Privacystatement

Click here for the Privacy Statement for the use of e-learning via LTI 1.3

We* understand that you do not want to share your personal and study data with everyone. That is why we handle this information with care. We comply with the General Data Protection Regulation (GDPR). However, we do need your data to support you properly. In this statement, we explain which data we need from you and what we use it for.

Storage of your data

We store the personal data we receive from you or from your employer (with or without a broker). This includes, for example, data we receive when you register for a training, request a brochure, subscribe to a newsletter, or contact us by phone or email.

We collect and store, among other things, the following personal data (where applicable):

• Name, address and place of residence
• Date and place of birth
• Email address
• Phone number
• Communication between you and us
• Online training selection (i.e., events), progress and related training data
• Payment details
• Complaints
• Your Certificate
• Submitted reviews and evaluations
• Profile data built from your cookie profile
• Browser, device, IP and operating system data
• Website visits and click behavior on websites and/or emails

 

Use of your data

We use your personal data for the following purposes:

Registration and administrative handling of your participation in the online training you selected
Legal basis: Contract, Legal obligation, Legitimate interest

For this purpose, we process the following categories of personal data:

• Name, address and place of residence
• Email address
• Phone number
• Payment details
• Communication between you and us

We retain this data to comply with our legal obligations, such as tax retention requirements and the Public Records Act. We keep this data for as long as we are legally required to do so. We also retain the data for our legitimate interests for the period during which we enter into a customer relationship with you or your employer.

Provision of the online training you selected
Legal basis: Contract, Legal obligation, Legitimate interest

This also includes registration, training progress, providing information about trainings, related events, and other training-related purposes.

• Name, address and place of residence
• Email address
• Phone number
• Your Certificate
• Communication between you and us

We retain this data to comply with our legal obligations, such as tax retention requirements. We keep this data at least as long as we are legally required to do so. We also retain the data for our legitimate interests for at least the period during which we enter into a customer relationship with you or your employer.

Carrying out analyses to improve our services (quality research)
Legal basis: Legal obligation, Legitimate interest, Consent

• Name, address and place of residence
• Email address
• Phone number
• Submitted reviews and evaluations
• Profile data built from your cookie profile, such as:
  • Browser, device, IP and operating system data
  • Website visits and click behavior on websites and/or emails

We retain this data under our legal obligations, including the Public Records Act. We retain the data for our legitimate interests for at least the period during which we enter into a customer relationship with you. Otherwise, we retain this data with your consent until you withdraw it.

We perform these analyses as anonymously as possible, or only to comply with our legal obligations. That is why you often do not need to give consent for this processing. If we do this for commercial purposes where we can identify you, we will of course ask for your consent.

Keeping you informed about all our services and products
Legal basis: Legitimate interest, Consent

• Name, address and place of residence
• Email address
• Phone number
• Online training selection (i.e., events), progress and related training data
• Submitted reviews and evaluations
• Profile data built from your cookie profile
• Browser, device, IP and operating system data
• Website visits and click behavior on websites and/or emails

We retain the data for our legitimate interests for at least the period during which we enter into a customer relationship with you. Otherwise, we retain this data with your consent until you withdraw it.

Sending you the documents/information you requested and responding to your questions
Legal basis: Legitimate interest, Contract, Consent

• Name, address and place of residence
• Email address
• Phone number
• Submitted reviews and evaluations
• Profile data built from your cookie profile, such as:
  • Browser, device, IP and operating system data
  • Website visits and click behavior on websites and/or emails

We retain the data for our legitimate interests for at least the period during which we enter into a customer relationship with you. Otherwise, we retain this data with your consent until you withdraw it.

Notifying you of technical issues on the website(s)
Legal basis: Legitimate interest

• Name, address and place of residence
• Email address

If a technical disruption or problem occurs that may have a significant impact on the day-to-day functionality of our services, we will inform you. We do this to protect our legitimate interests for at least the period during which we enter into a customer relationship with you.

