Last Updated: November 1, 2023 (the “Effective Date”)
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural form.
- Account means a unique account created for You to access Our Service or parts of Our Service.
- Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Castle HR Ltd.
- Cookies are small files that are placed on Your computer, mobile Device or any other Device by a website, containing the details of Your browsing history on that website among its many uses.
- Device means any internet-connected electronic accessory that can access Our Service such as a computer, a cellphone or a tablet.
- Personal Data is any information that relates to an identified or identifiable individual.
- Service refers to this Website and its content, including courses.
- Service Provider means any natural or legal person who processes the data on behalf of Castle HR. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Website refers to Castle HR, accessible from www.castle-hr.com.
- You means the individual accessing or using Our Service, or the company, or other legal entity on behalf of which such individual is accessing or using Our Service, as applicable.
Personal Data We Collect
The Personal Data we collect falls into one of three categories:
- Necessary Personal Data refers to any information You are required to submit to Use Our Service.
- Voluntarily Provided Personal Data refers to any information You knowingly and willingly provide us when using our Service.
- Automatically Collected Personal Data refers to any information automatically sent by Your Devices in the course of accessing Our Service.
Personal Data that is Necessary to Use Our Service
The categories of Personal Data described below are necessary to help with Your use of Our Service and for Castle HR to meet Our obligations under Applicable Laws as well as Our contracted obligations to Our clients (i.e., Your employer). As a best practice, We collect the minimum amount of Personal Data that is required to successfully provide Our Service.
- Account Information. When You sign up for an Account, We require certain Personal Data such as Your first name, last name, email address, and employer name. If You are accessing Our Service on behalf of an organization, we may require more information about the organization such as entity name, entity type and size, nature of business/operations, and answers to qualitative questions about Your organization.
- Course Enrollment. When You enroll in Our Workplace Training courses We collect and store Personal Data such as your first and last name, email address, employer name and course progress status. We collect only the information necessary for compliance and verification purposes, and nothing more.
- Payment Transaction Information. We use the services of Rotessa to process, route and deliver funds under Applicable Laws in exchange for Our Services. These payment services, including the charging, processing and delivery of Our fees are ultimately subject to the policies located here: https://rotessa.com/legal/.
Personal Data You Voluntarily Provide to Castle HR
Castle HR collects the Personal Data You choose to provide to Us through your use of Our Service, as described here.
- Communications. When You communicate directly with Castle HR, such as booking a meeting, messaging Us or subscribing to Our marketing list through Our Website, We collect and store Personal Data from such communications, as provided by You.
Personal Data Generated from Your Use of Our Service
Like most Websites, We use technologies, such as Cookies and web beacons, to collect information about the pages You view, the links You click and other actions You take while using Our Service.
When We send emails through Our email distributor, such as newsletter or marketing emails, We are able to monitor certain activities such as how many emails were viewed, by whom, and which links You clicked on. These insights help Us improve Our content and ensure We are sending You valuable content. We do not share this information with anyone else.
Castle HR may automatically collect information relating to Your access and usage of Our Service, as further described here.
- Usage Information. Castle HR collects information about Your interactions with Our Service, such as the links, pages, and content You view and click on, as well as how long You spend on a particular page. Other information We collect may include Your Device type, operating system, browser type, IP address, MAC address, and the website or application from which You navigated to Our Service.
- Geo-location Information. Castle HR collects information about Your precise or approximate location as determined through data such as Your IP address or Your mobile Device’s GPS. Most mobile Devices let You control or disable the use of location services for applications in the Device’s settings menu. Most modern browsers will ask if You agree to share your location information with Our Website, and You may choose not to.
- Log Data and Device Information. We automatically collect log data and Device information when You access and use Our Service, even if You have not created an Account. That information includes, among other things: details about how You’ve used Our Service (including if You clicked on links to third-party applications), Your IP address, access dates and times, hardware and software information, Device information, Device event information, unique identifiers, crash data, Cookie data, and the pages You’ve viewed or engaged with before or after using the Castle HR Website.
Personal Data Received from Third Parties
Castle HR may receive Personal Data about You from third parties and combine that information with information We collect from Your use of Our Service. We are not responsible for how these third parties collect, control, manage, process, disclose or share Your Personal Data, and any request or query regarding any such management or disclosure of Your Personal Data should be directed to such third parties.
