Summary

Policy for Usage of Learn Computer Online

Full policy

PRIVACY NOTICE

This privacy notice tells you how we, LearnComputerOnline.in powered by Sonali Computer Specials, will collect and use your personal data to provide our service which allows educators, of any kind, to create a private space online, filled with tools that easily create courses and activities, all optimised for collaborative learning.

We have used Moodle software which is free and open source. This notice will tell you how we use your data. We have a Data Protection Officer and you can contact them if you have queries:

1 PERSONAL DATA

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

"any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

WHY DOES OUR APPLICATION ON MOODLE NEED TO COLLECT AND STORE PERSONAL DATA?

We need to collect personal data for correspondence purposes and/or to allow us to provide you our service. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose. "Sonali Computer Specials" is a company which values its user’s data protection and privacy rights and we have no interest in collecting data beyond what we need to make the services work for you. If you are going to be contacted by us for marketing purposes, we will not rely solely on this notice, but will always seek an additional confirmation from you that it’s OK to do that.

WILL SONALI COMPUTER SPECIALS SHARE MY PERSONAL DATA WITH ANYONE ELSE?

We may pass your personal data on to third-party service providers contracted to Moodle Pty Ltd's in the course of dealing with you. We do this because there are some services, such as our video conferencing facility, which will not work unless we are able to make these transfers. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our- and of course, your- behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Moodle Pty Ltd’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, or if it is necessary to comply with an employment contract, unless we are legally required to do otherwise. 

HOW WILL SONALI COMPUTER SPECIALS USE THE PERSONAL DATA IT COLLECTS ABOUT ME?

Sonali Computer Specials will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Sonali Computer Specials maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed. Sonali Computer Specials is required to retain certain information in accordance with the Law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

CAN I FIND OUT THE PERSONAL DATA THAT THE ORGANISATION HOLDS ABOUT ME?

Sonali Computer Specials at your request, can confirm what information we hold about you and how it is processed. If Sonali Computer Specials does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data.
  • Contact details of our data protection officer in the EU, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Sonali Computer Specials or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

WHAT FORMS OF ID WILL I NEED TO PROVIDE IN ORDER TO ACCESS THIS?

Sonali Computer Specials accepts a request made through a login account while the person making the request is logged in. In certain circumstances Sonali Computer Specials could ask for additional information and the following forms of ID when information on your personal data is requested:

  • A colour copy of a Passport, driving licence or National ID Card

2 DATA POLICY

SCOPE

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

RESPONSIBILITIES

All data subjects whose personal data is collected, in line with the requirements of the GDPR.  

3.1 PRIVACY NOTICE

WHO ARE WE?

Sonali Computer Specials is a education firm primarily involved in business of providing computer education to all kinds of students, professionals etc. Sonali Computer Specials has recently started its online computer courses through brand name of "LearnComputerOnline" all optimised for collaborative learning. We have used the platform of Moodle software which is open source learning management system. 

We collect personal data relating to you for specific purposes, with the nature of the data collected depending on your interaction with Sonali Computer Specials. We are committed to transparency in this and have provided a very detailed breakdown of these processes in Annex 1 at the end of this document.

Our legal basis for processing for personal data:

  • Article 6.1(a), GDPR, Consent
  • Article 6.1(b), GDPR, Contract
  • Article 6.1(f), GDPR, Legitimate Interest

Any legitimate interests pursued by us, or third parties we use, are as follows:

  • Recruitment and Induction of new Candidates
  • Emergency Contacts for people who work with us, such as employees and Contractors for Health and Safety purposes.
  • Business Development
  • Providing login systems to users via their existing social media accounts

The special categories of personal data concerned are:

  • Biometric Data in the form of facial images
  • Health Data in respect of employees, Contractors and other people who work with us
  • Any special categories of special personal data which any user volunteers while using the our systems or our website- for example in a forum or submission

3.2 CONSENT

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for Sonali Computer Specials to process both standard and sensitive types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used. Agreement with this Privacy Notice and its accompanying Terms and Conditions (as applicable) (and any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.

