VCC Live Academy Privacy Policy

Last modified: 24th November 2020


VCC Live Academy provides its Subscribers with access to training content over the Internet. The training content includes online materials that focus on how contact centers operate and perform (“Services”). 

In order to gain access to training content, Subscribers are required to complete a registration process (registered Subscribers will have a user account). During the registration you will be required to register some data. This Privacy Policy contains all information regarding how we handle your data in relation to the Services.
By completing the registration process for VCC Live Academy, you agree to the provisions of this Privacy Policy.

VCC Live reserves the right to update this Privacy Policy from time to time. It is important for you to review this Privacy Policy before using our Services and subsequently, periodically, though we will notify you of any changes that, in our sole discretion, materially impact this Privacy Policy. The updated Privacy Policy will be effective as of the time of posting, or on such later date as may be specified in the updated Privacy Policy, and your continued use of the Services after any such changes are effective will constitute your consent to such changes. When we change this Privacy Policy, we will update the “Last Modified” date above. 

1. Data controller, general provisions

1. Members of the VCC Live Group form a group of enterprises as construed for the purposes of the GDPR (regulation (EU) 2016/679 of the European Parliament and of the Council, General Data Protection Regulation). The controlling undertaking shall be the undertaking which can exert a dominant influence over the other undertakings by virtue, for example, of ownership, financial participation or the rules which govern it or the power to have personal data protection rules implemented. An undertaking which controls the processing of personal data in undertakings affiliated to it should be regarded, together with those undertakings, as a group of undertakings.

Members of the VCC Live Group

Controlling company data:

Company name: VCC Live Group Zártkörűen Működő Részvénytársaság
Registered seat: Balatoni Rd. 2/A, 5th floor, Budapest, 1112 Hungary
Company register number: 01-10-141046
Mailing address: Balatoni Rd. 2/A, 5th floor, Budapest, 1112 Hungary
Electronic (e-mail) address: info@vcc.live
VAT ID: 24670023-2-43

Controlled companies’ data:

Company name: VCC Live Hungary Korlátolt Felelősségű Társaság
Registered seat: Balatoni Rd. 2/A, 5th floor, Budapest, 1112 Hungary
Company register number: 01-09-735941
Mailing address: Balatoni Rd. 2/A, 5th floor, Budapest, 1112 Hungary
Electronic (e-mail) address: info@vcc.live
VAT ID: 13452696-2-43

Company name: VCC Live Germany GmbH
Registered seat: Gontardstraße 11, 10178 Berlin, Germany
Company register number: HRB 190017 B
Electronic (e-mail) address: info@vcc.live
VAT ID: DE277993151

 

Company name: VCC Live USA Inc.
Registered seat: State of Delaware, Centerville Road, Suite 400, City of Wilmington, County of New Castle, Delaware 19808
Electronic (e-mail) address: info@vcc.live 

Center of activities: Balatoni Rd. 2/A, 5th floor, Budapest, 1112 Hungary 

Representative of VCC Live Group:
Name: Szabolcs Tóth
email: szabolcs.toth@vcc.live
phone: +36 1 999 7400

VCC Live Group’s Joint Data Protection Officer:
name: dr. Rita Seres
email: rita.seres@vcc.live
phone: +36 1 999 7400

2. The objective of this Privacy Policy is to establish the scope of the processed personal data and the methods of the data processing, in addition to ensuring that the constitutional principles of data protection and requirements of data security are adhered to. 

3. To achieve the goals set out in subsection 2., your personal data will be handled confidentially, in line with operational statutory provisions. We will ensure their security, and take the technical and organizational measures and create the procedural rules necessary to meet the pertinent statutory requirements and other recommendations.

4. When processing personal data, we will adhere at all times to the requirements of operational data protection regulations, including individual industry regulations. This, in particular, pertains to the requirements of the GDPR.

2. What information do we collect?

1. We collect and process the following personal data.
Information you provide to us:

  • first name
  • surname
  • work email address
  • company name

Information we collect automatically:

  • log data, which may include your IP address
  • the date and time when you use the Services
  • usage data, which may include the frequency of login, and the different types of activity undertaken by you as a subscriber
  • general location information, such as IP address and the region in which you are located when you log in and use our Services
  • subscriber support questions, issues, and general feedback that you provide


3. How we use information about you

We need to identify and authenticate our users (including when you log in to VCC Live Academy).
We use information that you provide when registering to set up your user account, contact you regarding our Services, and manage your account.
We use your contact information and information related to your request to respond to your questions and requests.
We use log in and other data such as general location information to help us manage the performance, security and compliance of our Services.
We analyze usage information, your feedback, and support queries to help us understand and make improvements to our Services.
We use your contact information to send emails related to VCC Live Academy, such as courses news, notifications regarding completion of courses, etc.

When using our Services, you may access, update, or correct most of your account information by logging in to your account to edit your profile or organization record.

4. Legal grounds for processing data  

Information you provide to us: the data processing is necessary for the performance of the contract (VCC Live Academy's Terms of Service).

Information we collect automatically: The legal ground for data processing when we automatically collect information is our legitimate interests in the effective and lawful operation of our website, so long as such interests are not overridden by your data protection interests or fundamental rights and freedoms. 

5. Who do we disclose your information to

We disclose your information to our own employees, agents, and other contributors who need to view such data to fulfill their professional functions or the duties assigned to them. We shall ensure that individuals and contributors who are entitled to view the data processed by us adhere to the provisions of the applicable statutory requirements at all times and agree to maintain confidentiality and protect the privacy of your information.

