This Notice describes the steps Learning Tree International, Inc. and its EU affiliates (together “Learning Tree”, “Company”, “we” or “us”), part of the Learning Tree Group of Companies (“Learning Tree Group”, “we” or “us”), take to protect the personal data that we process about our customers and other business related personal data. Learning Tree is committed to the protection of the personal data that we process about you in line with the data protection principles set out in the European Union General Data Protection Regulation 2016 (“GDPR”).
Learning Tree’s EU affiliates are each responsible for making this notice accessible to their respective clients and prospects.
If you are an individual associated with one of our customers or vendors, the relevant data controller is the Learning Tree EU affiliate with which the company you are associated with has a contract. If you are a website user or associated with a prospective customer or vendor, the relevant data controller is the Learning Tree entity that you would contract with.
A list of Learning Tree’s EU affiliates and the relevant contact details for each are provided in Annex 1 to this Privacy Notice.
We may source, use and otherwise process your personal data in different ways. In all cases we are committed to protecting the personal data of our business contacts.
In each of the sections listed below, we describe how we obtain your personal data and how we will treat it.
Section 2.1 Representatives of our Existing or Prospective Customers and Vendors
Section 2.2 Visitors to Premises
Section 2.3 Website Visitors
A - Sources of personal data
We may obtain your personal data from the following sources:
B - Personal data that we collect and process
We may collect the following categories of personal data relating to our corporate customers’ or vendors’ employees, officers, authorised signatories, and other associated individuals. This may include:
C - Why do we collect your personal data and what are our lawful bases for it?
| Representatives of our Existing or Prospective Customers and Vendors | ||
| We may use your personal data to: | Our lawful basis for doing so is: | Our legitimate interests in doing so are: |
| Provide you with our products or services or receive products or services from you | Legitimate Interest | Efficiently fulfil our contractual and legal obligations Management Reporting (including at an intra-group level) |
|---|---|---|
| Establish and manage our relationship | Efficiently fulfil our contractual and legal obligations Account Management Exercise or defend legal claims Understand the market in which we operate Management Reporting (including at an intra-group level) |
|
| Learn about how our products and services are or may be used | Understand the market in which we operate Management Reporting (including at an intra-group level) |
|
| Security | Managing security, risk and crime prevention Management Reporting (including at an intra-group level) |
|
| Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication | Promote our goods and services Management Reporting (including at an intra-group level) |
|
If you object to us using your contact details for these purposes, including direct marketing, please send us an email to us using the relevant email address in Annex 1.
Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.
A - Sources of personal data
We may obtain your personal data from you directly and from our systems’ records.
B - Personal data that we collect and process
C - Why do we collect your personal data and what are our lawful bases for it?
| Visitors to our Premises | ||
| We may use your personal data to: | Our lawful basis for doing so is: | Our legitimate interests in doing so are: |
| Security | Legitimate Interest | Managing security, risk and crime prevention |
|---|---|---|
| Maintain records of visitors to our premises | Management Reporting | |
If you object to us using your contact details for these purposes, please send us an email to us using the relevant email address in Annex 1.
A - Sources of personal data
We may obtain your personal data from the following sources:
B - Personal data that we collect and process
C - Why do we collect your personal data and what are our lawful bases for it?
| Website Visitors | ||
| We may use your personal data to: | Our lawful basis for doing so is: | Our legitimate interests in doing so are: |
| Provide our website services to you | Legitimate Interest | Website Management Promote our goods and services Account Management |
|---|---|---|
| Establish and manage our relationship | Understand the market in which we operate Management Reporting (including at an intra-group level) Account Management |
|
| Learn about our websites(s) users’ browsing patterns and the performance of our website(s) | Website Management | |
| Security | Managing security, risk and crime prevention Management Reporting (including at an intra-group level) |
|
| Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication | Promote our goods and services Management Reporting (including at an intra-group level) |
|
| Learn about how our products or services may be used | Understand the market in which we operate Management Reporting (including at an intra-group level) |
|
If you object to us using your contact details for these purposes, including direct marketing, please send us an email to us using the relevant email address in Annex 1.