Complying with the laws and regulations applicable to us, as prescribed by the (national) government.
Legal basis: Legal obligations

• Name, address and place of residence
• Date and place of birth
• Email address
• Phone number
• Communication between you and fellow students and teachers
• Communication between you and us
• Your Certificate

We retain the data for as long as the legal obligation, as defined for example in tax retention requirements or the Public Records Act, requires us to do so.

Application data as part of your job application or recruitment and selection process
Legal basis: Contract, Consent

• Name, address and place of residence
• Date and place of birth
• Email address
• Phone number
• Your CV and, where necessary, a Certificate of Conduct (VOG)
• Payment details

We retain this data for a job application for a maximum of 4 weeks, or, with your consent, for one year. We may collaborate with our parent company for this purpose.

Sending you, with your consent or within a customer relationship, a newsletter, quality research and/or other commercial messages by email
Legal basis: Legitimate interest, Consent

• Name, address and place of residence
• Email address
• Phone number
• Online training selection (i.e., events), progress and related training data
• Communication between you and us
• Profile data built from your cookie profile
• Browser, device, IP and operating system data
• Website visits and click behavior on websites and/or emails

We process this data with your consent until you withdraw your consent or object to further processing.

Further explanation

We anonymize the personal data we use for analyses. This means you cannot be identified in our analyses.

Sharing with third parties

We may make your personal data available to our accreditation organizations. In order to obtain and maintain accreditation for a training, we are sometimes legally or contractually required to allow committees responsible for accreditation or quality marks to review personal data. We limit this to a minimum.

In some cases, we work with external service providers, such as teachers and exam agencies. They may only use your data to perform services that are in the interest of your training. They may not approach you for other purposes or share your data with other parties.

We sometimes also work with external parties that process your data independently. Your data is then processed in accordance with the privacy statement of those parties. This is the case, for example, with external examinations or certification, and also with some accreditation bodies. We will always inform you when this is the case.

With your consent, we may share your data with third parties for commercial purposes. We do this, among other things, to show you more relevant advertisements and provide you with relevant offers on our websites and those of third parties. We have made or will make appropriate agreements with these parties so that they protect your data properly. You can usually find these parties in the cookie overview.

It may be that government authorities or other parties legally require us to share your data. In that case, we only share the strictly necessary data.

Finally, we may have made agreements with your employer to share certain study results. In this case, it depends on the type of agreements we have made with your employer how your results are shared. This may be, for example, because we act as a processor for your employer, your employer has legitimate interests in viewing certain data, because this has been agreed between you and your employer in a study agreement or employment contract, or because you have given consent. We will always inform you when we will share results with your employer.

The use of cookies

SkillsTown B.V. uses cookies and similar techniques on this website. On our cookie policy page you will find an overview of the cookies used on this website and what they are used for.

Newsletters, communications and our subscriber list

Through our newsletter we inform interested parties by email about news relating to our services and everything connected to them. We only add your email address to our subscriber list if you give consent. Every newsletter contains a link that allows you to unsubscribe and/or adjust your preferences. We may supplement the profile we have built about you through the use of cookies with the email address you enter here. We also track open and click behavior to measure the effectiveness of our newsletter.

Phone number and email address

If you leave your phone number or email address via a form field, we may contact you regarding the interests defined for that form. We can also enrich the personal profile we have built about you through cookies with these contact details. We can measure open and click behavior of the emails we send you. For our legitimate interests, legal obligations, and to enter into an agreement, we may use this data to contact you. If you give consent, we may also use this data to send you commercial messages or to support other commercial purposes as described below.

Online training data

If you have previously completed a training with us, we combine your behavioral data on the website with the trainings you previously completed. This allows us, for example, to ensure we do not offer you the same training again, but instead offer a training that better matches previously completed trainings. We do this on the basis of ‘legitimate interest’.

Commercial consent/Permission

Commercial consent, or permission for the commercial use of your data, is only applied when you have actively provided consent by ticking a box at the bottom of forms. If you shared data with us in the past, before the introduction of the GDPR or the amended Telecommunications Act, we will handle that data under the legal framework applicable at that time. With commercial consent, you give us permission to combine, enrich, use and share your data with third parties, which may or may not be part of our group.