You may withdraw consent at any time by:

  • Contacting Sonalicomputerspecials@gmail.com

Please identify your role in relation to Sonali Computer Specials (if you are a Contractor, Staff member, Moodle Partner, End-user, Site Admin etc.), and the data you wish to withdraw consent to be processed.

3.3 DISCLOSURE

Sonali Computer Specials will pass on your personal data to certain third parties. Since we have used Moodle platform for hosting our services and Moodle is a distributed, global company and it uses cloud services which may be accessed by Moodle employees in any part of the world, including their Head Office in Australia.


3.4 RETENTION PERIOD

Sonali Computer Specials will processes different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. For further details on the retention period for any particular type of data, please contact sonalicomputerspecials@gmail.com

3.5 YOUR RIGHTS AS A DATA SUBJECT

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Sonali Computer Specials refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

You should address your requests to the data controllers of our sites. 

3.6 COMPLAINTS

In the event that you wish to make a complaint about how your personal data is being processed by Sonali Computer Specials (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Sonali Computer Specials data protection Officer

The details of Contacts for Sonali Computer Specials's Data Controller:


Supervisory authority contact details

Data Protection Officer (DPO) / GDPR Owner contact details

Contact Name:

Sonali Joshi

Sonali Joshi

Address line 1:

Shop no 5, Om Shreeji Apartment

Shop no 5, Om Shreeji Apartment

Address line 2:

Savarpada

Savarpada

Address line 3:

Borivali (East)

Borivali (East)

Address line 4:

Mumbai, Pin Code - 400066, INDIA

Mumbai, Pin Code - 400066, INDIA

Email:

sonalicomputerspecials@gmail.com

sonalicomputerspecials@gmail.com

Telephone:

+91 9867139946

+91 9867139946 


ANNEX 1

Purpose of processing

Categories of personal data

The source of the personal data

sending e newsletters to Sonali computer Specials users

email address, name

Data subject

sending e newsletters to Sonali computer Specials users

email address, name

Data subject

Attendee registrations and payment for Sonali computer Specials

email address, name, payment details

Data subject

Presentation admission process run by Marketing department of Sonali computer Specials

email address, name, workplace, summary of applicable presentations

Data subject

Communicating marketing campaigns on Facebook

name, email address, location, job title, interests, any other Facebook categories used

Data subject

Communicating marketing campaigns on Twitter

name, email address, location, interests

Data subject

Sonali computer Specials participants information (LearnComputerOnline)

name, email address

Data subject

 

 

 

Recruitment

Name, Address, phone number, email, social media profile links, Photograph, educational and work history, interests

Candidate

Recruitment

Contact details

Candidate

On-boarding

Contact details, emergency contact details, drivers licence, passport, id documents, banking details, tax details, superannuation details, gender, qualifications, biometric data, date of birth

Employees

Health and Safety

Name, phone number, email, relationship with Employee

Employees

HR Records

Health Records

Employees

On-boarding

Contact details, emergency contact details, drivers licence, passport, ID documents, banking details, gender, qualifications, biometric data

Employees

On-boarding

Telephone number

Team Members

Performance

Performance information, contact details

Managers/HR

Engagement

Contact details, job information, engagement information

Employees/HR

Letter of Offer

Name, address, phone number, email and remuneration details

Employees/HR

Confirmation of Information

Contact details, remuneration details, length of service, job information

Employees, HR

Exit interviews

Contact details, feelings about working at Moodle

Employees

On-boarding

Photograph

Employees

Interview

Answers to questions around previous job and skills

Sonali computer Specials HR

 

 

 