Where we use cookies or similar technologies to fulfil this purpose we will seek your prior consent where required to do so by law.
Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.
We do not sell your personal data to third parties.
Learning Tree Affiliates
We may share your personal data with other entities in the Learning Tree Group of Companies (see the list in Annex 1).
Third Party Courses
We may transfer your personal data to organisations that provide third party training courses, on the basis that these course operators are GPDR-compliant and will adhere to the requirements of data protection laws.
Our Service Providers
We may disclose information about you to organisations that provide a service to us, on the understanding that they will keep the information confidential and will comply with the GDPR and other relevant data protection laws.
We may share your information with the following types of service providers:
Company Mergers and Takeovers
We may transfer your personal data to potential purchasers and their advisors, subject to appropriate confidentiality obligations, in the event we decide to dispose of all or parts of our business.
If and when transferring your personal data outside the EEA, we will only do so using one of the following safeguards:
International transfers within the Learning Tree Group are governed by EU Commission-approved Standard Contractual Clauses for Controllers and, where relevant, for Processors.
We may also transfer your data to third-party vendors outside the EU. Where we do so, the Standard Contractual Clauses or other safeguards approved by the European Commission are in place to safeguard that personal data.
You may request a copy of these agreements by contacting us using the relevant email address in Annex 1.
The GDPR provides you with certain rights in relation to the processing of your personal data, including to:
These rights are not absolute and are subject to various conditions under:
Where processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If at any time you decide that you do not want to be contacted for any purpose or if you would like to exercise any of your rights as set out above, you can contact us by emailing the relevant email address provided in Annex 1.
We will keep and Process your Personal Data only for as long as is necessary for the purposes for which it was collected in connection with your relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.
Learning Tree International AB (‘we’ ‘our’ ‘us’) are committed to protecting and respecting your privacy. This website is operated by Learning Tree International AB, Lindhagensgatan 126, 112 51 Stockholm, Sweden. This section is our Cookies Notice; it tells you why we use cookies, the cookies we use and how you can manage the cookies stored on your devices.
A cookie is a small removable data file, typically of letters and numbers, downloaded on to a computer, smartphone or other device when the user accesses certain websites.
Cookies are used for a variety of reasons from making a website function more efficiently, to recognising a user’s device and tailoring that user’s experience to fit prior preferences. Cookies can also provide the owners of a site valuable information about how that site is being used. We use cookies to allow us to distinguish you from other users of our website, which helps us to provide you with a personalised experience when browsing our website and allows us to improve our site.
The type of cookies we use are session cookies and persistent cookies. Session cookies are temporary files which last only as long as your browsing session and are erased once you close your browser. Persistent cookies are files that stay in your browser’s subfolders after you close your browser.
Please review the table below for more detailed information on the specific cookies we use.
Essential Cookies
Certain cookies are necessary for our website to function and cannot be switched off. If you block them, our website will not work properly with your computer.
| Cookies | Type of cookie (e.g., first party, third party, session or persistent) | Types of data held | Purpose(s) | Lifespan of the cookie | Is the data combined with other information held about the users/visitors? Please specify. | Is the data shared with any third parties, including group companies? If so, with whom, where and for which purpose(s)? |
| .LTREFORMSAUTH | First party | Username, Account ID | Login Cookie | Session, persistent if remember me is checked | Data is combined with Individual ID (Unique internal identifier), but not contained in the cookie itself | No, encrypted. |
| ASP.NET_SessionId | First party | Unique session ID | Connection for asp.net application session data | Session | No | No |
| __RequestVerificationToken | First party | Request forgery token | Web form cookie, prevents form HTTP POST without an HTTP GET | Session | No | No |
| ASPSESSIONID[XXXXXXXX] | First party | Unique session id for classic asp applications | Connection for classic asp applications | Session | No | No |
| .ASPXEVALS | First party | Unique evaluation ID | Login cookie | Session | Yes, course attendance | No, encrypted |
| .ASPXEVALSINCLASS | First party | Unique evaluation ID | Login cookie | Session | Yes, course attendance | No, encrypted |
| .ASPXEVALSWEEKLYCONTEST | First party | Registration number, email | Login cookie | Session | Yes, course attendance | No, encrypted |
Performance Cookies
These cookies allow us to measure and improve the performance of our site by counting visits, return visits and proving us with information about the pages that are most visited.
