-party service providers, such as some payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. We have listed the ones we use and provided links to their policies in this document.

We recommend you also read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

For example you may be located in Europe but our payment gateway is in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.