Who We Are

SLG Holdings LLC and its affiliated companies, “Direct Support Learning”, “we” or “us”, is the company at the heart of the Direct Support Learning Project: empowering IDD providers to improve DD services.

This privacy notice sets out how Direct Support Learning collects and uses information about you when you use our products and services, “services”, and why we collect certain personal data. This notice also explains the choices you can make about how we use your information.

Your Privacy Matters

Your privacy protection is important to us. This is why we have adopted the following pivotal legislation: the EU’s General Data Protection Regulation 2016/679, “GDPR”, UK General Data Protection Regulation, “UK GDPR”, and the California Consumer Privacy Act 2018, “CCPA”.

This privacy notice relates to all personal data we process and addresses the legislation mentioned.

What is Personal Data?

“Personal data” means any information relating to an identified or identifiable natural person, “data subject”. An identifiable natural person is someone who can be identified, directly or indirectly, by reference to identifiers such as a name, ID number, location data, online identifier, or factors specific to their identity.

Useful Resources

We are committed to building a secure LMS that protects learners’ and employees’ data. Privacy features embedded in Direct Support Learning ensure GDPR compliance and adherence to local privacy laws.

However, some responsibility for compliance rests with the organization controlling each installation. We encourage organizations to:

• Write multiple policy documents to maintain transparency.
• Protect digital minors with age-of-consent checks.
• Handle data requests and track retention periods.
• Enable users to access/download data and appoint a privacy officer.

Why We Collect Your Personal Data

We collect your data to provide services or for correspondence. We ensure our data collection is limited to this purpose.

Our legal bases under GDPR are:

• Consent, Article 6.1(a): For community engagement, updates, or marketing. You may withdraw consent anytime.
• Contract, Article 6.1(b): To fulfill service or partnership obligations.
• Legal Obligation, Article 6.1(c): Compliance with laws.
• Legitimate Interest, Article 6.1(f): For recruitment, safety, business development, and login services.

If you object to our legal basis for processing, we may be unable to provide services.

Special Categories of Data

We may process:

• Facial images, such as profile pictures.
• Health data of employees/contractors.
• Other sensitive data voluntarily submitted by users.

We share such data only as legally permitted under GDPR.

How We Collect Personal Data

We collect data when you:

• Create an account
• Request support
• Register for or attend training or events
• Request materials
• Participate in surveys, promotions, purchases, job applications, or forums

How We Use Personal Data

We may share your data with third-party providers to deliver services, such as video conferencing. These providers are contractually bound to secure and use your data only as needed.

Subscribing agencies and users are responsible for agreeing to terms that outline data usage.

How We Store Personal Data

We process and store your information securely and in compliance with GDPR. We retain it only as long as needed, and we implement safeguards to protect your data.

Some data must be retained for legal reasons, such as tax or audit. Retention periods may vary by sector or business need.

Marketing

We do not collect unnecessary data or sell your information. If we contact you for marketing, we will first seek your consent.

Your Rights

You have the right to:

• Withdraw consent
• Access your data
• Rectify inaccuracies
• Erase data
• Port your data
• Restrict or object to processing
• Object to automated decisions
• Know what we collect
• Opt out of data sales, though we don’t sell it
• Judicial review
• Be free from discrimination
• Receive breach notifications
• File a complaint with an authority

Contact our Data Protection Officer at
support@go.directsupportlearning.com.
We will respond within one month.

If your data is controlled by another organization, such as your employer or institution, please contact them directly.

Third-Party Websites

If you access a site not hosted by us, or click an external link, review their privacy notice. We’re not responsible for data collected by others.

Children and Personal Data

We do not intentionally collect data from children under 16. If you believe we hold such data, please contact us at
support@go.directsupportlearning.com.

Verification

Before acting on a data request, we verify your identity. We prefer requests made while logged into your account, but may request ID, such as a passport or driver’s license.

Updates to this Privacy Notice

We may update this notice based on:

• Community or stakeholder feedback
• Service changes
• Data policy adjustments

The “last updated” date reflects the most recent change. Please review this notice periodically.

Cookies and Similar Technologies

We use cookies and similar tracking technologies on our Website to help customize the Website and improve your experience. A cookie is a small file placed on your device that enables various features and functionality.

Types of Cookies We Use

• Essential Cookies: Required for basic site functionality such as account access and secure areas. These cannot be disabled.
• Analytics and Performance Cookies: Used to collect aggregated, non-identifying information about how visitors use our Website, such as page visits and referral sources, to help us improve performance.
• Functionality Cookies: Remember your preferences such as language or region to provide a personalized experience.
• Targeting and Advertising Cookies: Track browsing habits to deliver relevant advertising and measure the effectiveness of campaigns.

Your Cookie Choices

You may disable cookies through your browser settings at any time. Note that disabling cookies may affect the functionality of our Website and other sites you visit. For more information on managing cookies, visit
www.allaboutcookies.org.

Where required by law, we will ask for your consent to use non-essential cookies when you first visit our Website.

Payment Information

If you make a purchase through our Website or services, we may collect payment data necessary to process your transaction, such as your payment card number and associated security code. Payment information is processed securely through our payment provider and is not stored on our servers beyond what is required to complete your transaction.

Mobile Messaging – Non-Sharing Clause

No mobile information, including SMS opt-in data and consent, will be shared with third parties or affiliates for marketing or promotional purposes.

Information sharing with subcontractors that support our operations, such as customer service providers, is permitted solely to deliver those services. All such subcontractors are contractually bound to protect your information.

Text messaging originator opt-in data and consent will not be shared with any third parties under any circumstances.

For full details on our SMS messaging program, including opt-in and opt-out procedures, please see our Mobile Messaging Terms of Service at
https://go.directsupportlearning.com/sms-terms/.

Contact Us

Contacting the Supervisory Authority

If you wish to lodge a complaint, contact:

Data Protection Commissioner
Canal House, Station Road, Portarlington
R32 AP23 Co Laois, Ireland
Email: info@dataprotection.ie
Phone: +353 57 8684800