Privacy & Cookie Policy

General

Your privacy is important to Open Study College. We respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Our policy is intended to give you confidence in the privacy and security of the personal information we obtain from you whether you upload information via our website, download it or are simply visiting our website. We cannot, however, be responsible for any use of the personal information you provide to third party websites which may be accessed through our website.

1. Important information and who we are

a. Purpose of this privacy policy

This privacy policy aims to give you information on how Open Study College collects and processes your personal data through your use of this website, including any data you may provide through this website, when you contact us, when you request or agree to receive further information from us, purchase one or more of our products or services or take part in any competition or survey circulated by us.

While we are happy to supply information relating to our courses to minors (i.e. those under 18 years), we do not accept orders for courses and or course materials and similar / ancillary items / products from minors without parent/guardian consent.

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 any other notices issued by us which relate to specific circumstances and / or information and is not intended to override such specific notices.

b. Controller

OSC Ltd trading as Open Study College is the controller and is responsible for your personal data. It is referred to as , “we”, “us” or “our” in this privacy policy.

We have appointed a data privacy manager 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 you legal rights as set out below, please contact the data privacy manager using the details set out below.

c. Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name: Shawna Baker

Email address: info@openstudycollege.com

Postal address: 1760 Solihull Parkway, Birmingham Business Park, Birmingham B37 7YD

d. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 1st July 2024. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

e. Third-party links

This website 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 privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

"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 or which is not associated with or linked to your personal data (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, maiden name, last name, username or similar identifier, marital status, title, date of birth.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your purchases made and/ or orders placed by you and/or on your behalf, username, password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We may 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, 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 (for example, to provide you with products or services that you request). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your direct interactions with us. You may give us your personal data (including Identity, Contact and/or Financial Data) by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • make a purchase and / or place an order with us;
  • request information or marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy included within this document for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below as and when appropriate.

Technical Data from the following parties:

(a) analytics providers such as Google based outside the UK;

(b) advertising networks such as Criteo and whether based inside or outside the UK; and

(c) search information providers such as Algolia and whether based inside or outside the UK.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as First Data, Etika and Sage Page and whether based inside or outside the UK.
• Identity and Contact Data from data brokers or aggregators such as Business Data Prospects and whether based inside or outside the UK.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4. How we use your personal data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Where we need to perform the contract we are about to enter into or have entered into with you, including taking steps at your request before entering into such a contract.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. “Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Where we need to comply with a legal or regulatory obligation, including the prevention of crime. We will identify the relevant legal obligation where we rely on this legal basis.
• Where we have your consent to use your personal data for a specified purpose, for example if you are not an existing customer and you subscribe to receive marketing emails from us.

a. Purposes for which we will use your personal data

We have set out below, a description of all the ways we plan to use your personal data, and which of the above 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 personal 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 below.