This includes various types of consents, such as the commercial communications described above. By commercial communications we also mean following up with interested parties regarding our services and everything related to them. For this, we use your email address and the profile built about you through cookies. We may use third parties to deliver services for commercial purposes. In doing so, we take your preferences and privacy legislation into account. If you are known to these companies and your ad settings on their platforms allow it, we may show you targeted ads through their channels.

We, or third parties engaged by us, may also contact you for reviews or to request feedback for quality research outside the studies we conduct based on our legitimate interests and legal obligations. For this purpose, we will link your email address to the data already known to us.

Enhanced Conversions measurement

With your consent, we share your email address with Google. We do this by first anonymizing your email address using a hash and only then sending it to Google. This safeguards your privacy and means Google cannot see your email address. The hash is then compared with the hashes of logged-in Google accounts. In this way, we can improve the accuracy of conversion measurements.

SkillsTown Inspire and your data

Inspire is your personalized online learning platform where you can follow online trainings that match your needs and level. Within this environment you can see details about your trainings, such as progress, training offering and your stored profile data. When requesting an individual subscription via the SkillsTown webshop, among other things, your name and address details, email address and phone number are processed.

Security and retention period of your data
We protect your personal data against misuse and access by unauthorized persons using the techniques available at this moment. We retain some personal data for as long as we are legally required to do so, such as payment details and invoices. We retain some personal data with your consent until you withdraw your consent. You can always ask us to delete this data. To provide our services, we retain certain personal data for as long as necessary to perform the agreement. We retain certain personal data because we (or a third party) have an interest in doing so. In the interest of improving our services, we may retain your data for a longer period, but in that case we will always anonymize the data.

reCAPTCHA

We use the reCAPTCHA service of Google Inc. to properly distinguish and detect a genuine website visitor from a spam bot. To make this work smoothly, the IP address of a website visitor, mouse movements, typing patterns and possibly other data are collected. This data is ultimately sent to Google for further analysis. For more information, please refer to Google’s privacy policy.

What privacy rights do you have?

If you have questions or would like to know which personal data about you is being processed, or if you want to exercise one of your rights, you can always contact us.

You have the following rights:

• Right of access: you have the right to access the personal data we process about you.
• Right to rectification: you have the right to have the personal data we process about you corrected or supplemented if it is inaccurate or incomplete.
• Right to object: you can object to the processing of your personal data and to direct marketing.
• Right to erasure: you can request that we delete your personal data.
• Right to withdraw consent: if you have given us consent to process personal data, you can withdraw this consent at any time.
• Right to data portability: if technically possible, you have the right to have the personal data we process about you transferred to a third party.
• Right to restriction of processing: in some cases, you can request that we restrict the processing of your personal data (temporarily or otherwise).

When handling your request, we may ask you to identify yourself. We do this to ensure we provide the personal data to the correct person.

You may always view and/or improve or update your personal data. If you follow an online training with us or purchase one of our products, you can view and adjust the key data in your SkillsTown Inspire account.

If you do not follow an online training with us or have not purchased one of our products, you can access your subscription center via a link in each email to see which personal data we have about you and adjust it if you wish.

You can also ask us to delete your data and stop using it. In some cases, you can indicate that you want us to use your data in a limited way. We can also convert digital data, such as a registration confirmation or study agreement, into a document you can print.

Would you like to carry out one of the above actions? Please contact us by email at securityenprivacy@saltagroup.com. We will respond as soon as possible, but in any case within 4 weeks, to your request. If you want your data to be deleted, we will first check whether this is (already) legally permitted. If we are not (yet) allowed by law to delete your data, we will let you know and indicate the first possible moment at which we will be allowed to delete your data.

Submitting a complaint

If you believe we are not handling questions about your privacy properly, you have the right to submit a complaint to the supervisory authority. This is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

Data Protection Officer

We have appointed a Data Protection Officer. The Officer supervises the application and compliance with privacy legislation. To contact the Data Protection Officer, you can email securityenprivacy@saltagroup.com.

