1. Who we are and what we do
Who we are
We are 微微草视频 Solutions Limited ("微微草视频", "us", "we", "our"). We are a limited company registered in England and Wales under registration number 07938138, a wholly owned subsidiary of 微微草视频 Ltd, and we have our registered office at West Village, Wellington Street, Leeds LS1 4LT. We are registered with the UK supervisory authority, the Information Commissioner's Office ("ICO"), in relation to our processing of Personal Data under registration number ZA193379.
What we do
For the purpose of this privacy notice, we operate The Training Hub, an online learning management system providing e-learning courses and associated training services to organisations and individuals working in and with the adult social care sector. We are committed to protecting the privacy and security of the Personal Data we process about you in connection with The Training Hub.
Controller
Unless we notify you otherwise, we are the controller of the Personal Data we process about you in connection with The Training Hub. This means that we decide what Personal Data to collect and how to process it.
Please note that if you access The Training Hub through your employer's account, your employer is also a data controller in its own right in respect of certain information about your training activity that it can access through the Platform. We explain this further in section 7 below. Your employer is responsible for telling you about its own processing of your personal data.
2. Purpose of this privacy notice
The purpose of this privacy notice is to explain what Personal Data we collect about you in connection with The Training Hub, why we collect it, what we do with it, and how long we keep it. This notice also explains your rights in relation to your Personal Data, so please read it carefully. If you have any questions, you can contact us using the details in section 12 below.
3. Who this privacy notice applies to
This privacy notice applies to you if:
- you access or use The Training Hub Platform as a learner (an "Authorised User"), whether through your employer's account or directly;
- you are appointed by your employer to access learners' progress for The Training Hub;
- you are a billing or administrative contact for an organisation that has entered into a Training Hub Access Agreement with us; and
- you contact us with an enquiry, a complaint, or to exercise a data protection right in connection with The Training Hub.
If you use other 微微草视频 websites, products, or services, our main external Privacy Notice also applies to you in relation to those activities.
4. What Personal Data is
"Personal Data" means any information from which someone can be identified, either directly or indirectly. For example, you can be identified by your name or an online identifier such as your username or IP address.
"Special Category Personal Data" is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health, or data concerning someone's sex life or sexual orientation.
We do not intentionally collect Special Category Personal Data in connection with The Training Hub. Please do not share Special Category Personal Data with us through the Platform.
5. Personal Data we collect
The type of Personal Data we collect about you will depend on your relationship with us and with The Training Hub. For the specific types of Personal Data we collect and the purposes for which we collect them, see the table in section 7 below.
6. How we collect your Personal Data
We collect Personal Data about you:
- directly from you when you register for or use The Training Hub Platform;
- from your employer or their platform administrator, where your employer has purchased access to The Training Hub on your behalf and creates or provides your account details;
- automatically through the Platform as you interact with it, including through cookies and similar technologies (please see our Cookie Policy for further information); and
- from you when you contact us directly, for example by email or telephone, in connection with The Training Hub.
7. Purposes, lawful bases, and retention periods
We will only use your Personal Data when the law allows us to. The table below sets out how and why we process your Personal Data in connection with The Training Hub.
