We collect personal information about you in the following ways:

01. Information you provide voluntarily

You may choose to provide us with personal information when you use our Website or Services.  The types of personal information you may provide voluntarily include:

• Identity data: This refers to the personal information you provide to create or maintain an account with Rocket Learning Rewards, such as your email address. As part of the Rewards Program, we will also require Learner ID or pseudonymous identifiers.

• Learning activity data: This is not personal information about you, but information received from the LMS, such as: Course completions, module access, time spent and assessment completion or scores (where customers request)

• Points and reward-related metadata: This is also not considered personal information, but rather information about your use of the rewards program, such as the number of points earned and rewards redeemed.

02. Information we collect automatically

When you visit our Website or use our Services, we may collect some personal information automatically.  The types of personal information we collect automatically may include:

• Device data: This is personal information relating to visits to our Website and our Services from your computer or other device (e.g. mobile devices), such as your IP address, approximate geographical location (e.g. country / city-level), browser type, internet service provider, and resources viewed (e.g. Website pages), operating system, length of visit and referring website addresses.

We may collect this personal information using cookies (and similar technologies).  For more information about our cookies (and similar technologies), please see our Cookie Statement [link].  [If you wish to change your cookie preferences, you can access our cookie management tool here [link].]

03. Information we collect from third party sources

In some cases, we may collect personal information about you from third party sources, including business partners, event organisers, and professional networking sites.  In general, the personal information we collect from these third parties will be identity data (i.e. as described above under the sub-heading “Information you provide voluntarily”)

We use the personal information we collect about you for the following reasons:

• To provide the Website and the Services to you: We will use your personal information to provide our Website and the Services to you, including maintaining any account you have with us.

• To generate analytics: We will use your personal information to develop analytics that provide a better understanding of how our visitors and customers use our Website and services, allowing us to improve our offerings continually.

• To send Service or support-related communications: We will use your personal information to send Service or support-related communications around your rewards card, as well as to respond to any customer inquiries you raise. 

• To maintain security.  We may use your personal information to maintain the security of our Website and Services (for example, to detect and prevent fraudulent behaviour, violations of our terms of service, or similar). 

• To comply with legal requirements.  We will use your personal information to comply with the laws and regulations to which we are subject (for example, legal requirements to report to tax authorities, disclose information to law enforcement authorities, or similar).

We may disclose your personal information to the following categories of recipients:

• To our service providers: We may share your personal information with service providers who provide services related to the delivery of the Website and the Services (e.g., hosting providers, marketing providers, payment providers, IT providers, delivery partners, insurers, and professional advisers). Our primary service providers include:

AWS  provide hosting and secure data storage

Tillo assists with the distribution of digital gift cards distribution

Mixpanel provides analytics and actionable insights on the rewards program

• To our affiliated companies: We may share your personal information with other Rocket Learning Rewards group companies where necessary for the purposes described above. Rocket Learning Rewards group companies will always protect your personal information by this Privacy Notice.

• To competent authorities: We may use and disclose your personal information when we believe it is necessary to exercise, establish, or defend legal claims, to protect the vital interests of any person, or to comply with an order or request from any competent court, regulator, law enforcement agency, or government authority.

• To a potential buyer: We may disclose your personal information to a potential buyer (and its agents and advisors) in connection with any proposed sale of all or part of our business. We will inform the buyer that they should use your personal information only for the purposes outlined in this Privacy Notice.

• To any other third party: We will only transfer your personal information to other third parties with your consent or where we are required [or permitted] by law to do so. 

Rocket Learning Rewards is based in Ireland, but our service providers operate in multiple countries worldwide.  For these reasons, when you visit our Website or use our Services, your personal information may be transferred to countries other than the country in which you reside.  Rocket Learning Rewards will take all necessary measures to ensure that your personal information is protected in accordance with this Privacy Notice and that any such transfers are lawful. 