Central code repository

contact details (name, surname, email, photo), activity and contribution

Data subject

Community education and feedback (Sonali computer Specials)

contact details (name, surname, email, photo), activity and contribution

Data subject

Mirror of central code repository

contact details (name, surname, email, photo), activity and contribution

Data subject

Developer code repository

contact details (name, surname, email, photo), activity and contribution

Data subject

Developer code repository (Sonali computer Specials dev machines)

contact details (name, surname, email, photo), activity and contribution

Data subject

Sharing of rapid prototypes, research artefacts, usability testing feedback

Contact details, activity, contribution

Employee

Conduct user studies, interviews, and surveys

Contact details, activity, contribution

Employee

Conduct user surveys, Mobile - Support for Airnotifier websites

Contact details, form entries,

Data subject

Scheduler for usability testing & user interviews

Name, email, Contact details, schedules, location data

Data Subject, Employees

Hosts the usability tests and user interview recordings

Contact details, biometric, video, voice recording,

Data Subject, Employees

Community engagement & recruitment for user studies

Contact details, activity, contribution

Data Subject, Employees

Community engagement & recruitment for user studies

contact details (name, surname, email, photo), activity and contribution

 

MOBILE - Training in LearnComputerOnline

contact details (name, surname, email, photo), activity and contribution

Data subject

 

 

 

Paying wages to employees

Contact details (name, surname and email), Bank details, Tax details, sick leave, Annual Leave, salary, pension

Employee

Collecting fees payable by direct clients

Contact details (name, surname and email)

Client

Collecting fees payable by partners

Contact details (name of partner, email, name and surname of partner representative)

Partner

Receiving event registration fee

Contact details (name, surname, email of the participant, phone number, business name and address)

Attendee

Paying supplier invoices

Supplier details (name, surname, email, bank details)

Attendee

 

 

 

Individual's Profile on Sonali computer Specials site

Contact details

Data subject and data subject employer

Individual's data on Sonali computer Specials website

User and activity data

Data subject, Controller

Partner Marketing Support

Partner details, Location, Date, Times

Data subject

Partner Marketing Support

Client details, Partner details

Data subject, data subject employer, Partner organisation

Partnership support conference calls

Name, Voice Recording, Video/Photograph of user

Sonali computer Specials  Partner website Data

Partner Organisation Profile on Partner site

User details, Partner Organisation details

Partner Organisation provides info and manages it

Partnership team commercial discussion about Partners and sectors

HQ Organisation details, Partner Organisation details, names, emails, addresses

Controller(s) - Sonali computer Specials Employees  and for contractors ->themselves or company.

Partnership team discussion

Partner Organisation details

Controller(s) - Sonali computer Specials Employees  and for contractors ->themselves or company.

Sonali Computer Specials team communications

Contact details and any other as comes up in emails

Controller

Sonali computer Specials team communications

Contact details

Controller

Sonali computer Specials Client Customer financial data from Partners

Client details, Partner details

Sonali computer Specials

Sonali computer Specials Client Customer financial data from Partners

Client details, Partner details

Sonali computer Specials

Lead / Customer Information

Contact Details

Data Subject

writing and storage of agreements/contracts/documentation with partners, and potential partners

Contact details

Sonali computer Specials / Applicant

General Business Documentation of meetings including attendees

Partner Organisation details, Partner details, Partner Employees

Controller

General Business Documentation

Partner Organisation details, Partner details

Controller

General Business Documentation

Partner Organisation details, Partner details

Controller

 

 

 

log storing and searching for analysing and troubleshooting Sonali computer Specials Cloud sites and signup/provisioning

Location, IP address

Sonali computer Specials site admins and Sonali computer Specials site users

Storing of historical logs - moodle, web server, statistics

website name, location, IP address

Sonali computer Specials site admins and Sonali computer Specials site users

Facilitating the signup and control of the Sonali computer Specials Cloud account

Name, email, location, telephone number

Sonali computer Specials site admins

Primary provider for text messaging. Logs for text message sending

Phone numbers

Sonali computer Specials site admins

Email processing (Sonali computer Specials and signup)

email

Sonali computer Specials site admins and Sonali computer Specials site users

Backup text messaging service. 

