Xpedite is a product developed by ExpertCollege. Therefore, ExpertCollege is the Controller for any personal data you provide when using Xpedite products and services.

ExpertCollege processes personal data for the purpose of providing our products and services. In doing so, we act in accordance with the General Data Protection Regulation (GDPR) to ensure that your data is processed carefully and your privacy is protected. The GDPR refers to the party responsible for your personal data as the Controller. If you use our products or services, partner with us or enter into a business relationship with us, we become Controller for some of your personal data when we exchange or process your information.

In this privacy policy, we would like to inform you about our policies, how ExpertCollege handles your personal data and how we fulfil our duties as Controller. We would also like to make you aware of the rights you have when ExpertCollege processes your personal data.

Should you have any questions after reading this privacy policy, or if you have feedback on how we handle your personal data, please refer to the information on how to contact us about this at the bottom of this page.

1. What kind of personal data do we process?

When we process personal data for marketing purposes

When you provide your personal data to ExpertCollege Holding affiliates that offer healthcare education and training services, and were informed of their data collection practices through their privacy policies, or otherwise agreed to share your personal data with their partners and affiliates, we may collect this data from these companies for the purpose of direct marketing.

When we collect data from companies affiliated with ExpertCollege Holding, we will only collect data necessary for our marketing purposes, namely:

• Your first and last name;
• Your email address;
• Your profession/title.

We will always balance our interest in advertising our products and services against your interest in protecting your personal data, as well as the benefit you might derive from receiving marketing offers relevant to your field. We will ensure that you have the option to unsubscribe from such emails at any time.

When creating an account on our website

To allow you to access our e-learning environment and enable your progress and development in the e-learning modules, we require some information from you. To register your account, we process the following personal data:

• Your first and last name;
• Your gender;
• Your email address.

When ordering products on our website

When you purchase e-learning modules through our website, we also collect data needed to process your payment and in some cases for sending products by post. In these cases, we will request and process additional data, namely:

• Your address details;
• Your billing information;
• Your payment method;
• Your phone number.

When using our e-learning modules

When you study using our e-learning modules, we also keep records of your study progress. We record which modules you have started and completed. After you have completed a module, a certificate will be made available. Our system also records the answers you give in the e-learning modules. This happens automatically and is necessary to determine your score, when you have obtained the certificate, which questions and topics should or should not be brought to your attention in more detail, and to show you your progress. During this process, we therefore record the following personal data:

• Study progress data.

Contact with our customer service 

When you contact our customer service, you will be asked to share personal data so that we can verify your identity and help you with your account. We will never ask for unnecessary data and will instruct you to send any additional information to our Data Protection Officer to ensure the confidentiality of your data. We collect this data to fulfil our obligations to you, including providing customer service.

If you experience technical problems related to your account, we may need to log into your account to resolve these issues. No data will be downloaded from your account during this process.

Calls to our customer service may be recorded for training purposes. By calling our customer service, you consent to your conversation being recorded. If you do not want your conversation to be recorded, you can end the call and contact us via email.

Marketing

We aim to attract customers by creating interesting content and user experiences tailored to your needs. When you use ExpertCollege content and have given permission for cookies to be placed on your device, we can track which pages you view and what content you use.

If you wish to take up an offer, such as access to content, manuals and webinars, we will collect your contact details (name, email address, professional details) in exchange for access to the content. By accessing, downloading and using the content, you agree to the collection of your personal data.

When you fill in a form in response to a content offer and provide contact details/personal information, we will link your previous page visits to your contact details in our system. We will use this information to send you information about our products/services that we think may be relevant to you.

If you no longer wish to receive this information from us, you can unsubscribe. In that case, we will remove your details from our mailing list.

We use HubSpot to plan and execute our marketing activities. More information about this platform is available here.

We promote Xpedite to carefully selected companies that we think will benefit from the product. To do this, we collect the following data from public sources:

• Initials and surname (including affixes) of the director/owner of the company.

We approach potential leads directly or through a partner company that only processes data on behalf of ExpertCollege. We have signed a processor agreement with this company and guarantee your rights as a data subject under the GDPR.

We will always balance our interest in promoting our products with your right to protection of your personal data. If you indicate that you do not wish to receive calls from us, we will no longer contact you and delete your data from our systems.

Cookies and tracking

A cookie is a small file, often containing unique identifiers, that is placed on your device temporarily or for a longer period of time to allow websites to record your browsing behaviour and store information. Different types of cookies may be used, depending on the desired duration, purpose and the party placing them.

Duration

Session cookies: these cookies store your information only while you are using the website and are deleted when the website is closed.

Permanent cookies: these remain on your browser or device even after you close your browser (for instance to allow a website to remember your password).

Purpose

Strictly necessary cookies: these enable websites to function properly and are related to services specifically requested by you as a user.

Functional or preference cookies: these allow websites to remember choices you have made in the past, such as your preferred language settings. They can also remember your login details, allowing you to log in automatically.

Analytical or statistical cookies: these collect information about how users interact with websites for statistical purposes, and to improve content and features.

Marketing or tracking cookies: these collect data to build user profiles for promotional purposes or to track the user on a specific website or across different websites.

Party placing the cookies

First-party cookies: these cookies are placed directly by the websites you visit.

Third-party cookies: these cookies are placed by websites other than the ones you are visiting.

Cookies used by ExpertCollege

Strictly necessary cookies: these cookies are placed for the following purposes:

• to ensure the website works as expected;
• to see which user is logged in;
• to save modules;
• to save course IDs.

These are first-party cookies (placed by ExpertCollege) that will remain on your device for as long as necessary with regard to the above purposes.

