This Privacy Notice sets out the basis on which Focus on Force / K2 Partnering Solutions Pty Ltd. will process personal information provided to us or collected about you when you use our products and services, or otherwise interact with Focus on Force. This information is also referred to as ‘personal data’.
We understand that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits our site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.
This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you.
When we refer to "Focus on Force," "we," or "us" in this policy, we mean Focus on Force, which controls the information collected when you use the services. Focus on Force offers Salesforce training, including certification study preparation products and services. We also offer related services, like support. We refer to all of these products, together with our other services as "services" in this policy.
K2 Partnering Solutions Pty Ltd. collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) as well as local laws, and we are responsible as ‘controller’ of that personal information for the purposes of those laws. For the purpose of applicable data protection legislation (including but not limited to the GDPR), the company responsible for your personal data is the one you are dealing and/or contracting with. If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us, Please refer to Section 'Your rights‘, in respect of data that we already hold, or which we receive from third parties.
What does this policy cover?
What information do we collect about you?
Some data will be collected automatically by our site, other data will only be collected if you voluntarily submit it and consent to us for example, when signing up for an account. We collect information about you when you provide it to us and when you use our services, as further described below.
Information you provide to us directly
When you visit or use some parts of our websites and/or services we might ask you to provide personal data to us. If you don’t want to provide us with personal data, you don’t have to, but it might mean you can’t use some parts of our websites or services.
Information we collect automatically
We collect some information about you automatically when you visit our websites or use our services, like your IP address and device type. We also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our websites and services so that we can continue to provide the best experience possible (e.g., by personalising the content you see).
Information you provide to us
Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the services. For example, you provide your contact information and, in some cases, billing information when you register for the services. You also have the option of adding a profile photo and other details to your profile information to be displayed in our services. Account and profile information collected includes:
- Email Address
- Profile photo (if provided)
Content you provide through our products: The services include the Focus on Force products you use, where we collect and store content that you post, send, receive and share. This content includes any information about you that you may choose to include. Examples of content we collect and store include: course progress and past practice exam results.
Content you provide through websites: You provide content to us when you provide feedback on our products, provide feedback or ask questions in the forums, post comments on pages or when you participate in any interactive features, surveys, contests, promotions, activities or events.
Information you provide through our support channels: The services also include customer support, where you may choose to submit information regarding a problem you are experiencing with a service. When you engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Payment Information: We collect certain payment and billing information when you register for certain paid services such as payment card details, which we collect via secure payment processing services.
Information we collect automatically when you use the services
We collect information about you when you use our services, including browsing our websites and taking certain actions within the services.
Your use of the services: We keep track of certain information about you when you visit and interact with any of our services. This information includes the practice exams you use and complete, the study guide sections you complete and your practice exam results.
Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the services. This device information includes your connection type and settings when you access or use our services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, and device identifiers. We use your IP address and/or country preference in order to approximate your location to provide you with a better service experience. How much of this information we collect depends on the type and settings of the device you use to access the services.
How we use information we collect
We use your data to provide you with any products and services you have requested and to manage our relationship with you. This includes:
- Providing and managing your Account
- Providing and managing your access to our site
- Personalising and tailoring your experience on our site
- Supplying our products and services to you
- Personalising and tailoring our products and services for you;
- Responding to communications from you;
- Supplying you with email such as newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the unsubscribe link in the email
- Analysing your use of our site and gathering feedback to enable Us to continually improve our site and your user experience;
- In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you without your consent for us to be able to use such data.
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
Communications may include:
- Providing you with information you’ve requested from us (like training or education materials) or information we are required to send to you
- Operational communications, like changes to our websites and services or assistance with using our websites and services
- Marketing communications in accordance with your marketing preferences
- Asking you for feedback or to take part in any research we are conducting
Further information on the ways we use the information we collect:
To support you: This may include assisting with the resolution of technical support issues or other issues relating to the websites or services, whether by email, in-app support or otherwise. We use your information to resolve technical issues you encounter, to respond to your requests for assistance and to repair and improve the services.
To enhance our websites and services and develop new ones: For example, by tracking and monitoring your use of websites and services so we can keep improving, or by carrying out technical analysis of our websites and services so that we can optimise your user experience and provide you with more efficient tools.
To market to you: In addition to sending you marketing communications, we may also use your personal data to display targeted advertising to you online – through our own websites and services or through third party websites and their platforms.