Changes to this Privacy Statement

We may amend this privacy statement. If you want to know how we protect and use your data and for which purposes, we recommend reviewing this privacy statement regularly. This privacy statement was last amended on 14-03-2024.

Use of e-learning

We understand that you do not want to share your personal and study data with everyone. That is why we handle this information with care. We comply with the General Data Protection Regulation (GDPR). However, we do need your data to provide our services properly. In this statement, we explain which data we collect and how we use it.

Storage of your data

We store personal data that we receive from you or your employer (possibly via a broker). This includes data provided when registering for training, requesting a brochure, subscribing to a newsletter, or contacting us by phone or email.

We may collect and store the following personal data (where applicable):

• Name, address and place of residence
• Date and place of birth
• Email address
• Phone number
• Communication between you and us
• Online training selection, progress and related training data
• Payment details
• Complaints
• Certificates
• Submitted reviews and evaluations
• Profile data based on cookies
• Browser, device, IP and operating system data
• Website visits and click behavior

Use of your data

We use your personal data for the following purposes:

Registration and administrative handling of your participation in the online training you selected
Legal basis: Contract, Legal obligation, Legitimate interest

For this purpose, we process the following categories of personal data:

• Name, address and place of residence
• Email address
• Phone number
• Payment details
• Communication between you and us

Data is retained in accordance with legal retention requirements and for the duration of our customer relationship.

Provision of the online training you selected
Legal basis: Contract, Legal obligation, Legitimate interest

This includes registration, progress tracking, and training-related communication.

For this purpose, we process the following categories of personal data:

• Name, address and place of residence
• Email address
• Phone number
• Certificate
• Communication between you and us

Carrying out analyses to improve our services (quality research)
Legal basis: Legal obligation, Legitimate interest, Consent

For this purpose, we process the following categories of personal data:

• Name, address and place of residence
• Email address
• Phone number
• Submitted reviews and evaluations
• Cookie-based profile data and related information, such as:
  • Browser, device, IP and operating system data
  • Website visits and click behavior on websites and/or emails

Where possible, analyses are performed anonymously.

Keeping you informed about all our services and products
Legal basis: Legitimate interest, Consent

For this purpose, we process the following categories of personal data:

• Name, address and place of residence
• Email address
• Phone number
• Online training selection (i.e., events), progress and related training data
• Submitted reviews and evaluations
• Profile data built from your cookie profile
• Browser, device, IP and operating system data
• Website visits and click behavior on websites and/or emails

Sending you the documents/information you requested and responding to your questions
Legal basis: Legitimate interest, Contract, Consent

For this purpose, we process the following categories of personal data:

• Name, address and place of residence
• Email address
• Phone number
• Submitted reviews and evaluations
• Cookie-based profile data and related information, such as:
  • Browser, device, IP and operating system data
  • Website visits and click behavior on websites and/or emails

Notifying you of technical issues on the website(s)
Legal basis: Legitimate interest

• Name, address and place of residence
• Email address

Complying with the laws and regulations applicable to us, as prescribed by the (national) government
Legal basis: Legal obligation

For this purpose, we process the following categories of personal data:

• Name, address and place of residence
• Date and place of birth
• Email address
• Phone number
• Communication between you and fellow students and teachers
• Communication between you and us
• Certificates

Application data as part of your job application or recruitment and selection process
Legal basis: Contract, Consent

For this purpose, we process the following categories of personal data:

• Name, address and place of residence
• Date and place of birth
• Email address
• Phone number
• Your CV and, where necessary, a Certificate of Conduct
• Payment details

Application data is retained for a maximum of 4 weeks, or, with your consent, for one year.

Sending you, with your consent or within a customer relationship, a newsletter, quality research and/or other commercial messages by email
Legal basis: Legitimate interest, Consent

For this purpose, we process the following categories of personal data:

• Name, address and place of residence
• Email address
• Phone number
• Online training selection (i.e., events), progress and related training data
• Communication between you and us
• Profile data built from your cookie profile
• Browser, device, IP and operating system data
• Website visits and click behavior on websites and/or emails

This data is processed with your consent until you withdraw consent or object to further processing.

Additional information

We anonymize personal data used for analysis whenever possible.