| Cookies | Type of cookie (e.g., first party, third party, session or persistent) | Types of data held | Purpose(s) | Lifespan of the cookie | Is the data combined with other information held about the users/visitors? Please specify. | Is the data shared with any third parties, including group companies? If so, with whom, where and for which purpose(s)? |
| Not Applicable | ||||||
Third Party Cookies
These cookies are set by third parties to collect personal data about you to provide personalised advertisements and to provide analytics on the website.
| Cookies | Type of cookie (e.g., first party, third party, session or persistent) | Types of data held | Purpose(s) | Default Lifespan of the cookie | Is the data combined with other information held about the users/visitors? Please specify. | Is the data shared with any third parties, including group companies? If so, with whom, where and for which purpose(s)? |
| _ga | Third party, persistent | Unique Identifier for Google Analytics | Google Analytics related cookie. Used to distinguish users. | 2 years | no | The only third party who has access to this data is Google |
| _gid | Third party, persistent | Unique Identifier for Google Analytics | Google Analytics related cookie. Used to distinguish users. | 1 day | no | The only third party who has access to this data is Google |
| _hjIncludedInSample | Third party, session | Aggregate Click, mouse movement, and scroll data on select pages | This session cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate Heatmaps, Funnels, Recordings, etc. | 365 days | no | The only third party who has access to this data is HotJar |
| mbox | Third party | n/a | Adobe Test & Target cookie, we may no longer be using this | 90 days | We are no longer using this | |
| _dc_gtm_UA-XXXXXXXX-X | Third party | Tracking scripts. This tool acts as a container for tracking scripts | Google Analytics ID, injected via Google Tag Manager, so that DoubleClick Campaign Manager can consume it. | 1 minute | no | The only third party who has access to this data is Google |
| _omappvp | Third party | Anonymous pop-up impression and click data | OptinMonster related cookie for visitor persistent. | 30 days | No | The only third party who has access to this data is OptInMonster |
| _omappvs | Third party | Anonymous pop-up impression and click data | OptinMonster related cookie for visitor session. | 30 days | No | The only third party who has access to this data is OptInMonster |
| cid | First party | Unique user identifier | Legacy Learning Tree user tracking cookie, connects to legacy forms | 21 months | Server side | No |
| Sync | First party | Date | Legacy Learning Tree user tracking cookie. Last time a cid cookie was generated | 21 months | No | No |
| TempId | First party | Individual ID and first 3 characters of email, fulfillcode | Legacy My Learning Tree user tracking cookie used for prefilling forms when available | 90 days | Data is combined with Individual ID (Unique internal identifier) | No |
| UserID | First party | Unique identifier | My Learning Tree user tracking cookie. | 180 days | No | No |
| Userref | First party | Username, usually email | My Learning Tree logged in user, designed to prefill user ID when implement | 180 days | No | No |
Our website uses Google Analytics to monitor how visitors move around the website and how they reached it. This is done so that we can see statistics on the types of content users’ access, find out the number of users that have visited the site before and collect information on how many users have visited our website. The Google Analytics application that we use is set to anonymize the data of our website visitor and cannot be used to identify individuals – they are only used for statistical purposes only. You can opt out of Google cookies here.
You have the option of whether to accept or deny cookies. However, choosing to block cookies may disable certain features of this site or prohibit the use of this site altogether. To deny or limit the use of cookies on your device you may set your web browser to deny the setting of any cookies, set your web browser to notify you when a cookie is set or you can delete set cookies later.