Phone numbers

Sonali computer Specials site admins

News, Updates, Product tip emails subscriber lists (opt in)

Name, email

Sonali computer Specials site admins

Email sent to site admins regarding their Sonali computer Specials Cloud service

Name, email, financial data

Sonali computer Specials site admins

Operational reporting on cloud servers and Sonali computer Specials sites

Location, IP address, moodle activity data

Sonali computer Specials site admin

Recurring subscriptions and Payment

name, email, country

Sonali computer Specials site admins

Billing engine and subscription management

contact details, country, website name

Sonali computer Specials site users

Assignment submission document converter (when students submit assignments in various file formats, this process converts them into PDF file so the teacher can grade and annotate the document)

could be any data submitted in the file

Sonali computer Specials site users

Web Conferencing feature for all Sonali computer Specials sites

contact details, voice, audio, video, biometrics, IP address, location data

Sonali computer Specials site users

 

 

 

Authentication, Design, development and tracking of Sonali computer Specials code, profile published on Tracker site, notifications

Contact details, biometric (avatar)

Data subject

Authentication, profile published, notifications

Contact details, biometric (avatar), any details provided by user

Data subject

Authentication, notifications

Contact details, biometric (avatar)

Data subject

Statistics and error recording

IP Address, error logged messages potentially including usernames, and usage records

Website records

Business Development statistics generation

Data compiled from other listed data sources

Website records

Making and receiving phone calls

Call metadata including phone numbers and time & call duration

telephone records

Making and receiving phone calls

Call metadata

telephone records

Authentication, documents, usage, emails

Names, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage records

Data Subjects, Sonali computer Specials

Communication in and outside of company

Names, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage records

Data Subjects, Sonali computer Specials

Communication in and outside of company

Names, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage records

Data Subjects, Sonali computer Specials

Internal HR functions, leave and communications

HQ personal staff information, leave information, communications details

Data Subjects, Sonali computer Specials

Partner billing, record keeping and communications

HQ authentication information, contact details, Moodle partner contact details, client statistics & invoicing

Data Subjects, Sonali computer Specials

Purchasing various services (domains, etc)

Profile data and credit card for Moodle HQ Staff or Contractor

Data Subjects, Sonali computer Specials

Licenses for software

Personal contact information, cloud stored work may have personal data in it

Data Subjects, Sonali computer Specials

Notifications of critical ICT events

Moodle HQ person information, possible data in alert if relevant to alerting

Data Subjects, Moodle HQ

Authentication, subscribed marketing & security notifications, bounce records, read and open records, link click records

Personal contact information (Name & Email)

Data Subjects, Sonali computer Specials

Billing & Purchasing

Billing information including name, addresses, order information

Data Subjects, Sonali computer Specials

Authentication, document management & office license

Contact Details, IP addresses

Data Subjects, Sonali computer Specials

Hosting corporate infrastructure

HQ Person information, all data covered by other register entries.

Data Subjects, Sonali computer Specials

Legacy ticketing system

Contact details, biometric (avatar), any details provided by user

Data Subjects, Sonali computer Specials

Ticketing System / Public Comms Hub

Contact details, biometric (avatar), any details provided by user

Data Subjects, Sonali computer Specials

CRM for Services team

Contact details, contract details with partners, any other information related to partnership with Moodle HQ

Data Subjects, Sonali computer Specials

Monitoring

No personal data, just system level metrics

Data Subjects, Sonali computer Specials

Authentication, Database/API query derived statistics

Contact details

Data Subjects, Sonali computer Specials

Credential and secure information store

Username and passwords for cloud services, may contain other notes

Data Subjects, Sonali computer Specials

Public site spam prevention

User contributed content (forum posts)

Data Subjects, Sonali computer Specials

DNS and Denial of Service Protection (gradually being phased out)