Personal Data received from third parties may include, but is not limited to:
- Third-party Services. If You create, connect, or login to Your Account with a third-party service (Google, Facebook, etc.), the third-party Service Provider may send us information such as Your registration and profile information from that service. This information varies and is controlled by that Service Provider or as allowed by You via Your privacy settings with that Service Provider.
- Employer Records. To the extent permitted by Applicable Laws, we may obtain records related to Your employment from Your Employer. This may include Your employment contract, previous performance review notes, disciplinary notices, training logs and anything else directly related to Your ongoing employment with Your employer.
- Referrals. Referring persons may submit Personal Data about You such as Your email address or other contact information.
Use of Your Personal Data
Castle HR may use Your Personal Data for the following purposes:
- To provide and maintain Our Service, including to monitor the usage of Our Service.
- To manage Your Account: to manage Your registration as a user of Our Service. The Personal Data You provide can give You access to different functionalities of Our Service that are available to You as a registered user.
- For the performance of a contract: the development, compliance and delivery of courses available to You through Our Service.
- To contact You: To contact You by email, telephone call, or SMS regarding updates or informative communications related to the functionalities, products or contracted services when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or previously inquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us related to business inquires or issues with Our Service.
- To enable internal business analytics: Such as tracking the source of marketing inquiries or an individual’s progress in each Castle HR workplace training course.
We may share Your Personal Data for the following purposes:
- With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyze the use of Our Service or to contact You.
- For business transfers: We may share or transfer Your Personal Data 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.
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With Your employer: We may share information related to Your engagement with Our Service back to Your employer.
Retention of Your Personal Data
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. Where feasible, Usage data will be anonymized (i.e., all personally identifiable information removed) and aggregated for the purposes of analyzing long-term trends and patterns.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at Castle HR’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.
Where permissible under Applicable Laws We may use certain limited Personal Data about You, such as Your email address, to hash it and to share it with digital platforms, such as Facebook or Google, to generate leads, drive traffic to Our Service or otherwise promote our Service. These processing activities are based on Our legitimate interest in undertaking marketing activities to offer You products or services that may appeal to You.
The digital platforms with which we share Your Personal Data are not controlled or supervised by Us. Questions about how each digital platform Service Provider processes Your Personal Data should be directed to those providers.
Your Choices and Rights
Limiting Information Collected and Opting-out
You have choices regarding Your Personal Data:
- You can choose not to use Our Service;
- You can limit the information You provide to Us;
- You can choose not to participate in Our promotions;
- You can limit the communications that We send to You; and
- You can opt out of marketing emails by clicking the “unsubscribe” link at the bottom of any marketing email We send You or by changing the notification settings in Your Account.
You may exercise the rights described in this section by emailing firstname.lastname@example.org.
Managing your Information
You are responsible for keeping Your Personal Data up to date. You can access and update some of Your Personal Data through Your Account settings. You may ask Us to correct inaccurate or incomplete Personal Data about You (and which You cannot update Yourself within the Account).
Data Access and Portability
You may request copies of Your Personal Data held by Us. You may also request copies of the Personal Data You have provided to us in a structured, common, and machine-readable format or request us to send this information to another Service Provider (where technically feasible).
You can request the removal of all Personal Data that We have on file for You. You may update, amend, or delete Your information at any time by signing into Your Account, if You have one, and visiting the Account settings section that allows You to manage Your Personal Data. You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us.
If You request the erasure of Your Personal Data:
- We may keep some of Your Personal Data for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if We suspend an Account for fraud or safety reasons, We may keep certain information from that Account to prevent a User from opening a new Account again;
- We may keep and use Your Personal Information as needed to comply with Our data retention obligations under Applicable Laws or contractual agreements. For example, Castle HR may keep certain records as required for tax purposes, legal reporting, audits, and the continued delivery of Our Service obligations to Your employer.
- Residual copies of Your Personal Information may not be removed from Our backup systems for a limited time span after Your request has been processed.
Security of Your Personal Data
The security of Your Personal Data is important to Us, but You should know that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use all commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised based on actual or suspected unauthorized use of Your Account, please contact Us by email.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We will remove that information from Our systems.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.