Sharing data with third parties

We may share your data with:

• Accreditation bodies
• Trainers and exam institutions
• Certification organizations
• Marketing partners (with consent)
• Authorities (if legally required)
• Employers (based on agreements or consent)

All third parties are required to protect your data.

Use of cookies

SkillsTown B.V. uses cookies and similar technologies. Details can be found in our cookie policy.

Newsletters and subscriptions

We send newsletters only with your consent. Each newsletter contains an unsubscribe link. We monitor open and click behavior to improve our communication.

Phone number and email address

If you provide your contact details, we may contact you regarding your interests and enrich your profile using cookies.

Online training data

We combine website behavior with completed training data to offer relevant recommendations, based on legitimate interest.

Commercial consent

Commercial consent is only applied if you actively provide permission. This allows us to combine, enrich, and share data for marketing purposes.

Enhanced Conversions measurement

With your consent, your email address is hashed and shared with Google to improve conversion measurement accuracy.

SkillsTown Inspire and your data

Inspire is your personalized learning platform. It stores training progress, profiles, and learning data. When purchasing an individual subscription, personal details are processed.

Data security and retention

We protect your data using current security technologies. Data is stored as long as legally required or necessary for service delivery. Some data is retained longer in anonymized form.

reCAPTCHA

We use Google reCAPTCHA to distinguish real users from bots. This includes processing IP addresses and interaction data. See Google’s privacy policy for details.

Your privacy rights

You have the right to:

• Access your data
• Correct your data
• Object to processing
• Request deletion
• Withdraw consent
• Transfer data
• Restrict processing

We may ask for identification when handling requests.

Requests can be sent to:
securityenprivacy@saltagroup.com
We respond within 4 weeks.

Complaints

If you are dissatisfied, you may file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

Data Protection Officer

You may contact our Data Protection Officer at:
securityenprivacy@saltagroup.com

Changes to this Privacy Statement

We may update this statement periodically. We recommend reviewing it regularly.
Last updated: 14-03-2024

E-learning via LTI 1.3

Version 1.0 | 15.12.2025

This statement is intended for employees who access SkillsTown e-learning content via their employer’s Learning Management System (LMS). This privacy statement provides information about how SkillsTown handles your personal data when you use SkillsTown’s e-learning content and how SkillsTown shares such data with your employer.

1. Who is responsible?

Your employer has entered into an agreement with SkillsTown to provide e-learning content within your LMS (i.e., learning platform). SkillsTown processes this data on behalf of your employer. Where SkillsTown processes personal data for its own purposes, SkillsTown acts as the data controller.

2. Personal data we process

When loading e-learning content into the LMS provided by your employer, we may process the following personal data about you:

• Identification and contact details such as first name, last name, (business) email address, UserID (a pseudonym provided by your employer);
• Training progress data such as progress status, (partial) results, certification;
• Scan results aimed at individual knowledge or personality assessments via multiple-choice questions and/or AI simulation interactions;
• Input in AI-driven trainings such as typed text, audio recordings and speech transcripts;
• Diagnostic/interaction data such as IP address, log data, browser information, metadata (incl. reCAPTCHA);
• Feedback data about e-learning trainings such as star ratings and responses in open text fields.

3. Purposes of processing

We process your personal data for the following purposes:

3.1 Facilitating access to SkillsTown e-learning content via an LTI integration
To provide access to the e-learning content, we request your identification and contact details. Depending on how your employer has configured the LMS, we may not need all of these personal data. You can ask your employer which login method is used and which personal data is shared with us.

3.2 Completing the e-learning trainings, including tracking and reporting training progress data
When you participate in an e-learning training, personal data about you is generated, namely:

• Training progress data such as your answers, duration, progress, result and certificate;
• Diagnostic/interaction data such as login times, browser, operating system and IP address.

3.2.1 Offering and integrating supportive (external) content (e.g., video) in line with learning objectives defined by the Employer
When loading e-learning trainings, external content from third parties may form part of the training, such as videos from YouTube and Vimeo. Use of such videos may be necessary to complete the training and is only permitted on the condition that you accept the required cookies to play the video.