• To respond to you when you contact us with an enquiry or to request information (including brochures and other materials). We will use the Identity and Contact Data that you provide when you contact us in order to respond to you.
• To register you as a new customer. We will need to use your Identity and Contact Data to register you as a new customer of Open Study College. This is necessary for performing a contract that we are about to enter or have entered into with you.
• To process and deliver your order. We will use your Identity, Contact, Financial and Transaction Data in order to process and
  deliver our products and services to you, including to: (a) manage payments, fees and charges and (b) collect and recover money owed to us. This is necessary for performing our contract with you and (in respect of debt collection) is in our legitimate interests in recovering sums owed to us.
• To manage our relationship with you. We may use your Identity, Contact, Profile, and Marketing and Communications Data to:
  • notify you about changes to our terms. This is necessary for compliance with our contract with you.
  • notify you about changes to our privacy policy. This is necessary for to comply with a legal obligation.
  • invite you to leave a review or take a survey. This is necessary for our legitimate interests in keeping our records updated, understanding how our customers use our products and services developing our business and informing our marketing strategy.
  • provide you with updates relating to any material changes to course information including (but not limited to)changes to syllabus, examinations and assessments and tutor details. This is necessary for performance of our contract with you.
• To enable you to partake in a prize draw or competition. We may use your Identity, Contact, Profile, Usage and Marketing and Communications Data to process your participation in such activities. This is necessary for the performance of a contract with you.
• To enable you to complete a survey. If you choose to complete a survey that we use for research purposes, we will retain the information that you provide in response to that survey. We may also use your Identity, Contact, Profile, Usage and Marketing and Communications Data to process your participation. This is necessary for our legitimate interests in understanding our customers, developing our business and to inform our marketing strategy.
• Administration. We may use your Identity, Contact and Technical Data for the purpose of administering and protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). This is necessary for our legitimate interests (in running our business, the provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation, sale or group restructuring exercise and for compliance with our legal obligations.
• Website content and advertisements. We may use your
  Identity, Contact, Profile, Usage, Technical and Marketing and Communications Data to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. This is necessary for our
  legitimate interests in understanding our customers and how they use our products and services, developing our business,
  products and services, in growing our business and informing our marketing strategy.
• Website Analytics. As you navigate our website, Technical and
  Usage Data may be collected automatically. We use data analytics to improve our website, products/services, marketing, customer relationships and experience including to find out things such as the number of visitors to the various parts of the website,
  and to help us to improve the content of the website and to customise the content or layout of the website for you, in accordance with our legitimate interests. This is necessary for our legitimate interests in defining types of customers for our
  products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
• Fault reporting. If you contact us to report a fault with our website, we will use the Identity and Contact Data provided for the purposes of rectifying that fault in accordance with our legitimate interests.
• Marketing: We may analyse and use your Identity, Contact,
  Technical, Usage, Profile and Marketing and Communications Data to send you relevant marketing communications, and to make suggestions and recommendations to you about goods or services that may be of interest to you including marketing and sales information / promotions and / or offers. Our lawful basis for such activity is set out below:
  • Where you are an existing customer and you have not opted out of receiving direct marketing, this is necessary for our legitimate interests in carrying out direct marketing, developing our products and services, and growing our business).
  • Where you are not an existing customer, we will only send such
    communications where we have obtained your prior consent to receiving direct marketing communications.
• Third-party marketing. We will never share your personal data with any third party for marketing purposes. If that ever changes, we will get your express opt-in consent before we do so.

b. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to order confirmations, reminders, updates to our terms and conditions, or
checking that your contact details are correct.

c. Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy set out at the end of this privacy policy.

d. 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

Your personal data will only be disclosed to those of our employees or workers that have a need for such access for the purpose for which it was collected. Your personal data will not be disclosed to any other
individuals or other entities except in the following circumstances:

• On occasion, we need to hire other companies to help us to serve you better and in some of these cases we may need to share personal data that is necessary to perform tasks for us, such as:
  • delivery services;
  • third party payment providers;
  • IT, website and system administration services and support;
• Where it is necessary to disclose it to our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to us.
• Where it is necessary for the performance of our contract with you, including where you have asked us to do so or where we need to take steps to enforce any contract which may be entered into between us.
• Other companies which are associated with OSC Ltd (for example, but without limitation) holding companies, subsidiary companies and other companies within the same group of companies where it is necessary to help us provide products/services to you or as may be necessary in the context of a business reorganisation or group
  restructuring exercise.
• Where we are under a legal duty to do so in order to comply with any legal obligation such as provision of information to HM Revenue & Customs, regulators and other authorities based in the United Kingdom.
• In order to protect the rights, property or safety of our business, our employees and workers, customers, suppliers and others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. And/or with who we have commercial co-operation and / or joint venture arrangements (or similar) from time to time. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

At times we may share your personal data with entities outside UK, that carry out certain functions on our behalf. This may involve transferring your data outside the UK to countries which have laws that do not provide the same level of protection of personal data as UK law.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

We have reviewed all our systems and the below are those that process data outside of the UK and their locations:

Service provider | Country where it processes data | Purpose/ description

HubSpot | USA | e-mail/marketing automation

First Data | USA | Payment provider

Ruler Analytics | European Economic Area (EEA) | Reporting and insights

Facebook (Ads) | USA | Advertising

Google Ads | Europe | Advertising

Google Data Studio | Europe | Reporting and insights

Zapier | USA | Digital automation

SAP Litmos | Worldwide | Learning management system

Rakuten | Worldwide | Affiliate platform

Trustpilot | Italy, The Netherlands | Review platform

Algolia | USA, Europe | Search

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

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.

