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This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
WHO WE ARE
“GiGsters Academy” is a learning management system on the Site, administered by GIG, which specialises in and offers a series of training, documentation, development and knowledge management courses with the aim of helping its users develop their knowledge and training them to help them reach their full potential within their areas of work. Users of GiGsters Academy (“Users”) access GiGsters Academy by means of a unique combination of a username and password. By gaining access to the service through this combination, Users are allocated access to a portal whereby they are able to attend online courses and training, which may include text documents, video and audio files, images, presentations, amongst others.
PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how GIG collects and processes your personal data through your use of this Site, including any data you may provide through this Site when you register as a user of GiGsters Academy and when you start making use of and interacting within GiGsters Academy.
This Site is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
This Privacy Policy may be updated from time to time, and we will notify you of any changes by posting the new Privacy Policy on the Site and revising the “Effective Date”. We encourage you to review our Privacy Policy whenever you use this Site 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 this Site and cancelling your account(s). You may cancel your GiGsters Academy account at any time by sending an email to knowledge@gig.com, or by otherwise following any instructions that we provide to you for cancelling your account on the portal within GiGsters Academy or otherwise. You are responsible for cancelling your account with GiGsters Academy.
By registering for or using GiGsters Academy and accepting the terms and conditions and the privacy policy you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.
CONTROLLER AND PROCESSOR
This privacy policy is issued on behalf of GIG. GIG is the controller and responsible for this website.
GiGsters Academy is hosted by TalentLMS, which supplies the learning management software on its servers, and which acts as a Data Processor of the data you submit through GiGsters Academy. We encourage you to thoroughly review the TalentLMS Privacy Policy to make sure you are comfortable with the ways in which they process your information
CONTACT DETAILS
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Full name of legal entity: Gaming Innovation Group plc
Email address: dataprotection@gig.com
Address: Data Protection Officer – Legal Department
@ GiGBeach, Triq id-Dragunara, St. Julians, STJ 3148, Malta.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
“Identity Data” includes first name, last name, or similar identifier;
“Contact Data” includes email address;
“Job Information” includes your job position and manager’s name (when you first register as a User on the Site);
“Courses Data” includes details of the courses and training undertaken by a User on the Site, and related progress and results;
“Interaction Data” includes data you submit to the Site or as you participate in any interactive features of the GiGsters Academy, participate in a survey, activity, request customer support, or otherwise communicate with us or within a forum discussion within GiGsters Academy;
“Technical Data” includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this Site.
“Usage Data” includes information about how you use our Site
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, if any, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, if any.
We are committed to keeping your information up to date as far as is reasonably possible. However, if you believe that we have made an error, then please contact us and we will use reasonable endeavours to correct any such errors.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the specific ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
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To enable users to access the online learning service, complete courses, answer questionnaires, access resources, record learning progress and download personalised certificates. |
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Necessary to ensure you are being provided with a fully functional online learning tools to develop your knowledge |
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To track training and courses completion and identify training needs
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Necessary for our and your legitimate interests to better tailor the courses to your needs and derive useful data concerning the interests, characteristics and website use behaviour |
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To assist the Human Resources department of your company to carry out performance reviews with respect to your role within the company |
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Necessary for our and your legitimate interests to monitor your progress in your role with your company and to identify areas you are developing in as well as ones where any assistance may be needed |
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To enable you to enjoy and easily navigate the Site |
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Necessary for our and your legitimate interests to ensure an efficient browsing experience |
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To better understand your needs and interests and thereby to personalise your experience |
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Necessary for your legitimate interest to provide you with the necessary tools to develop your knowledge |
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To fulfil requests you may make |
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Necessary to be able to assist you wherever needed |
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To provide you with further information on new or upcoming courses and course materials, expiry of current courses. |
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Necessary to update you on any courses which may be required for you to complete as part of your role within your company or as otherwise needed to ensure knowledge of applicable laws and regulations |
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To create Aggregated Data that GIG will use for daily reporting and generation of statistics |
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Necessary for our legitimate interests (for running our business) |
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To monitor compliance with applicable laws and regulations |
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Necessary for our legitimate interests (to ensure compliance with laws and regulations) |
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To use data analytics to improve our website |
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Necessary for our legitimate interests (to keep our Site updated and relevant and to develop our business) |
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Site. These cookies may for instance store customisation data related to your usage of the Site.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent the limited situations where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
Your personal data may be shared with third parties on a need to know basis. This may include:
Software companies engaged by GIG from time to time to optimize and facilitate the services supplied through GiGsters Academy;
Parent or subsidiary companies of GIG forming part of Gaming Innovation Group;
Individuals within the Human Resources Team at GIG as well as your Managers for the purpose of carrying out performance reviews;
Any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, sale of assets, or similar transaction in which information is required to be transferred to one or more third parties as part of such transaction.
