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Privacy Policy

Privacy Policy

1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and company users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4    In this policy, "we”, "us” and "our” refer to our data controller. [For more information about us, see Section 13.]

2. Acknowledgement

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1   In this Section 3 we have set out:

 (a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing

3.2    We may process data about your use of our website and services ("usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. Our legitimate interests, namely monitoring and improving our website and services.

3.3    We may process your account data. The account data may include your name, email address, postal address, contact phone number and dietary preferences. The source of the account data is you, your employer or a person you have authorised to book you a place on one of our courses. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4    We may process your information included in your personal profile on our website ("profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of generating invoices and receipts, enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

3.5    We may process your personal data that are provided in the course of the use of our services ("service data”). The source of the service data is you, your employer or a person you have authorised to book you a place on one of our courses. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.6    We may process information that you post for publication on our website (eg the workshop listing) or through our services ("publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.7    We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you.

3.8    We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data”). The transaction data may include your contact details, your card details and the transaction details. We use SecureTrading Financial Services Ltd as transaction service provider. (Please see section 4.4). The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.9    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.10 We may process information contained in or relating to any communication that you send to us ("correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.11 We may process data. This data may include course application or purchase details. The source of this data is your application details. This data may be processed for application purposes. The legal basis for this processing is our legitimate interests, namely, your course or coaching application or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.13  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks.

3.14  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.15  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3.16 Our website is not intended for young people under 16 years of age. We will never knowingly gather or use personally identifiable information from anyone under the age of 16. No person under the age of 16 is allowed to register on this website.

4.    Providing your personal data to others

4.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, associated centres and faculties, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3    We may disclose relevant data to our suppliers or subcontractors insofar as reasonably necessary for the purposes of supplying services such as training, consultancy and coaching.

4.4    Financial transactions relating to our website and services are or may be handled by our payment services providers, (our Bank and/or SecureTrading Financial Services Ltd) We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the SecureTrading Financial Services Ltd payment services at:  http://www.securetradingfs.com/privacy/

4.5    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.7    We use a number of different services to communicate with members and event delegates. This includes Constant Contact. See: Constant Contact privacy Policy

4.8 For the purposes of health and safety, event venues may be provided with a register of delegate’s names. Event caterers may be provided with a list of delegate names and dietary requirements.

4.9 For the purposes of website maintenance, our website consultants, may have access to sufficient data to undertake website maintenance.

4.10 For the purposes of undertaking surveys we use SurveyMonkey. See: SurveyMonkey Privacy Policy

5.    International transfers of your personal data

5.1    In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2    We are based in the United Kingdom. The European Commission has made an "adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from their website.

5.3    The website hosting facilities are supplied by Wilson Digital Media Ltd. See www.wilsondigital.co.uk. The European Commission has made an "adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.4    Our contractors are situated in the European Economic Area. The European Commission has made an "adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.5 For the purposes of email communications we may use Constant Contact Inc. who are based in California, USA. Their privacy policy can be seen on: www.constantcontact.com/legal/privacy-statement

Constant Contact Inc. is committed to achieving compliance with the GDPR by May 25^th, 2018.

5.6    You acknowledge that personal data that you submit for publication through the link on our website to twitter or facebook may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6.    Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will retain your personal data as follows:

(a)   Basic personal data (e.g., account data) relating to subscriptions and event applications shall not be kept for longer than is necessary for that purpose or those purposes.

6.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)   The period of retention of account data will be determined based on what is considered reasonable.

6.5    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.    Amendments

7.1    We may update this policy from time to time by publishing a new version on our website.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3    We may notify you of changes to this policy by email.

8. Your rights

8.1    In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;