All account information is password protected. Where appropriate we use industry standard Secure Socket Layer (SSL) encryption to protect data transmission. All of our website security is regularly reviewed by our security and abuse team.

We use SSL technology extensively on our all back-office systems which store and / or process customer account information.

We endeavour to make purchasing our products and services as safe as we reasonably can. Your browser will automatically default to secure mode before you enter any personal or payment details. This means that all of your details are encrypted to keep them secure. To check that you are shopping in a safe environment look for the locked padlock or a key icon in the bar at the bottom of your screen or for the relevant icon when the address bar goes green.

We only accept payments which are placed using SSL. We do not store debit or credit card details on our servers once initial payment has been made and processed. All such details are stored securely through Symantec which uses internationally recognised encryption systems. Encryption keys are then held on state-of-the-art tamper-proof systems. 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.

Should you have further concerns about cyber security, please contact our Customer Service Team at info@openstudycollege.com.

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

As a general guide, we retain enquiry information for a period of up to two years from the date of the last enquiry. After that time the information is securely archived. All archived information is kept for a minimum period of six years from the date of receipt.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a minimum of six years after they cease being customers (this is usually once the individual has completed their course) for tax purposes.

In some circumstances you can ask us to delete your data: See section 9, titled "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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

a. Your rights

You have the right to:

• Request access to your personal data (commonly known as a “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 which will be notified to you, if applicable, at the time of 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, 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:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will 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.

If you wish to exercise any of your above rights, please send a written request to us at the address listed in section 1c above.
b. Complaints to the ICO: You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

c. 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.

d. 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.

e. Time limit to respond
We try to respond to all legitimate requests within one 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.

10. Cookies and our Cookie Policy

A “cookie” is a small text file stored on your computer and used by your web browser. They can be used for many different purposes, and on this website some of them are essential to deliver the functionality needed to run this website and to enrol on a course.

Our cookie policy applies to websites operated directly by us.

Any alterations and / or amendments to our cookie policy will be posted on our website. We reserve the right to vary our cookie policy from time to time. Such changes shall become effectively immediately they are posted.

a. Our use of Cookies
We may collect information automatically when you visit our website. Such information is stored in a cookie.

We use the following types of cookies:

• Necessary cookies
  When you browse our website some cookies are required for the site to work correctly. Data is collected via these cookies for audit purposes. This functionality may include remembering which course product you have added to the shopping basket, or which payment plan you have selected as your preferred option.
• Analytical cookies
  These cookies monitor how visitors navigate around our website and how they found it in the first place. We use these cookies to enable us to monitor total (not individual) figures as to which type of content is most popular with users and also to identify problems with the website which may need to be rectified or improved upon. This enables us to provide our users with a better experience of using our site.
  
• Advertising (or ‘targeting’) cookies
  Our courses are advertised on third party websites as well as on social networks.
  We work with third party media partners to achieve this.
  Advertising cookies store information about the user’s computer. They do not store personal information about the individual. They are likely, however to store information about which products have been browsed by your computer.

The specific cookies that we deploy on our website are detailed in the cookie preference tool which is accessible by clicking on the ‘cookie’ icon on our website.

Please note that the following third parties may also use cookies, over which we have no control. The following are the third party services we use with details of how to opt out / control the use of the relevant cookies:
Google

Microsoft Ads/Bing

Facebook

Instagram

TikTok

Pinterest

LinkedIn

Rakuten Advertising

b. Changing Cookie Settings
You have the option not to use cookies at all. However, if you choose this option we cannot guarantee that you experience with our website will be as good as it would have been had you allowed the use of cookies. You can set your preferences via the cookie preference tool which is accessible by clicking on the ‘cookie’ icon on our website.

As a final note, information collected by cookies does not collect information which identifies you personally. It includes general information about your computer settings, your internet connection, IP address, browsing patterns (including timings) and location.

The following links explain how you can control the use of cookies through your browser:
Internet Explorer
Chrome
Safari
Firefox

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.