This Privacy Policy informs you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from visitors to Operam.co.uk (“Website”). This Privacy Policy applies only to information that you provide to us through this Website and explains in plain language what we do with that information, how we share it, and how we handle the content you place upon it. It also explains your rights and the choices available to you regarding our use of your personal information and how you can access and update this information. 

 

Our Privacy Policy may be updated from time to time, and we will notify you of any material changes by posting the new Privacy Policy on the Website at the Privacy Policy page and revising the “Effective Date” at the top of this policy. We encourage you to review our Privacy Policy whenever you use the Website to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this Privacy Policy, you will need to stop using the Website. 

 

This Privacy Policy applies to the information that we obtain through your use of the Website via a “Device” or when you otherwise interact with Operam.co.uk. A “Device” is any computer used to access the Website, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device. Website does not include any other own or third-party products or services for which a separate privacy policy is provided. You should always review the policies of third party products and services to make sure you are comfortable with the ways in which they collect and use your information. 

 

By using the Website and accepting the Terms of this Policy you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. 

 

Who we are: 

Operam Limited (“Operam”) provide accessible and affordable learning resources to organizations worldwide.  

 

Operam are based in the United Kingdom at Devonshire Business Centre, Letchworth, Hertfordshire, SG6 1GJ. 

Operam owns, updates and produces content for Operam.co.uk.  

Operam complies with Data Protection Laws, including the European regulation for data protection 2016/679/EU (General Data Protection Regulation – GDPR). Operam will not knowingly do anything or permit anything to be done which might lead to a breach of the Data Protection Laws.  

 

The Personally Identifiable Information We Collect 

Visitors to operam.co.uk: In the course of using this Website, you may provide us with personally identifiable information. This refers to information about you that can be used to contact or identify you, and information on your use of and activities at our Website that may be connected with you (“Personal Information”). Personal Information that we collect may include, but is not limited to, your name, company, location, telephone and email address. When you visit the Website, our servers automatically record information that your browser sends whenever you visit a website. This information may include, but is not limited to, your Internet Protocol address, browser type, and information you search for on our Website. We also use “cookies” to collect information. We store cookies of third-party providers. In particular, Google stores a Google Analytics cookie in order to be able to differentiate between users, their location and time spent on the website.  For visitors to the website we also use the following tracking cookies that are associated with our use of our Customer Relationship Management (CRM) Tool, Hubspot or similar should that CRM be replaced. These cookies fall into two general categories:  

 

  • Essential/necessary cookies: these cookies do not require consent.
  • Consent banner cookies: there are cookies included in the consent banner under GDPR.

 

Specific cookie names and descriptions are listed below, as well as tracking information for the ads tool and cookies from third-party systems:  

 

Essential/necessary cookies 

 

__hs_opt_out 

This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when we give visitors the choice to opt out of cookies.  (Expires: 2 years) 

 

__hs_do_not_track 

This cookie can be set to prevent the tracking code from sending any information to HubSpot. Setting this cookie is different from opting out of cookies, which still allows anonymized information to be sent to HubSpot. (Expires: 2 years) 

 

__hs_testcookie 

This cookie is used to test whether the visitor has support for cookies enabled. (Expires: Session cookie) 

 

hs_ab_test 

This cookie is used to consistently serve visitors the same version of an A/B test page that they’ve seen before. 

(Expires: Session cookie)  

 

<id>_key 

When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login. The cookie name is unique for each password-protected page.   

 

hs-messages-is-open (TTL 30 minutes) 

This cookie is used on the visitor UI side so HubSpot can determine/save whether the chat widget is open for future visits. It resets after 30 minutes to re-close the widget after 30 minutes of inactivity 

 

hs-messages-hide-welcome-message (TTL 1 day)  

When you dismiss the welcome message in your messages tool, a cookie is set to prevent it from appearing again for one day. 