Functional cookies: these cookies are placed on your device for the following purposes:

• to save your language preferences;
• to save your login details.

These are first-party cookies that will remain on your device for as long as necessary with regard to the above purposes.

Functional cookies can be turned off at any time in the cookie settings.

Purposes of analytical cookies:

• marketing purposes: measuring ad reach;
• measuring website traffic;
• measuring how users interact with certain features and how long they stay on certain pages.

We use Google Analytics in accordance with the guidelines of the Dutch Data Protection Authority:

• we have a processing agreement with Google;
• we anonymise IP addresses;
• data sharing with Google is disabled;
• data sharing with Google for advertising purposes is disabled;
• the user ID function is disabled.

You can always disable analytical cookies in the cookie settings. They are first-party cookies that are deleted after 12 months.

Purposes of tracking cookies:

• tracking visitors anonymously before they become contacts;
• tracking page views;
• linking page views to existing or new contacts.

Tracking cookies are placed only after you have given your consent. You can withdraw your consent at any time in the cookie settings. Tracking cookies are first-party cookies that are deleted after 12 months.

2. Why do we process this personal data?

With this purchase, we guarantee access to a well-functioning digital learning environment. To ensure this, we must process certain personal data.

ExpertCollege does not process more data than necessary for this purpose. The data processing purposes arising from our product and service offerings are:

• Registering user accounts;
• Recording study progress in our e-learning modules;
• Offering a certificate on completion of a module;
• Processing orders and payments for our products and services.

In addition, there are some purposes for which we use your data only after you have given us permission to do so. These purposes are:

• Providing information about our products and services through our newsletter.

3. Will your personal data be shared with third parties?

ExpertCollege shares your data with third parties for the following purposes:

• if this is necessary for the performance of the agreement resulting from your purchase, or if you have given your consent;
• cross-marketing campaigns in collaboration with ExpertCollege Holding affiliates, to market products and services that we believe are relevant to your needs. In these cases, we will only share strictly necessary data (name, email address and profession/title). We will share your data only after verifying that the affiliated company fully complies with data protection legislation. View the list of affiliates.

4. How long will your data be stored?

If a legal time limit exists for the processing of certain types of personal data, ExpertCollege will store this personal data for at least as long as required by law and/or no longer than the legally prescribed time limit.

However, no such legal time limit exists for most of the personal data ExpertCollege processes. Personal data from your account, including study progress data, will be stored in your account for up to 10 years after your last login, after which it will be irrevocably deleted.

Data for marketing and commercial purposes will be stored as long as you are registered as a customer of ExpertCollege, or until we have determined that you are no longer a (potential) customer of our products or services.

5. Data transfer to countries outside the EEA

We may outsource certain tasks (such as providing customer service) to our affiliates outside the European Economic Area (EEA), in the Philippines.

We have taken appropriate measures to ensure that the protection your data enjoys in the EEA also applies if your data is stored elsewhere. ExpertCollege and its affiliates have carried out an analysis regarding the consequences of data transfer and signed standard contractual provisions approved by the European Commission. If you would like to see a copy of these provisions, please contact our Data Protection Officer at the address below. 

All your personal data is stored securely on servers within the EEA and can only be accessed remotely by our affiliates for customer service, technical support and coordination purposes. 

As an additional measure, ExpertCollege has implemented an EN-ISO/IEC 27001:2017-certified Information Security Management System (ISMS) to ensure the confidentiality, integrity and accessibility of your data. 

6. Your rights

When we process your personal data, you are referred to as a Data Subject under the GDPR. As a Data Subject, you enjoy various rights regarding the protection of your privacy. You can contact us, the Controller of your personal data, at any time to exercise your rights. More information about this can be found at the bottom of this page. 

As a Data Subject, you have the following rights: 

• Right of access: access to personal data stored and processed by us; 
• Right to rectification: the right to have incorrect personal data or information stored by us corrected; 
• Right to erasure: the right to have personal data stored and processed by us erased; 
• Right to object: the right to object to the processing of your personal data on grounds of legitimate interest or for direct marketing. 

If you wish to exercise any of the above rights, please email dpo@expertcollege.com. Please send us a copy of your proof of identity (ID or passport) so that we can verify your identity and check that the request really comes from you. To protect your privacy, please black out the passport photo, citizen service number, passport number and MRZ code (the series of numbers, letters and characters at the bottom of your passport). We will inform you when we have processed your request and aim to respond within 4 weeks. 

You can easily request your data using the Data Subject Access Request Form, which you can download here.

7. Data Protection Officer

ExpertCollege has appointed a Data Protection Officer (DPO) to oversee how it processes your personal data. The DPO advises ExpertCollege’s management and staff on all matters related to the processing of personal data and privacy. 

The DPO is also your first point of contact for questions or comments about ExpertCollege’s processing of your personal data, or if you wish to exercise your rights under the GDPR. You can also contact our DPO if you believe ExpertCollege’s handling of your personal data is incorrect or unlawful. To do so, send an email to dpo@expertcollege.com, addressed to Ms M. Vasileva. 

You can also contact the DPO by post at the following address: 

ExpertCollege BV
T.a.v. Functionaris Gegevensbescherming
Gondel 1
1186 MJ AMSTELVEEN

8. Complaints

If you are dissatisfied with our response to your question or comment, or with the way we have processed it, and you believe we are handling your data unlawfully, you can report this to the Dutch Data Protection Authority. This organisation enforces privacy laws and regulations on behalf of the government. You can submit your report or complaint via its website: https://www.autoriteitpersoonsgegevens.nl.