We transfer your personal data to our service providers or partners outside the European Economic Area (EEA). We shall only transfer your personal data outside the EEA in the event that the respective countries to which such data is to be transferred provide an adequate level of protection for your personal information.
Determining whether an adequate level of protection of your personal data is provided is based on the existence of one of the following:
The European Commission has determined that the respective third country, territory or a specified sector within that third country ensures an adequate level of protection for data transfers;
The service provider or partner to whom your personal data is to be transferred provides appropriate safeguards and data subject rights and adequate legal remedies for data subjects are available. Appropriate safeguards can be provided in various ways including the use of standard contractual clauses approved by the EU Commission. For more information kindly click here.
The service provider or partner to whom your personal data is to be transferred is subscribed to the U.S. Privacy Shield, which requires all such companies subscribed to it to provide adequate protection to personal data that is transferred between EU and US companies.
The software supplier used by GIG, which supplies the Learning Management System software for GiGsters Academy is based in the US. GIG has independently verified that such supplier is subscribed to and bound by the U.S. Privacy Shield. For more information on how our supplier collects and processes personal data kindly click here. For more information on the U.S. Privacy Shield kindly click here.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data (kindly refer to the table above) and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
We shall retain data collected for a period of five (5) years unless we are legally required to retain such data for a longer period of time under any applicable law, in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We shall retain Aggregated Data for an indefinite period of time as, although this stems from personal data, it does not identify you in any way and does not amount to personal data.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons where we need to abide by applicable laws or where otherwise there is a legitimate interest for us not to comply with such request. Otherwise you may ask use to delete all your personal data at any point in time, and at which point we will use our best endeavours to adhere to your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, however, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will use best endeavours to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one (1) month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THIS SITE
These terms and conditions outline the terms and conditions for using the site accessible at https://gigsters-gig.talentlms.com/ (this “Site”), where you can choose to register to use GiGsters Academy and (where applicable) be redirected to GiGsters Academy.
2.1 “GiGsters Academy” is a learning management system on the Site, administered and operated by Gaming Innovation Group plc with company registration number C 44319, and having its registered address at @GIG Beach, Triq id-Dragunara, St. Julians STJ 3148, Malta (“GIG” or “We”).
2.2 GiGsters Academy specialises in and offers a series of training, documentation, development and knowledge management courses with the aim of helping its users develop their knowledge, and training them to help them reach their full learning potential.
2.3 Users of GiGsters Academy (“Users”) access GiGsters Academy by means of a unique combination of a username and password. By gaining access to GiGsters Academy through this combination, Users are allocated access to a portal whereby they are able to attend online courses and training, which may include text documents, video and audio files, images, presentations, amongst others.
To contact us, please email knowledge@gig.com.
3.1 By using the Site and GiGsters Academy, you confirm that you accept these terms and conditions and that you agree to comply with them. If you do not agree to these terms and conditions, please do not use this Site and GiGsters Academy.
3.2 The features, tools and elements of GiGsters Academy are accessible only to Users with an active account; and may be subject to additional policies, terms, conditions and/or agreements that apply in addition to these terms and conditions.
3.3 It is important to read, understand and comply with all our additional policies, terms, conditions and/or agreements as they provide the rules for using the relevant services. Our additional policies and terms (including all policies and terms referenced in them) are incorporated in and form part of this Agreement, and include without limitation, our Privacy Policy, and the LMS Terms of Use and LMS Privacy Policy, as applicable.
4.1 The Site may be accessed and used in a number of ways including, without limitation, by:
general users who browse the Site, without creating an account; and
Users who have created an account in order to use any of the features, tools or elements of GiGsters Academy that are available only to account-holders.