Some countries may have specific requirements that apply when we transfer personal information internationally.  Where this is the case, the requirements that apply and measures we take to comply with those requirements (where applicable) are described further under the relevant “Additional information for individuals in the EEA/UK and Switzerland.

We use cookies to provide our Website and Services.  For more information, please see our Cookie Statement.

You can review, change or withdraw your consent at any time by clicking the cookie icon in the bottom-left corner of the screen.

Data protection laws grant individuals rights regarding the collection and use of their personal information.  Depending on the laws that apply in your country and to which we are subject, these may include the ability for you:

• to request access to, correction of, deletion of, or portability of personal information that we process about you,

• to request that we restrict processing, or to object to our processing, of personal information about you,

• to opt-out of marketing communications that we may send you (even if you previously consented to receive these) – for example, by clicking on the unsubscribe link in any marketing emails we send,

• to not be subject to wholly automated decisions if these have legal effects on you or similarly significantly affect you, and

• if our processing is based on your consent, to withdraw your consent to our processing (although this will not affect the lawfulness of our processing prior to your withdrawal).

Please contact us using the details provided in this Privacy Notice if you wish to exercise any of these rights.  We will fulfil any such requests in accordance with applicable data protection laws. 

In addition, you also have the right to complain to your local data protection authority about our use of your personal information.  However, while you are not required to do so, we ask that you contact us first to give us the opportunity to address your concerns directly before speaking with your data protection authority.

We store the personal information we collect for as long as is necessary for the purpose for which it was collected (for example, as long as required to provide you with the Website or the Services) or as otherwise necessary to comply with applicable legal requirements.

When we have no ongoing need to use your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information is stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

Neither our Website nor our Services are intended for or advertised to children under 16. We do not knowingly or intentionally collect information about children under 16. 

If you believe that we have collected information about a child under 16, please contact us using the details provided above so that we may delete the information.

We may update this Privacy Notice from time to time in response to changes in legal, regulatory, or operational requirements.  We will provide notice of any such changes (including when they will take effect) in accordance with the law.

To see when this Privacy Notice was last updated, please see the "Last Updated" section at the outset of this Privacy Notice.

If you are in the European Economic Area (“EEA”) or the UK, then please note the following additional information:

01. Data controller

The data controller of your personal information is Rocket Learning Rewards.  You can contact Rocket Learning Rewards using the details provided above.

02. EEA/UK legal basis

We will ordinarily collect and use your personal information only where (i) we have your consent (which will be apparent from the context, because we will ask for you consent when you provide your personal information); (ii) it is necessary to perform a contract with you (for example, we must process your payments data in order to fulfil any order you place with us), in which case we will be unable to fulfil our contract with you if you do not provide necessary information; (iii) the use is within our legitimate interests and not adverse to your rights and freedoms (for example, to send you marketing communications, provided this is consistent with your communications preferences); or (iv) it is necessary for compliance with a legal obligation. 

As we may rely on different legal bases for each of the different categories of personal information we process and the purposes for which we process them, please contact us if you would like further information about the specific legal basis relied upon in any particular context.

03. International transfers

If Rocket Learning Rewards transfers your personal information to a country outside of the EEA (for EEA residents) or the UK (for UK residents), it will ensure that any such transfers are compliant with EU and UK data protection law, as applicable. 

In practice, this means that Rocket Learning Rewards will only transfer your personal information to a non-EEA or non-UK recipient where: (i) the recipient is located in a country that the European Commission has decided is adequate to receive personal information from the EEA or the UK Secretary of State has decided is adequate to receive personal information from the UK (as applicable); (ii) the recipient has signed appropriate contractual terms with Rocket Learning Rewards that incorporate the European Commission’s Standard Contractual Clauses or the UK Information Commissioner’s International Data Transfer Agreement or International Data Transfer Addendum (as applicable); or (iii) a data transfer derogation applies (for example, where you have consented to the transfer of your personal information).