 

Consent banner cookies  

__hstc 

The main cookie for tracking visitors. It contains the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). (Expires: 2 years)  

hubspotutk 

This cookie is used for to keep track of a visitor’s identity. This cookie is passed to HubSpot on form submission and used when de-duplicating contacts. (Expires: 10 years)  

__hssc
This cookie keeps track of sessions. This is used to determine if we should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. (Expires: 30 min)
 

__hssrc 

Whenever HubSpot changes the session cookie, this cookie is also set. We set it to 1 and use it to determine if the visitor has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session. (Expires: None. Session cookie)  

 

messagesUtk 

This cookie is used to recognize visitors who chat with us via the messages tool. If the visitor leaves our site before they’re added as a contact, they will have this cookie associated with their browser. If we have a history of chatting with a visitor and they return to our site later in the same cookied browser, the messages tool will load our conversation history with that visitor.  

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the web sites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Website or all functionality of our services. 

 

In addition there are cookies served through the email services we provide via Mailchimp, or similar. 

 

User email campaigns 

Mailchimp automatically place single pixel gifs, also known as web beacons, in every email sent. These are tiny graphic files that contain unique identifiers that enable Mailchimp and us to recognize when our subscribers have opened an email or clicked certain links. These technologies record each subscribers email address,IP address, date, and time associated with each open and click for a campaign. Mailchimp use this data to create reports for us about how an email campaign performed and what actions subscribers took. 

 

User sites 

Operam may elect to use certain MailChimp add-ons or features, the use of those may permit or require additional cookies or tracking technologies to be employed. If so MailChimp installs a JavaScript tracking snippet (“Snippet”) on that our Website. This Snippet will allow cookies, pixels, and other technologies to be set to facilitate the use of certain automations, features and functionality offered by MailChimp through the Services. The specific cookies, pixels, or other technologies that will be set on a user’s Site depend on the particular add-ons or features that we choose to use as part of the Services. These optional add-ons and features include:
 

Google remarketing ads: Our Google remarketing ads feature (also known as web retargeting ads) allows Operam to create and manage advertisements on the Google Display Network. When Operam use this feature, MailChimp installs a Google tracking pixel on our Website through the Snippet. The Snippet also allows Operam to set a MailChimp cookie that will recognize Site visitors via ads placed with the Google remarketing ads feature. These technologies facilitate the placement of advertising campaigns on the Google Display Network and enable MailChimp to provide reporting about the performance of these advertising campaigns.  

 

Popup forms: The Snippet will allow Operam’s Plaforms to deploy a MailChimp cookie that recognizes whether a visitor has previously viewed a popup form and ensures the same visitor does not see the form again for a period of up to one year.  

 

Landing Pages 

Operam use the MailChimp feature known as “Landing Pages,” the use of that feature will permit additional cookies or tracking technologies to be employed. Operam have the option to set cookies on the device of any visitors to those pages. MailChimp installs the Snippet on the Landing Page to facilitate the deployment of the cookie(s) selected. 

 

Customers: If you are a Customer and no longer wish to receive such emails you can remove yourself from the recipients list at any time by selecting the “unsubscribe” link provided within the e-mail footer. If you are providing information (including Personal Information) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Information. 

 

Content: We collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our “Website”. Such Content includes any Personal Information or other sensitive information that you choose to include (“incidentally-collected Personal Information”). Although Operam owns all rights to the Hosted Service, Customers retain ownership, control and all rights to their records and data which are their property. 

 

Other submissions: We collect other data that you submit to our “Website” or as you participate in any interactive features, participate in a survey, contest, activity or event, request customer support, or otherwise communicate with us. 

 

How We Use, Process and Retain Personal Information 

 

Personal Information is or may be used for the following purposes: 

(a)to provide and improve our Website, services, features and content; 

(b)to administer your use of our Website; 

(c)to enable you to enjoy and easily navigate the Website; 

(d)to better understand your needs and interests; 

(e)to fulfil requests you may make; 

(f)to personalize your experience; and 

(g)to provide or offer software updates and product announcements.  

 

We use information we obtain by technical means (such as the logging performed by our servers or through the use of cookies) for the above purposes and in order to monitor and analyse use of the Website and our services, for the Website’s technical administration, to increase our Website’s functionality and user-friendliness, to better tailor it to your needs, to generate and derive useful data and information concerning the interests, characteristics and Website use behaviour and to verify that visitors to the Website meet the criteria required to process their requests. 

