- how we look after your personal data; and
- about your privacy rights.
1.Important information and who we are
- to the extent the UK GDPR applies, the law of the United Kingdom or of a part of the United Kingdom which relates to the protection of personal data;
- to the extent the EU GDPR applies, the law of the European Union or any member state of the European Union to which we, or our client, is subject, which relates to the protection of personal data.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller / Processor
Depending on the circumstances in which we receive personal data from either you or other third parties, we will either be processing such personal data in our capacity as a data processor or a data controller.
We are primarily a data processor for the purposes of the Data Protection Legislation, further to processing our customer's personnel information in order to provide our customers with our services.
We will only be a data controller in respect of your personal data if you provide such data directly to us via our website or other direct communication, not related to our provision of services.
- Name: Gavin Keeble
- Email address: email@example.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2.The data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Mostly we process information in relation to companies and not individuals but we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, job title and country of residence.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We do not process financial data as this is managed on our behalf by our third party payment management providers. Please refer to the following privacy notices for more information on how these third parties will process your personal data: Xero Limited – (www.xero.com/uk/legal/privacy/) and Stripe Inc – (https://stripe.com/gb/privacy).
If you fail to provide personal data
Where we need to process personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3.How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for or use our products or services;
- make an enquiry on our website;
- subscribe to our publications or request marketing to be sent to you; or
- give us feedback or contact us.
Indirect interactions. For example if your employer or an event organiser does any of the above on your behalf or we obtain your details via a third party marketing company.
4.How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into, or, have entered into, with you. This applies to processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 'Legitimate Interest' means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the negative impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Where we need to comply with a legal obligation which includes processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note: we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||
|Performance of a contract with you|
|To allow us to tailor and deliver our services to you as a customer||
|Performance of a contract with you|
|To process and deliver your order including:||
(c) Marketing and Communications
|(a) Performance of a contract with you|
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you||
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
Our website utilises CookieBot which collects and assists us in collecting your personal data when you visit our website. For more information surrounding CookieBot, please see www.cookiebot.com/en/about/.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions where we still have a lawful basis for processing such personal data.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5.Disclosures of your personal data
We may share your personal data with a number of third parties for the purposes set out in section 4 of this policy. These include but are not limited to:
- Fly Marketing Ltd t/a Fly. Fly are a marketing technology company that assist us with the maintenance and development of our website as well as various other marketing development matters and they supply us with hosting services. For more information surrounding Fly and how they or their sub-contractors may process your personal data, please contact Fly directly (https://www.talk2fly.com/);
- Server hosting providers such as Google Cloud, Amazon Web Services and Microsoft Azure (in which such servers are hosted in the UK)
- Other service providers such as Zoom, Microsoft Teams, Google Meet, Google Sheets or Blue Jeans; and
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
If you have any concerns as to who the third parties are that process your personal data and/or how such third parties may be using any personal data we share with them, please contact us directly.
Many of our external third party suppliers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it (and that we comply with Data Protection Legislation) by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data either the same, or very similar, protection to which it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected or actual personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements where this applies. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or we have a contractual reason for so doing and we are acting as a data processor and not a data controller.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We will keep personal data (including but not limited to Contact, Identity and Profile) relating to our customers and their personnel, for a period of 10 years. We hold this personal data for this period (unless a request is made by you to destroy or return such data) in order to provide such individuals with access to our post-programme learning support portal.
We will keep all other personal data that we receive either: through enquiries made to us via our website, email correspondence or telephone; or from our third party suppliers (e.g. SoPro), for a period of five years. We hold this personal data for this period (unless a request is made by you to destroy or return such data) in order to make suggestions and recommendations to you about particular services that may be of interest to you.
Please note, we also keep basic information about our customers (including but not limited to Contact, Identity) by law for 6 years after they cease being customers for tax purposes.
9.Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no lawful reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, 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 you wish to exercise any of the rights set out above, please contact us directly.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
SECONDNATURE INTERNATIONAL LIMITED