To analyse, aggregate and report: We may use the personal data we collect about you and other users of our websites and services (whether obtained directly or from third parties) to produce aggregated and anonymised analytics and reports.
To provide the services and personalize your experience: We use information about you to provide the services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the services.
For example, we use the name and picture you provide in your account to identify you to other service users.
To communicate with you about the services: We use your contact information to send transactional communications via email and within the services, including confirming your purchases, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages.
Depending on your settings, we send you email notifications when you or others interact on the services, for example, when there is a reply to a forum post. We also send you communications as you onboard to a particular service to help you become more proficient or provide additional information about that service.
To market, promote, and drive engagement with the services: We use your contact information and information about how you use the services to send promotional communications that may be of specific interest to you, including by email. These communications are aimed at driving engagement and maximizing what you get out of the services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests.
For safety and security: We use information about you and your service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of service policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the services, with your permission.
Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the services, including to operate the services, provide customer support and personalized features and to protect the safety and security of the services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
How and where do we store your data?
Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using our site and submitting information to us. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties.
We use data hosting service providers in the United States to host the information we collect.
Data security is of great importance to us, and to protect your data. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our site.
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
How long do we keep your data?
Account information: We retain your account information until you delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes.
Information you share on the services: If your account is deactivated or disabled, some of your information and the content you have provided will remain. For example, we continue to display comments and content you provided to the forums.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How we share information we collect
We share information we collect about you in the ways discussed below.
Site Pages, Blog Posts and Community Forums: Our website offer publicly accessible pages, blog posts and member forums. You should be aware that any information you provide in these websites - including profile information associated with the account you use to post the information - may be read, collected, and used by any member of the public who accesses websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these services. To request removal of your information from publicly accessible websites operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our services.
- Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, payment processing, analysis and other services for us, which may require them to access or use information about you. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name and profile picture alongside the testimonial.
- Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services.
- Analytics: We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
- Legal Proceedings: In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
What Happens If Our Business Changes Hands?
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. We will respond to requests about this within a reasonable timeframe.
- You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. You may contact us as provided in the Contact Us page to request assistance.
- Access and update your information: Our services give you the ability to access and update certain information about you from within the service. For example, you can access your profile information from your account. You can update your profile information within your profile settings.
- Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so. For example, if you believe a services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy.
- Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email or by contacting us to have your contact information removed from our promotional email list or registration database.
International Data Transfers
- We collect information globally and primarily store that information in the United States. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the services. Whenever we transfer your information, we take steps to protect it.
- For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
Your rights to withhold and withdraw information
- You may access certain areas of our Site without providing any data at all. However, to use all features and functions available on our site you may be required to submit or allow for the collection of certain data.
- You may withdraw your consent for Us to use your personal data by contacting us. However, you acknowledge this may limit our ability to provide the best possible products and services to you.
Summary of your rights under GDPR
Under the GDPR, you have:
the right to request access to, deletion of or correction of, your personal data held by us;
be informed of what data processing is taking place;
the right to restrict processing;
the right to data portability;
object to processing of your personal data;
the right to complain to a supervisory authority;
Our Service is not intended for children under the age of 13 (16 in the EU), and therefore, we do not knowingly acquire or receive Personal Data from children under the age of 13 (16 in the EU). If we later learn that any user of our Service is under the age of 13 (16 in the EU), we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service.
Our Data Protection Officer is Maurizio Scozzafava and can be contacted here: email@example.com
Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third party source.
If you would like to exercise any of those rights, please:
- Email our Data Protection Officer on firstname.lastname@example.org or write to us at 55 Old Broad St, London EC2M 1RX, United Kingdom and mark your correspondence to the attention of the Data Protection Officer.
- let us have enough information to identify you (eg full name and other identifying details such as the circumstances under which we had dealings with you),
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates, including any account or reference numbers, if you have them.
If you would like to unsubscribe from any email newsletter you can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take a few days for this to take place.
For California Residents:
Selling of data: CCPA provides Californian consumers with a right to opt-out from the selling of their data. K2 does not sell personal data to third parties, and therefore, there is no need to enable Californian consumers to opt-out from this option, as required by CCPA.
If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to the DPO at email@example.com. We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information. Please refer to our Complaints Policy on our website www.k2partnering.com. This does not affect your right to lodge a complaint with a national supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
The European Union supervisory authority selected by K2 is “Garante per la Protezione dei Dati Personali”, which can be contacted at firstname.lastname@example.org.
The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.