 

We collect and process personal data in a transparent manner, to the extent necessary for specified, explicit and legitimate purposes, and do not process it further in a manner incompatible with those purposes. We take care that the data we collect are accurate and, when necessary, updated. We take all reasonable steps to immediately delete or rectify personal data, if inaccurate. We take the appropriate technical and organizational measures for the security, confidentiality, integrity and availability of the data. We expressly declare that these measures ensure that, by definition, personal data are not made accessible without the intervention of the natural person to an indeterminate number of natural persons. 

 

Information Sharing and Disclosure 

 

Third Parties: We do not sell your Personal Information or Content and will not share or disclose any of your Personal Information or Content with third parties except as described in this policy. We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes). 

 

Service Providers, Business Partners and Others: Operam use third party vendors and providers who supply the necessary hardware, software, networking and storage to run the Website and Hosted Services. These third parties have access to your Personal Information only for purposes of performing these tasks on our behalf. 

 

Compliance with Laws and Law Enforcement: Operam cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process, to protect the property and rights of Operam or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. 

 

Children: Our services are not directed to children. We do not knowingly collect Personal Information from children. If we become aware that a child has provided us with Personal Information, we will take steps to delete such information. If you become aware that a child has provided us with Personal Information, please contact us at the contact information below. 

 

Business Transfers: We may share or transfer your Information (including your Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified on any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information. 

 

Your Rights 

 

Transparency, information and answers to requests: Operam adheres to the principle of transparency in processing. For any question regarding this policy you may contact us at the email provided at the end of this Policy. We will respond without delay and in any case within one month upon receipt of the request. 

 

Access: You have the right to receive from Operam confirmation on whether your personal data are processed and in case this happens all required information thereof (processing means, records etc.). 

 

Rectification: You have the right to require the rectification of inaccurate data relating to you without undue delay, as well as to fill in incomplete data if necessary for processing. 

 

Erasure: You have the right to ask for the erasure of personal data concerning you without undue delay. Operam by means of its designated personnel will erase the data where one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes of processing; or b) the person requesting the erasure withdraws consent on which the processing is based and there is no other legal ground for the processing; or c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing or the data subject objects to processing for direct marketing; or d) the personal data have to be erased for compliance with a legal obligation. Operam will not proceed to the erasure of the personal data if the data must be maintained for compliance with a legal obligation or in cases where the processing is required for the establishment, exercise or defence of legal claims. If you receive marketing emails, you can remove yourself from the recipients list by selecting the “unsubscribe” link within the e-mail. 

 

Restriction of processing: You have the right to request restriction of processing if the accuracy of personal data is disputed, for that period of time that allows Operam to verify the accuracy of personal data, or based on any other legitimate reason specified in applicable Data Protection Laws. 

 

Data Portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format as well as the right to request the direct transmission of personal data by Operam to another, if this is technically feasible. 

 

Right to Object: You may oppose the processing of personal data which takes place without your consent. In this case, Operam no longer submits the personal data unless it demonstrates imperative and legitimate reasons for the processing that outweigh the interests, rights and freedoms of you as a data subject or for the foundation, exercise or support of legal claims. If you receive promotional emails, you can remove yourself from the recipients list by selecting the “unsubscribe” link within the e-mail content. You may also oppose processing at any time by contacting us at the email provided at the end of this Policy. 

 

Complaint to Supervisory Authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes Data Privacy Laws. 

 

Security 

 

Operam is concerned with safeguarding your information. Operam are registered with the Information Commissioner’s Office in the UK (A8396430) and as such we align to data protection through appropriate technical and organizational measures designed to protect your information from unauthorized access. 

 

Data Ownership 

 

Although Operam owns all rights to the Hosted Services, Customers retain ownership, control and all rights to their records and data which are their property. 

 

Contacting Us 

 

If you have any questions about this Privacy Policy, please contact us at Operam Limited, Devonshire Business Centre, Letchworth, SG6 1GJ, UK or email privacy@operamacademy.com