LAST UPDATED: May 10TH, 2018
Launched 25 th May 2018 there is a series of new regulations to clarify and strengthen privacy (how the information used by the system is managed).
The regulations clarify who has responsibility for personal data and how it is managed;
There are three groups of people associated with using this platform;
The Account Holder - you are the Account Holder.
The Data Controller (1) - you are also the Data Controller with respect to the data you add for people you want to include in the process of 360 feedback.
The Data Controller (2) - we are also Data Controllers – but – limited to the information you add to manage your account as the Account Holder on the platform.
The Data Processors - we are the Data Processors for the information you add to the system for the 360 feedback process.
As the Data Controller (1) - you are responsible to ensure consent has been by each person you add to the system to provide feedback. You are also responsible to ensure that any data is managed in line with the GDPR regulations.
As the Data Processers - we are contracted to ensure that the data you (as the controller) add to the system is managed and protected in line with the GDPR regulations.
As Data Controllers(2) - we have the same responsibilities as you, to ensure that any data we manage about you the account holder is maintained in line with the GDPR regulations.
When you use the system you agree that you use it for the designed intentions only and at your own discretion and at your own risk. Whilst we takes appropriate precautions to prevent data loss and system integrity we will not be held responsible for any damage to or loss of data on your computer system or for the results of the data and information collected by account holders as part of the process.
Under no circumstances will icskills.com limited or its engaged employees be liable to any user of the system on account of the user's use or miss-use of the system or reliance on the system to maintain data.
Icskills.com or its employees will under no circumstances be held responsible or liable to damage or data loss of any third party computer or computer system where the damage or data loss has been caused by a user or user's computer or computer system during any time that they are registered as account holders on the reactive360 system.
Without limiting the foregoing, under no circumstances shall reactive360 be held liable for any delay or failure in performance resulting directly or indirectly from acts of nature, forces, or causes beyond its reasonable control, including, without limitation, Internet failures, computer equipment failures, telecommunication equipment failures, other equipment failures, electrical power failures, strikes, labour disputes, riots, insurrections, civil disturbances, shortages of labour or materials, fires, floods, storms, explosions, acts of God, war, governmental actions, orders of domestic or foreign courts or tribunals, non-performance of third parties, or loss of or fluctuations in heat, light, or air conditioning.
Icskills.com limited retains its right to at any time and without warning remove the complete account of the account holder where the account holder is suspected of or actually deemed to be abusing the system or not using the system for the designed intentions.
Icskills.com limited also retains its right to at any time and without warning remove the complete account where the account holder does not or cannot provide evidence on request that they comply with local compliance regulations covering Data Privacy including GDPR. Where this is the case Icskills.com limited will not be held liable or responsible for any loss of data incurred by the user or users.
These Terms of Service constitute the entire agreement between the parties with respect to use of the reactive360 system and supersede all prior agreements, written or oral. Any waiver of any provision of the Terms of Service will be effective only if in writing and signed by a director of Icskills.com limited.
Privacy and Data Control
Icskills.com limited recognises that privacy is very important and that the information you provide of a personal nature should not be used other than to aid with the provision of the services supplied.
Icskills.com limited as Data Processors will never distribute or use any of the information you add to the system other than to enable the operation of your account.
You the account holder as the Data Controller are responsible to ensure consent has been by each person you add to the system to provide feedback. You are also responsible to ensure that any data is managed in line with the GDPR regulations.
We will endeavour on request in writing (firstname.lastname@example.org) to provide you with a full list of the type of and actual personal data we have gathered during your use of the system.
All of the data added to your account, including your account holder details and any or all of the data you add to the system as part of the operation of the system can on request (email@example.com) be deleted.
All data that you add to the system as account holder makes you responsible for its control as Data Controller.
For the data that is used as part of the service (excepting the data you add to create and manage your account), the data that is processed by us as Data Processors we accept responsibility to manage the data in line with regulatory controls including GDPR.
The data that you add as part of creation of the account means information about you as the account holder personally that we collect or for which we act as Data Controller.
2. Information we collect:
2.1 Who are 'you'?
You hold an account within an icskills.com limited service and you create 360 feedback appraisals, questionnaires or reports.
People you have added to one or more of your 360 feedback appraisals or questionnaires, or replied to a message you sent to them from within any icskills.com limited systems.
2.2 Information we collect about you the account holder.
We collect usage information about you whenever you interact with our websites and services. This includes which parts of the sites you visit, what you click on, when you perform those actions.
Device and browser data.:
We collect information from the device and application you use to access our services. Device data mainly means your IP address, operating system version, device type, system and performance information, and browser type. If you on a mobile device we also collect the UUID for that device.
Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.
If you are the Account Holder we will also collect:
When you register for an account, we collect your first and last name, username, password and email address.
If you make a payment to icskills.com limited, we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card).
3. How we use the information we collect:
3.1 Account Holder:
We process personal data about you with your consent or in order to:
Fulfill our contractual responsibility to deliver the services to you.
You have consented to us using certain types of cookies on our websites.
3.2 Contact Information:
We use contact information to respond to your inquiries, send you information as part of the services, we do not use this information for any type of marketing.
3.3 Device data:
We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer your geographic location based on your IP address.
More details: Device and browser data: We collect this to help us improve your service experience through a specific device/browser by optimizing how the website looks in a particular browser, how your screen brightness affects your experience and to ensure the service operates optimally and as it should on different devices and browsers.
3.4 Log data:
We use log data for many different business purposes to include:
To monitor abuse and troubleshoot.
To create new services, features, content or make recommendations.
To fix bugs and troubleshoot product functionality.
3.5 Legal uses:
To respond to legal requests or prevent fraud, we may need to use and disclose information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
As an account holder, we only use contact information to respond to an inquiry which you submit to us.
We have an IT security policy - a copy can be obtained on request to firstname.lastname@example.org
6. Data Retention:
If you hold an account with icskills.com limited we do not delete the data in your account unless requested – you are responsible for and control the time periods for which you retain this data.
8. Who is my data controller?
As mentioned above - all response data at an individual level is Data Controlled by the Account Holder – the account holder takes full responsibility to comply with the local regulations. icskills.com limited can be a data controller of data only when the data is specific to the account holder.
9. Your rights:
Some of you (in particular, European users and those whose information we receive under the EU-U.S. Privacy Shield and EU GDPR) have certain legal rights to obtain information about whether we hold personal information, to access personal information we hold about them, and to obtain its correction, update, amendment or deletion in appropriate circumstances. Some of these rights may be subject to some exceptions or limitations. We will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a request).
Rights which you are entitled to are:
Data access rights
Right to restrict processing
Right of Rectification
Right to Erasure (Right to be Forgotten)
Right to object to processing
Right to withdraw consent; and
Data portability rights
Where you hold an account with any icskills.com service, you are entitled to a copy of all personal data which we hold in relation to you. You are also entitled to request that we restrict how we use your data or object to some aspect of our treatment of your data. You can view all of your data in your own account when you log in.
Where you have responded to a questionnaire sent to you by the Account Holder using an icskills.com limited service, you will need to reach out directly to that individual or organization to discuss managing, deleting, accessing, restricting access to or otherwise withdrawing consent for use of, the information which you provided to them in your responses. Icskills.com limited does not control your response data and, accordingly, is not in a position to directly handle these requests in relation to that data.
If you are resident in the European Union and you are dissatisfied with how we have managed a complaint you have submitted to us, you are entitled to contact your local data protection supervisory authority.