Website usage and all passed traffic data

Data Subjects, Sonali computer Specials

Voice and Video Meetings

Moodle HQ Employee contact information and recorded video

Data Subjects, Sonali computer Specials

Monitoring sites

Email address & Name for Authentication

Data Subjects, Sonali computer Specials

Virus & Malware scanning for Windows Users

Email address, Name, Scan data from local computer

Data Subjects, Sonali computer Specials

Moodlebot Telegram Bot (Allows Telegram to interact with Tracker and logs conversation in public chat rooms)

Any data listed in Tracker as well as free form chat

Data Subjects, Sonali computer Specials

Sharing created courses with other Sonali computer Specials users or Moodle users worldwide for moodle.net

Profile data for course creators

Data Subjects, Sonali computer Specials

Notification & Contact Forwarding, Analytics for Sonali computer Specials

HQ Staff and Contractor profile information

Data Subjects, Sonali computer Specials

Sonali computer Specials Staging Sites for internal use only

Any non-anonymised data from production instances for testing

Data Subjects, Sonali computer Specials

Test specific features as part of development

Should be no personal data stored, however IP addresses and other data may end up in logs, Moodle will also display IP data in internal logs which is publicly available

Data Subjects, Sonali computer Specials

Demo most recent version of software to the public

Should be no personal data stored, however IP addresses and other data may end up in logs, Moodle will also display IP data in internal logs which is publicly available

Data Subjects, Sonali computer Specials

Statistics and Marketing Tracking

IP addresses and logs, site behaviour analytics

Data Subjects, Sonali computer Specials

Communication about Sonali computer Specials Events

HQ Staff and Contractor profile information

Data Subjects, Sonali computer Specials

Ongoing testing of software

Logins for staff, possible other data as test cases

Data Subjects, Sonali computer Specials

Distribution of software

Source code with names in it and Moodle profiles for HQ Staff and Contractors

Data Subjects, Sonali computer Specials

Language translations for Sonali computer Specials Site

Profile data

Data Subjects, Sonali computer Specials

Sonali computer Specials documentation repository

Profile data

Data Subjects, Sonali computer Specials

Private Sonali computer Specials Code Repository

Profile Data

Data Subjects, Sonali computer Specials

Learning course form Sonali computer Specials

Profile data, course results

Data Subjects, Sonali computer Specials

Public Sonali computer Specials Code Repository

Profile data

Data Subjects, Sonali computer Specials

Storage of documents and other communications

Free form storage of documents, so any personal data is possible

Data Subjects, Sonali computer Specials

Home page for Sonali computer Specials User Association

Profile data

Data Subjects, Sonali computer Specials

Data collection for applications to be part of the Partner Network

Partner applications, Profile data

Data Subjects, Sonali computer Specials

Service status notifications

User logins for HQ Staff

Data Subjects, Sonali computer Specials

User login and other information

Login and other personal profile information

Data Subjects, Sonali computer Specials

Course hosting service

Login and other personal profile information

Data Subjects, Sonali computer Specials

Testing accessibility features in Sonali computer Specials moodle hosting

Login and other personal profile information

Data Subjects, Sonali computer Specials

Collaborative document/code editing

Open system with varied data as well as user IP addresses

Data Subjects, Sonali computer Specials

Register of research related to Sonali computer Specials moodle hosting

Published research documents, login details and profile

Data Subjects, Sonali computer Specials

Hosting applications for Sonali computer Specials Moodle hosting

Login information

Data Subjects, Sonali computer Specials

Legacy Sonali computer Specials moodle hosting sites

Login information

Data Subjects, Sonali computer Specials

Indexing for search purposes

Any data supplied over our sites network

Data Subjects, Sonali computer Specials

Collection and processing of anonymized data from third parties

Anonymized data from other institutions as well as login/profile for Moodle HQ employees and contractors

Data Subjects, Sonali computer Specials

News and information for the Development community

Login and other personal profile information. Details of specific development project participants

Data Subjects, Sonali computer Specials

Communication to Moodle community

Login and other personal profile information

Data Subjects, Sonali computer Specials

Accounts for access to software and licensing

Login and other personal profile information

Data Subjects, Sonali computer Specials