4.2 hen you create an account, you must provide current, complete and accurate information, and you must maintain and promptly update your information so that it is true, accurate, current and complete at all times. GIG shall have no liability to you (or any third party) arising from or in connection with your failure to maintain and update your information, including, but not limited to, any claim, loss or damage from your failure to receive information about GiGsters Academy.
4.3 If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party.
4.4 We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these terms of use. If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us at knowledge@gig.com.
4.5 GIG or any of its parent or subsidiary companies or affiliates of GIG will not be liable for any claim, loss or damage arising as a result of someone else using your password or account, either with or without your knowledge. However, you could be held liable for losses incurred by GIG or any of its parent or subsidiary companies or affiliates of GIG or otherwise a third party due to your conduct or someone else using your account or password.
4.6 We may amend these terms and conditions from time to time. Every time you wish to use the Site and GiGsters Academy, please check these terms and conditions to ensure you understand the terms and conditions that apply at that time.
4.7 We also reserve the right to update and change the Site and/or make changes to the content of or within GiGsters Academy from time to time without prior notification. We will endeavour to give you reasonable notice of any major changes.
4.8 We do not guarantee that the Site and GiGsters Academy, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of the Site and GiGsters Academy for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.
4.9 You are also responsible for ensuring that all persons who access the Site and GiGsters Academy through your internet connection are aware of these terms of use and other applicable policies, and that they comply with them.
5.1 We are the owner or the licensee of all intellectual property rights in the Site and GiGsters Academy, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are resered
5.2 You may print off one copy, and may download extracts, of any page(s) from the Site for your personal use and you may draw the attention of others within your organisation to content posted on the Site and GiGsters Academy.
5.3 You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.
5.4 Our status (and that of any identified contributors) as the authors of content on the Site and GiGsters Academy must always be acknowledged.
5.5 You must not use any part of the content on the Site and GiGsters Academy for commercial purposes without obtaining a licence to do so from us or our licensors, as applicable.
5.6 If you print off, copy or download any part of the Site or GiGsters Academy in breach of these terms and conditions, your right to use the Site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.
6.1 Where permissible, Users may post comments and other content, send communications and submit ideas, questions or other information, provided that the content is not illegal, obscene, threatening, defamatory, invasive of privacy, infringing of intellectual property rights, or otherwise injurious to third parties, and provided that such use and content is compliant with these terms and conditions and any other applicable policy.
6.2 GIG reserves the right (but not the obligation) to remove or edit any content posted by Users. GIG takes no responsibility and assumes no liability for any content posted by you or any third party.
6.3 If you post any content or submit any other material, you grant GIG a non-exclusive, worldwide, royalty-free, irrevocable, transferable and fully sub-licensable right to use, reproduce, modify, adapt, publish, publicly perform, translate, create derivative works from, distribute, and publically display such content or other material throughout the world in any media.
6.4 You grant GIG and its sub-licensees the right to use the name that you submit in connection with such content or other material, if they choose. You acknowledge and agree that you are not entitled to any compensation or reimbursement of any kind from GiG in connection with any use described in this paragraph.
6.5 You represent and warrant that you own or otherwise control all of the rights to the content that you post; that the content is accurate; that use of the content you supply does not breach these terms and conditions and any other applicable policy, and will not cause injury, loss or damage to any person or entity.
6.6 You must indemnify and keep indemnified GIG and for all claims resulting from content you supply, upload or transmit.
This Site or GiGsters Academy may include information and materials uploaded by other users of the Site, including to bulletin boards and chat rooms, as applicable.This information and these materials have not been verified or approved by us. The views expressed by other users on our Site do not represent our views or values.
If you wish to complain about information and materials uploaded by other users please contact us on knowledge@gig.com
8.1 GiGsters Academy, the Site and all content on GiGsters Academy and the Site are provided "as is", “as available” and on a "with all faults" basis, without warranties of any kind either express or implied, and the entire risk as to the quality and performance is with you.
