Salalem Privacy Policy

Salalem Business Privacy Statement

This Salalem Privacy Statement was updated on 24/01/2022.

In the course of providing Salalem services and related services to its corporate, non-profit organizations and governmental Subscribers (“Subscribers”), Salalem will receive and have access to personal data of individual users to whom subscribers grant access (“Users”). For the purposes of this privacy policy, Subscribers are data controllers and Salalem is a data processor. Salalem’s processing of User data and the security measures implemented to protect such data are governed by this policy.

Salalem will access, store and use the personal data of individual Users solely for the purpose of providing the services to its Subscribers and will process the data as instructed by its Subscribers.

As data controllers, Subscribers decide which of their employees or other authorized personnel are given access to the services. They do this by designating one or more account administrators or group administrators (“Administrator”) who have the ability to customize the Subscriber account, manage individual User accounts, access Insights tool and related reporting features, access the Administrator tools, and, when instructed by the Subscriber, allow access to e-Learning courses. Subscribers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, relating to the collection of personal information relating to individual Users selected by Subscriber for accessing the services. Salalem has no direct relationship with individual Users, who should contact Subscriber (their employer) for assistance with any requests or questions relating to the processing of their personal information.

In the event where Salalem makes any material changes to the manner in which it processes User data to provide its services to Subscribers, it will notify Subscribers.

A. Information about Users collected and stored by Salalem

1. Salalem will collect information provided by the Subscriber in order to set up the Administrator and User accounts. The Subscriber can customize the type of data requested to create an account, which may include the following:

• First name, father’s name, grandfather’s name, last name, and email address required, in both English and Arabic
• Job position
• Department/Sub-department which User belongs to
• Branch which User belongs to
• Name of User’s direct manager
• Gender of User
• Date User has been employed by Subscriber
• Photo, areas of interest, job skills, goals, and role (optionally provided by User or Subscriber)
• Other personal data, as allowed by the Subscriber

2. A unique identifying username is assigned by Salalem upon the creation of a User account.

3. Administrators may assign a User to a group membership.

4. Salalem stores information relating to the activities of Users as they use and interact with the services, such as courses enrolled in and viewed (and information relating to these courses); progress within a course; as well as answers and other items submitted by Users to satisfy the course requirements. This information is linked to a User’s unique account username and is shared with Subscribers via the reporting tools or upon request of the Subscriber.

5. The services enables Users to contact the Salalem Support Team for assistance or to report a problem, concern, potential abuse or other issues regarding the services or other users. Salalem may collect and store the User’s name, email address, location, operating system, IP address as well as the User’s activity on the Salalem platform and communications with the Salalem support team. Salalem may request additional information from Users in order to resolve any issue reported by a User or by another user.

6. When a User uses the services, Salalem collects and stores certain information by automated means: (a) technical information about the User’s computer or wireless device, such as IP address, operating system type and version, unique device ID, browser, browser language, domain, and other operating systems or platform information. This information is collected through the use of server log files and tracking technologies, such as: (i) cookies, which are small files that websites send to a computer or wireless device to uniquely identify a browser or mobile device or to store information in a browser setting; and (ii) other tracking technologies (see below for more detailed information).

8. IP addresses received from browsers or devices of Users may be used to determine the approximate location of Users.

9. In addition, when you enroll in and take courses, we collect certain data including which courses, quizzes you’ve started and completed, answers to questions, and other items submitted to satisfy course requirements.

B. Purpose of User Data Processing and Retention Period

Salalem processes the information collected about Users and Administrators for the purpose of providing the services to its Subscribers, specifically:

• Providing, administering, and facilitating access to the services, for Subscribers and Users, and managing Subscriber or User account preferences
• Fulfilling Subscriber’s instructions with respect to personal data of Users
• Displaying and sending via email notifications to Users for:
• Responding to User questions or concerns
• Making notifications to Users at the request of the Subscriber
• Sending Users administrative messages and information, including confirmation of account creation, course enrolment, course progress and notifications of responses from instructions to User questions
• Providing information to Users about courses available to Users, available and new service features; personalized course recommendations, which Users can opt out of at any time
• Sending push notifications to User wireless devices to provide updates and other relevant messages, which can be managed from the “options” or “settings” page for the mobile application.
• Enabling communications among Users and instructors or teaching assistants
• Soliciting feedback to improve User experience
• Resolving User support requests or claims
• Email Preferences
• Users can individually personalize the way Salalem communicates with them. A Subscriber can also instruct Salalem to configure email preference settings for all Users of a Subscriber.
• Retention of Personal Data
• Salalem will retain the data of Users for as long as instructed by the Subscriber. Salalem will delete certain or all personal data relating to Users upon request of the Subscriber. Salalem may retain aggregated or anonymized data as set forth below.
• Use of aggregated data
• In addition, User data is aggregated with other Salalem user data to enable Salalem to improve its products and services and develop new products and services, including:
• Reviewing and analyzing User browser and wireless device technical information
• Reviewing user activity across the Salalem platform and Services (for example, Salalem analyzes trends and User traffic and usage information to identify which courses are most popular)
• Facilitating the technical functioning of the services, including to troubleshoot and resolve issues, secure the services, and prevent fraud and abuse
• Developing a personalized course content recommendation engine
• When User data is used for the above purposes, it is aggregated and/or anonymized so that no personal data of Users is processed.

C. Cookies and other Tracking Technologies

Like many online platforms, Salalem and its analytics vendors use server log files and automated data collection tools, such as browser cookies. These tools are used for analytics purposes to enable Salalem to understand how Users interact with the services. Salalem and its analytics vendors may tie the information gathered by these means to the unique account ID of Users.

Cookies are small text files placed onto a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about User activities. Salalem uses both session cookies and persistent cookies.

A persistent cookie will remain on a User’s device for a set period of time specified in the cookie. Salalem uses these cookies to identify and recognize a specific User over a longer period of time. They allow Salalem to:

• Analyze the usage of the services (e.g. what links Users click on) in order to improve our services
• Test different versions of the services to see which particular features or content Users prefer to optimize the services
• Provide a more personalized experience to Users with more relevant content and course recommendations and allow Users to more easily log in to use the services.

User Preferences with respect to cookies and other tracking technologies

A User can set his or her web browser to notify about the placement of new cookies, limit the type of cookies or reject cookies altogether; if disabled, a User may not be able to use some or all of the features of the services (for example, may not be able to log in). General information about cookies and how to disable them can be found at www.allaboutcookies.org.

D. Sharing User Information with Sub-Processors

In order to provide the services to its Subscribers, Salalem shares data regarding Users with a number of third party service providers. These companies are contractually required to use User data solely as directed by Salalem for the purpose of providing services to Salalem.

• Other service providers of Subscriber, as instructed by Subscriber.
• To perform its services, Salalem leases servers from data centers operated by Google,Amazon, and Microsoft and located in Frankfurt,Germany.
• Salalem shares User information with third party companies that perform data analysis services to enable Salalem to better understand how Users use the service. These companies include Google Analytics. To prevent Google Analytics from collecting information for analytics, a User may install the Google Analytics Opt-Out Browser.
• Any other sharing of User data is subject to the consent and instructions of Subscriber