The process for blocking or removing cookies will vary from one web browser to the next.
For instructions on how to eliminate or restrict cookies through your browser settings please visit all about cookies.
For more information on how we protect your information please view our full Privacy Notice here.
By email: sedataprotection@learningtree.se
By telephone: 46 (0) 8-506 668 00
The purposes for collection and processing Course Participant Personal Data is outlined in the table below:
| Categories of Personal Data | Purpose of Processing | Lawful Basis for Processing |
| Contacting you regarding course content, instructors, schedules and other service messages | Legitimate interest (managing our relationship with you, to keep you informed about your course and changes in our policy; promoting and marketing,) | |
| Name Salutation Position/ Job title Department Contact information including email address, fax, phone, and physical address Demographic information (postcode, preferences and interests) Training Needs |
Internal record keeping | Legitimate interest (record keeping and business planning) |
| Improving our products and services | Legitimate Interest (business development and marketing, development of products and services) | |
| Providing you with promotional information on new Learning Tree, special offers and other information you may find interesting. | Legitimate Interest (marketing) | |
| Conducting participant surveys | Legitimate Interest (market analysis, management reporting, and feedback) | |
| Quality assurance, trend and statistical analysis | Legitimate Interest (forecasting, management reporting, and business analysis) |
Learning Tree only keeps the personal data in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
We will generally hold personal data collected for the purposes of complying with various legal obligations and regulations for the entire duration of our relationship with our Course Participants with regard to the provision of services and any applicable regulatory or retention period prescribed by law. We will retain information about you after your course has ended for as long as required for legal, regulatory, fraud prevention and legitimate business purposes.
However, we may retain data for longer periods, if required by law or if we consider it may be required for the purposes of dealing with potential claims.
Object to the Processing of your Personal Data in certain circumstances.
The following terms used within this Notice are defined as follows:
“Course Participant” means an employee or independent contractor of a legal entity, corporation, or sole proprietor with which Learning Tree has a contract, who participates in a course of training and related activities, including but not limited to testing or assessment;
“Data Controller” means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the Processing of Personal Data; where the purposes and means of Processing are determined by national or EU laws or regulations, the controller or the specific criteria for his nomination may be designated by national or EU law.
“Data Processor” means a natural or legal person, public authority, agency or any other body which processes Personal Data on behalf of the Data Controller.
"European Economic Area" or "EEA" means the Member States of the European Union, plus Norway, Iceland and Lichtenstein.
“GDPR" means the EU General Data Protection Regulation 2016/679 including national laws implementing or supplementing the GDPR.
“Learning Tree International Group” means the group of companies directly, or indirectly, held and/ or controlled by Learning Tree International, Inc. (LTRE.PK), a company with its principal place of business at 13650 Dulles Technology Drive, Suite 400, Herndon, VA, 20171-6156, USA, which includes Learning Tree International Inc. itself.
“Learning Tree International AB” is a member of the Learning Tree Group, with its principal place of business at Lindhagensgatan 126, 112 51 Stockholm, Sweden.
“Personal Data” means any information relating to an identified or identifiable natural person (also referred to as ‘Data Subject’); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Special Categories of Personal Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purposes of identifying an individual, data concerning health or data concerning a natural person’s sex life or sexual orientation.
“Process” or “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
| Entity | Contact | Address | Email Address | Telephone Number |
| Learning Tree International, Inc. | Privacy Officer | 13650 Dulles Technology Drive, Suite 400 Herndon, Virginia, 20171-6156, USA |
dataprotection@learningtree.com | 703.709.9119 |
| Learning Tree International Ltd | Privacy Officer | Leatherhead House, Station Road, Leatherhead, Surrey, KT22 7FG, United Kingdom | dataprotection@learningtree.co.uk | 44 (0) 1372 364600 |
| Learning Tree International AB | Privacy Officer | Lindhagensgatan 126, 112 51 Stockholm, Sweden | sedataprotection@learningtree.se | 46 (0) 8-506 668 00 |