8.2 Without limiting any other provision of these terms and conditions, neither GIG nor any of its parent or subsidiary companies or any affiliates of GIG, makes no representation or warranty about:
any of the services offered through the Site and GiGsters Academy (the “Services”), the results that may be obtained from the use of the Services, or the accuracy, reliability, availability, veracity, timeliness or content of any of such services;
whether the Services will be up-to-date, uninterrupted, timely, secure, error-free or non-misleading, or that defects in the Services will be corrected;
whether the Services or any data, content or material will be backed up or whether business continuity arrangements are in place in respect of the Services;
any third party agreements or any guarantee of business gained by you through GiGsters Academy or through GIG or any of its parent or subsidiary companies or any affiliates of GIG; or
GiGsters Academy or the systems or infrastructure on which the Services are based, being error or malicious code free, secure, confidential or performing at any particular standard or having any particular function.
8.3 To the extent permitted by law, we specifically disclaim any implied warranties of title, merchantability, fitness for a particular purpose, quality, suitability and non-infringement.
8.4 While it is GIG’s intention for the Services to be available as much as possible, there will be occasions when all or part of the Services may be interrupted, including, without limitation, for scheduled maintenance or upgrades, for emergency repairs, or due to failure of telecommunications links and/or equipment.
8.5 You acknowledge and agree that in no event shall GIG or any of its parent or subsidiary companies or any affiliates of GIG be liable in any way, whether in contract, warranty, tort (including negligence), or any other form of liability, for:
You must indemnify and hold harmless, and keep indemnified and continue to hold harmless, GIG and any of its parent or subsidiary companies or any affiliates of GIG, against all claims, loss, actions, proceedings, costs, expenses (including legal fees), claims and damages arising from:
any breach by you of these terms and conditions or other applicable terms, or of any laws, rules, regulations, codes, statutes, ordinances or orders of any government authority or court; or
your breach, or alleged breach, of any third-party right, including without limitation, any intellectual property right, confidentiality, or privacy right; or
reliance by you on any information obtained through the Site or GiGsters Academy, including, without limitation, GiGsters Academy content or any third party content; or
your access to or use of the Site or GiGsters Academy.
This Site or GiGsters Academy may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their terms and conditions and/or privacy policy or otherwise any other applicable policy. When you leave the Site or GiGsters Academy, we encourage you to read the terms and conditions and the privacy policy, and any other applicable terms and conditions and policy of every site you visit.
11.1 Except where expressly provided otherwise in the terms and conditions, you do not have any right, title or interest in or to any proprietary rights relating to the Site, GIG or GiGsters Academy.
11.2 The Site and GiGsters Academy and any other product or service name or slogan or logo contained within the Site and GiGsters Academy are the intellectual property of GIG and its suppliers or licensors, as applicable, and may not be copied, imitated or used, in whole or in part, without the prior written permission of GIG or the applicable trademark holder. Ownership of all such trademarks and the goodwill associated therewith remains with GIG or the applicable trademark holder.
11.3 You may not use any metatags or any other "hidden text" utilizing any name, trademark or product or service name of GIG without GIG’s prior written permission.
11.4 In addition, the look and feel of the Site and GiGsters Academy (including all page headers, custom graphics, button icons and scripts) is the service mark, trademark and/or trade dress of the Site and GiGsters Academy and may not be copied, imitated or used (in whole or in part) without GIG’s prior written permission, as applicable. Reference to any products, services, processes or other information, by trade name, trademark or otherwise does not constitute or imply endorsement, sponsorship or recommendation thereof by GIG.
11.5 Nothing contained on the Site and GiGsters Academy should be construed as being any licence or right of use of any trade mark displayed on the Site and GiGsters Academy.
12.1 You may cancel your GiGsters Academy account at any time by sending an email to knowledge@gig.com, or by otherwise following any instructions that we provide to you for cancelling your account on the portal within GiGsters Academy or otherwise. You are responsible for cancelling your account with GiGsters Academy.
12.2 We may close or suspend your account, or limit your access to GiGsters Academy if:
we determine that you have breached, or are acting in breach of, the terms and conditions or any other applicable policy;
we determine that you have infringed any laws or regulations or the rights of a third party, including infringing someone else's intellectual property rights, or if we determine that you have engaged, or are engaging, in fraudulent, or illegal activities; or
you do not respond to or complete any account verification requests.
12.3 All provisions of these terms and conditions that by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, and limitations of liability.
