This Privacy Policy aims to ensure that Cursum A/S, Rosenørns Alle 1, 1970 Frederiksberg C, CVR Number: 38247662 (hereafter referred to as “Cursum”) protects customers and their employees’ personal data in accordance with the rules for processing personal data that entered into force on May 25, 2018, as well as the current data protection laws applicable at any time. This policy describes responsibilities, data types and belongings as well as procedures for processing personal data, as outlined by the applicable EU Personal Data Regulation.
In Cursum, a data controller has been appointed to ensures that our personal data policy and implemented procedures are adhered to at all times, just as all Cursum employees are introduced to and taught in Cursum’s data policy and handling of personal data.
By using our services, you agree to Cursum handling your, and possibly, your employees’, personal information in accordance with this data policy.
Any future changes in our data policy will be made available through our website (www.cursum.com) and/or by direct distribution. The data policy was last amended 21 April 2018.
Information we collect about you
Cursum is a 100% digital organization and all person-related data is stored digitally. Therefore, there is no physical archive or any physical material containing personal data.
For the purpose of administration of learning and access to the Learning Center portal, Cursum stores and processes the following types of data for customers and their employees with access to lms.cursum.dk:
- Personal information: e-mail and name as well as possibly by the user’s own consent, education, gender, age, address and telephone number.
- Employment details: employer, division/department, title, workplace address, manager, phone number and employer’s email.
- Courses and performance: enrolled, commenced and completed courses and teaching activities with corresponding scores as well as obtained certificates and refreshments.
How we use this information
We use your data to improve your experience. Our service means that we keep your data inside the Cursum Learning Center unless you ask us or give us your permission to share it, for example, if you ask give us your permission to provide you with content and services through a partner’s platform.
We may use your personal information to:
- Register and maintain your account
- Remind you about activities and guided learning
- Allow you to use certain services or to inform you about changes to content and one or more available services
- Manage accounts and learning progress in accordance with requirements and wishes as part of an employment relationship
- Analyze the traffic on the website, including users’ use as well as demographic location to optimize our services
- Make inquiries if we suspect illegal activities or misuse
Who receives your personal information
We only use your data for internal quality analysis at Cursum and for ongoing documentation to our customers regarding the use of Cursum as part of an employment relationship.
In special cases, we may transfer your personal information to business partners and selected trusted third parties in order to register and maintain your user account and to help us deliver agreed goods and services to you.
Business partners all have confidentiality agreements and are not permitted to use personal data for other purposes. There will always be a relevant data processing agreement to ensure compliance with requirements and obligations in the EU Personal Data Regulation.
How we store your personal information
All data on Cursum’s learning platforms are hosted in Amazon or Azure’s European Data Centers in Ireland or the Netherlands, both of which comply with the requirements of the personal data regulation.
Cookies
The website uses “cookies”, which allows Cursum to see which parts of the website the user’s browser has previously visited. A cookie is a small data file that is sent to your browser from a web server and stored on your computer’s hard drive.
Cookies are used to improve our website, to estimate your traffic and patterns; to keep information about your preferences so that the website can be customized to your individual interests; to make your search faster and to recognize your profile when you visit the website again.
You can set your browser to reject cookies. If you choose not to receive cookies, there may be certain subpages on the website that you cannot access. Our web server sends cookies to your computer every time you log on to our website unless you have set your browser to reject cookies.
For more information, see our cookie policy here.
How we protect your personal information
In accordance with the EU Personal Data Regulation of May 25, 2018, we have taken the necessary technical and organizational security measures against your personal data being accidentally or illegally destroyed, lost or impaired, or disclosed to unknown parties. We store personal information on our own or one of our business partners’ secure servers. The personal information you enter is encrypted before being forwarded to us. If you have received (or have chosen) a password that gives you access to specific subpages on the website, it is your responsibility that the password be kept secret. Therefore, do not share your password with others.
Access to your information and the right to be forgotten
You can always change your account information. You can find out what information we have registered about you. If you wish to receive a copy of this information, please write to us at the address given below. We may charge a small administration fee to cover the cost of sending the registered personal information to you. You may have erroneous information deleted or corrected You can request to have your information deleted:· If you are signed as a Private person you can contact the CLC team on the support form at our website, and request either a data overview or deletion.
- If you access through your employer you should contact your administrator of the Cursum Learning Center and ask questions about which data is stored, ask for a review of the current data stored or ask to be deleted.
In the event that Cursum is used as part of an employment relationship, the personal information may be subject to internal procedures and approvals via primary worker-to-employer inquiry, which is then required to submit an approved request to support Cursum in obligations towards the end user’s ability to execute their rights in accordance with the Personal Data Regulation.
Procedures for disposal
Upon termination of cooperation, Cursum stores all data described in the previous mentioned sections for 6-12 months. This is because customers often recalculate subscriptions within the first half to full year and data therefore has a commercial value for both Cursum and the customer. Upon termination of customer employees, Cursum stores all data described in previous sections for 12 months. This is because customer’s employees (end-users) are often relayed in another or similar position with the customer and therefore they will re-enter Cursum within the first 12 months after reported termination. Cursum keeps track of the certifications that the end user has obtained through a validity period. Data therefore has a commercial value for all parties. Data is systematically reviewed quarterly to check for termination and disposal according to the above. In addition, system-specific measures in the form of automatic erasure procedures have been implemented so that user data is not kept beyond the specified period.
Safety procedures against data breaches
Cursum has conducted and regularly performs systematic analysis and risk assessments. In order to avoid any risks, data exchange is on secure connections and access to personal, sensitive data in Cursum is limited to those employees where processing of data is relevant for the provision of services.
In the event of data breaches or suspicions hereof, Cursum’s data controller will contact the Data Protection Authority within 72 hours. The data controller, on this occasion, announces the following:
- Description of the data breach, how many people are affected and how much data is covered
- Contact information on a data manager in Cursum
- A description of possible consequences of data breakdown
- A description of actions Cursum plans to take to address the violation.
Additional information
If you have questions or comments about our data policy or how we use your personal information, please contact us at:
Cursum A/S, Rosenørns Allé 1, 1970 Frederiksberg C, Denmark
Email: [email protected]
Telephone: +45 70605818