3.2.2 Offering trainings where results are shown only to you (scans and AI interaction skills)
For some e-learnings, you may be required to complete a scan to assess knowledge gained from the training. This may take the form of a multiple-choice questionnaire or a simulation with an AI avatar. The results are shown to you and are not reported to your employer.

3.3 Security, incident detection and service continuity
We also use your personal data to maintain and improve the security of our learning platform. Because we provide e-learning content via an LTI integration, it is important that we process certain diagnostic/interaction data to prevent accidental or intentional manipulation, loss, destruction or unauthorized access.

3.4 Collecting feedback and reviews about learning content to gain insight into user experience and satisfaction, for continuous product improvement
Because we always aim to improve our services, we may ask you to leave a review for certain trainings through multiple-choice and open-text questions, and to provide a star rating. Responses are anonymized and cannot be traced back to your identity.

Please note: for open-text questions, you may voluntarily provide more detail on what can be improved. If you include personal data (including special categories of personal data) in your response, we regard this as consent to process the personal data you provide.

4. Legal basis for processing

When processing your personal data, we rely on the following legal bases:

4.1 Performance of the agreement with the employer
When entering into an agreement with your employer, we ensure you have access to the required trainings. Your identification and contact details, training progress data and diagnostic/interaction data are processed for this purpose.

4.2 Consent
Where a training includes a scan with an AI simulation, consent must be obtained before AI is used. Where you leave feedback in open-text fields, we assume consent is given where (special categories of) personal data are included.

4.3 Legitimate interest
We process some of your personal data for our own purposes, such as continuously improving our security posture and optimizing our e-learning content. We make every effort to do this in an anonymized/aggregated manner as much as possible.

5. Retention periods

In general, your personal data is retained for the duration of the contract between your employer and SkillsTown. If you leave your employer while our agreement with your employer is still in place, your employer is responsible for deleting your account and personal data.

After deletion, backups are deleted within a maximum of 30 days. Feedback data, with or without (special categories of) personal data, is deleted after a maximum of 6 months.

6. Cookies and external content

When using external content (e.g., YouTube, Vimeo) and Typeform (for feedback, scans and multiple-choice questions), it is necessary to accept cookies. Without cookie consent, this functionality cannot work properly. This only occurs after you actively provide consent via the cookie banner.

7. Sharing your personal data

Your personal data relating to completing e-learning content is generally stored and processed within the European Economic Area (EEA). Where personal data may be processed (potentially) outside the EEA, we implement appropriate safeguards to ensure that the data is transferred and processed securely. Such transfers are governed by Standard Contractual Clauses (SCCs) and additional security measures.

Where necessary, we share your personal data with the following parties:

• Your employer. We share your training progress with your employer. The outcomes of a scan (including via an AI simulation) and any feedback data after completing a training are not shared with your employer.
• Our service providers. We use external service providers, such as hosting providers that ensure trainings are visible in your LMS. When selecting a service provider, we ensure that the provider is contractually obliged to use your personal data only for the purposes specified by us.
• Third parties required to perform the agreement with your employer or where we have obtained your consent.

8. Your rights

You have the right of access, rectification, erasure, data portability, restriction, objection, and the right to withdraw consent. If you would like to exercise any of these rights, please contact:

• Privacy questions: your internal Privacy department, or securityenprivacy@saltagroup.com
• DPO: your internal Privacy department, or securityenprivacy@saltagroup.com

9. Contact SkillsTown

For technical questions or privacy issues: securityenprivacy@saltagroup.com

10. AI functionalities

For some trainings, you can use AI-driven simulations or chat functionalities to enhance your learning experience and to assess your knowledge while completing a training. Such AI functionalities process only the input you provide yourself (text or audio) and show results only to you. The data is not used for profiling or commercial purposes and is deleted within 6 months after the session, in line with contractual agreements with your employer.

Where a training uses a scan in which AI is included, your consent will be requested before you can continue.

11. Changes

This privacy statement may be updated. Please consult the most up-to-date version regularly. The effective date is stated at the top of this document.