| Category of individual | Categories of Personal Data | Purpose of processing | Lawful basis | Retention period |
|---|
| Authorised Users (learners) |
Name, email address, job title, employing organisation, username, password (encrypted). |
To create and manage your Platform account and to provide you with access to the courses you or your employer have purchased. |
Contract – processing is necessary for the performance of the contract governing your access to the Platform, whether that contract is with you directly or with your employer. |
For the duration of your account, plus 2 years thereafter. |
| Authorised Users (learners) |
Course enrolment records, modules accessed, time spent, assessment attempts and results, completion status, date of completion. |
To deliver your e-learning courses and track your progress through them; to issue Completion Certificates where you successfully complete a course; to make Management Information available to your employer's platform administrator (see below). |
Contract – processing is necessary to deliver the course access and certificates you or your employer have purchased. Legitimate interests – making Management Information available to your employer's platform administrator, which enables employers to manage their workforce training effectively, an activity your employer should notify you of before you begin using the Platform. |
Active data retained for the duration of your account access period, plus 2 years. Completion Certificate records retained for 7 years from the date of issue (see further below). |
| Authorised Users (learners) |
Name, course title, date of completion, certificate reference number. |
To issue and retain a record of your Completion Certificate; to enable verification of completion on your request or with your written authorisation in the future; and to maintain the integrity of The Training Hub certification system. |
Legitimate interests – maintaining a reliable, verifiable record of course completion for the benefit of learners and the integrity of The Training Hub. |
7 years from the date of issue, regardless of whether your account or your employer's agreement with us has ended. |
| Authorised Users (learners) |
IP address, browser type and version, operating system, pages and content accessed, time and duration of visits, error and performance logs. |
To maintain the security, stability, and performance of the Platform; to diagnose and resolve technical issues; to obtain analytical information about how users interact with the Platform and to improve our services. |
Legitimate interests – maintaining a secure, reliable platform for all users and improving the quality of our services and content. |
Up to 12 months. |
| Platform administrators |
Name, job title, email address, telephone number, and records of actions taken through the administrator account. |
To enable administrators to manage Authorised User accounts, assign and remove access, and access Management Information on behalf of their employer. |
Contract – processing is necessary for the performance of the Training Hub Access Agreement with your employer. Legitimate interests – maintaining an audit trail of administrator activity for Platform security and integrity. |
For the duration of your employer's agreement, plus 2 years thereafter. |
| Billing and administrative contacts |
Name, job title, email address, telephone number, and records of commercial correspondence and financial transactions. |
To administer the Training Hub Access Agreement with your employer, including issuing invoices, managing renewals, and corresponding in connection with the agreement. |
Contract – processing is necessary for the performance of the agreement with your employer. Legitimate interests – managing our commercial relationship and keeping records for accounting and legal compliance purposes. |
For the duration of your employer's agreement with us, plus 6 years thereafter (to meet our contractual and statutory record-keeping obligations). |
| All individuals |
Content of enquiries, complaints, or data protection requests, together with contact details provided. |
To respond to your enquiry or complaint, or to action your data protection right request. |
Legitimate interests – responding to queries and maintaining appropriate records of our correspondence. Legal obligation – where processing is required to comply with our obligations under Data Protection Laws. |
Up to 6 years from closure (shorter where appropriate). |
Management Information and access by your employer
All users are provided with individual accounts. Where an organisation has assigned an approved person as a system 'manager', they can access learner management information which includes your course enrolment records, your progress through courses, your assessment results, and your completion status. Your employer is an independent data controller in respect of its own use of that Management Information, and it is responsible for having a lawful basis for doing so and for informing you about it. The E-learning Agreement requires your employer to tell you about this before you begin using the Platform.
微微草视频's role in making Management Information available to your employer is governed by this notice. We do not control what your employer does with Management Information once it accesses it.
Aggregated and anonymised data
We may use aggregated and anonymised data derived from use of the Platform for the purposes of product development, sector research, and service improvement. This processing does not identify you as an individual.
8. Sharing your Personal Data
We may share your Personal Data with:
- your employer's management, where you access The Training Hub through your employer's account, to the extent that Management Information is accessible through the administrator account as described in section 7 above;
- our technology and service providers, including the provider of the learning management system technology on which the Platform runs, our hosting providers, and other third-party suppliers who assist us in operating the Platform and delivering our services. We only share Personal Data with these providers to the extent necessary and require them to process it only on our instructions and in accordance with appropriate data protection agreements;
- regulatory authorities or law enforcement agencies, where we are required to do so by law or by a court order of competent jurisdiction;
- professional advisers, including lawyers and accountants, where necessary for us to obtain advice or to defend or bring legal proceedings; and
- successor organisations, if 微微草视频 sells, transfers, or merges all or part of its business. In that case, we will take appropriate steps to ensure that the privacy of your Personal Data is protected.