Regarding the sending of emails concerning VCC Live Academy, we use the service provided by HubSpot (HubSpot Ireland Limited, address: 662880, Two Dockland Central, Guild Street Dublin 1, Ireland, https://www.hubspot.com/ , https://legal.hubspot.com/product-privacy-policy ), and thus they qualify as a data processor. As part of the service provided by HubSpot, personal data may be transferred to the USA. Based on the relevant legislation, the transfer of data to this third country is suitably guaranteed by the fact that VCC Live has entered into standard contractual clauses with this service provider. Data processed by HubSpot: first name, surname, work email address.

We also use the service provided by Thinkific (Thinkific Inc., British Columbia company with offices at 369 Terminal Ave, Vancouver, British Columbia, V6A 4C4, Canada, https://www.thinkific.com/privacy-policy/) to send email concerning VCC Live Academy, and also use them as a software platform to deliver our online courses. Thus, they also qualify as a data processor. As part of the service provided by Thinkific, personal data may be transferred to Canada. The European Commission has issued adequacy decisions for Canada. [The effect of such a decision is that personal data can flow from the EU to that third country without any further safeguard being necessary. In other words, transfers to the country in question will be assimilated to intra-EU transmissions of data]. In addition, VCC Live has entered into a data processing agreement with Thinkific. Data processed by Thinkific: first name, surname, work email address, your progress through the course. Purpose: email sending, login authentication, administering your course. Thinkific technically processes this information but only accesses it if specifically requested by VCC.

We may also need to disclose your personal information if required to do so by law, by a regulator or during legal proceedings.

VCC Live does not sell your information. We restrict access to your information to authorized employees, and do not share your information with third parties except in the circumstances specified above.

6. Term of data processing

We will store your information on our systems (i) as long as is necessary for the relevant Services; (ii) for any retention period that is required by law; (iii) to the end of the period in which litigation or investigations might arise in respect of the Services; (v) upon termination of the user account by VCC Live if the account is inactive for a continuous period of one year. 

7. Your rights  

If you have requests that cannot be carried out by logging in to your account, such as accessing additional information or deleting information about you, please email  academy@vcc.live. Please note that we may need to retain certain information about you for as long as you maintain an account for our Services, to provide you with our Services, to comply with our legal and regulatory obligations, to resolve disputes, or to enforce the Terms of Service of VCC Live Academy.

Requests to access, correct, or delete your information will be handled within 30 days of receipt unless they are unusually extensive or complex, in which case we will advise you of the expected timeline for the handling of your request. 

7.1. Right to access

You are entitled to receive feedback from us regarding whether processing of your personal data is in progress, and if this is the case, you are entitled to access your personal data and the following information:

a. the purpose of the data processing
b. data categories of the affected personal data
c. recipients your personal data are or will be disclosed to, especially recipients in third countries or international organizations
d. the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
e. your right to request corrections, deletion or restriction of processing of your personal data, and your right to object against processing of such personal data
f. the right to submit grievances to any supervisory authority

A copy of the personal data forming the subject of the data processing shall be disclosed to you. Any further copies requested by you will be subject to a reasonable fee imposed by ourselves, based on our administrative costs. If the request is submitted electronically, we will disclose the information in a widely-used electronic format, except if otherwise requested.

7.2. Right to erasure

You shall have the right to obtain from the data controller the erasure of personal data concerning you without undue delay, and the data controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

a. the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed
b. you withdraw your consent on which the processing is based, and there is no other legal ground for processing
c. you object to the processing pursuant to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR
d. the personal data has been unlawfully processed
e. the personal data has to be erased to comply with a legal obligation in a Union or Member State law to which the data controller is subject

7.3. Right to rectification

Upon your request, we will correct your personal data without undue delay.
If accurate and correct or supplementary data is not available, we will base our correction/supplement on your supplementary statement.

7.4. Right to object

You may object at any time against the processing of your personal data on grounds relating to your particular situation. The data controller shall no longer process the personal data unless the data controller  demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

We will examine your objection and suspend data processing without delay, and within 15 days from submission of the request at the latest, and will inform you of the results in writing.

If the objection is justified, we shall cease processing your data, including further data collection and data transmission, and block such data. We shall also inform all parties the respective personal data were transmitted to earlier about our measures. These entities shall take appropriate measures to grant such rights to objection.

If you do not agree with our decision, or, if we fail to fulfill the above obligations within the 15 days deadline, you may submit your redress request to a competent court within 30 days of receipt of the decision, or from the last day of the deadline detailed above.

7.5. Right to restriction of processing

We will restrict data processing if one the following circumstances exist:

a. You challenge the accuracy of the personal data;
b. Data processing is unlawful, and you object to the deletion of your data; instead, you request the restriction of processing thereof;
c. We no longer need your personal data for data processing, but you request it for submission, representation or protection of your legal claims, or
d. You have objected to data processing

Except for storage, if data processing falls under the restrictions, the affected personal data may only be processed, with your consent, for submission, representation or protection of legal claims or to protect the rights of third parties (natural persons or legal entities), or if in the interest of the European Union or any member state.  

7.6. Right to data portability

You shall have the right to receive the personal data concerning you, which you have provided to the data controller in a structured, commonly-used, and machine-readable format, and have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, if the data processing is based on your consent or a respective agreement, and the data processing is carried out by automated means.

You shall also have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

Your rights under point 7 may be restricted to safeguard the state’s internal or external security, including purposes of home defense, national security, crime prevention and prosecution, law enforcement, to protect the economic or financial interests of the state, to prevent and investigate disciplinary and ethical offenses committed on the job or omission of employment law and health and safety obligations – always including oversight and supervision – and to protect your or third party rights.

8. Right to complain 

If you feel that you have experienced an infringement of your rights, you may request remedy from:

a. the competent supervisory authority in the member state

b. the competent court with jurisdiction over your area of permanent or temporary address.