We will not sell your Personal Data or share it with third parties for their own marketing purposes.
9. How long we keep your data
We will retain your Personal Data for as long as is necessary for the purposes for which it was collected, including to provide you with access to the Platform, to meet our contractual and legal obligations, and to deal with any complaints or claims.
Specific retention periods are set out in the table in section 7. In particular:
- Completion Certificate records are retained for 7 years from the date of issue, so that we can verify completion at your request or with your written authorisation after your account access period has ended; and
- Management Information relating to your employer's account is retained for the duration of the agreement between us and your employer. Following termination or expiry of that agreement, your employer has 30 days to request an export, after which we may delete or anonymise that data in accordance with our data retention policy.
At the end of the applicable retention period, your Personal Data will be securely deleted or anonymised. You can find out more about our data retention periods by requesting a copy of our Data Retention and Deletion Policy.
10. International transfers
Your Personal Data is primarily processed within the United Kingdom. Where it is necessary to transfer your Personal Data outside the UK, for example because a technology provider we use is based overseas, we will ensure that appropriate safeguards are in place. We do this by ensuring that:
- your Personal Data is only processed in a country in respect of which the Secretary of State has made an adequacy regulation confirming an adequate level of protection; or
- we put in place an International Data Transfer Agreement ("IDTA") with the receiving organisation, together with any supplementary measures that are necessary. A copy of the IDTA template can be found at the .
11. Your rights and how to complain
You have the following rights in relation to the Personal Data we hold about you:
Right to be informed
You have the right to know what Personal Data we collect about you, how we use it, for what purpose and on what lawful basis, who we share it with, and how long we keep it. We use this privacy notice to tell you.
Right of access (Subject Access Request)
You have the right to receive a copy of the Personal Data we hold about you.
Right to rectification
You have the right to have any incomplete or inaccurate Personal Data we hold about you corrected.
Right to erasure (right to be forgotten)
You have the right to ask us to delete your Personal Data in certain circumstances. Please note that we may not be able to delete Completion Certificate records where we have a legitimate interest in retaining them as described in section 9 above.
Right to object to processing
You have the right to object to our processing of your Personal Data where we rely on legitimate interests as our lawful basis. We will consider your objection and cease processing unless we have compelling legitimate grounds that override your interests or unless we need to continue processing for the establishment, exercise, or defence of legal claims.
Right to restrict processing
You have the right to request that we restrict our use of your Personal Data in certain circumstances.
Right to data portability
You have the right to ask us to transfer your Personal Data to you or to another organisation in a structured, commonly used, and machine-readable format, where our processing is based on your consent or the performance of a contract.
Automated decision-making
You have the right not to be subject to a decision based solely on automated processing that has a significant effect on you. We do not make automated decisions of that kind in connection with The Training Hub.
Right to withdraw consent
Where we rely on your consent to process your Personal Data for a specific purpose, you have the right to withdraw that consent at any time. Withdrawing your consent will not affect the lawfulness of any processing carried out before withdrawal.
Right to lodge a complaint
If you are concerned about the way in which we are handling your Personal Data, you have the right to lodge a complaint with the ICO. The ICO can be contacted:
We would welcome the opportunity to address any concerns you have directly before you contact the ICO, so please do get in touch with us first using the details in section 12 below.
How to exercise your rights
You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee, or decline to act, where a request is clearly unfounded or excessive.
Please contact us using the details in section 12 below. We may ask you to provide information to confirm your identity before we can process your request. Once we have confirmed your identity, we will respond without undue delay and within one month. Where a request is particularly complex, it may take up to three months; if so, we will keep you informed.
13. Changes to this privacy notice
We may update this notice from time to time. Where we make a material change, we will notify you by email or by a prominent notice on the Platform before the change takes effect. The date at the top of this notice shows when it was last updated.