Privacy

Circl Learning Limited Privacy Policy

 

Circl Learning Limited  is the controller and responsible for your personal data (collectively referred to as the Circl, Company, "we", "us" or "our" in this privacy notice).

 

The purpose of this Privacy Policy is to inform you of the types of personal information which we collect from you and how we use your personal information.

 

Changes to the privacy notice and your duty to inform us of changes

 

This version was last updated on 26th February 2020 and historic versions can be obtained by contacting us.

 

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.

 

Our policy

 

It is important that you read this privacy notice together with any other privacy notice, fair processing notice or privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

 

We collect personal information from:

 

  • Potential Clients
  • Clients
  • Course Participants

 

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, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

 

·       avail of our products or services;

 

·       create an account on our website;

 

·       subscribe to our service or publications;

 

·       request marketing to be sent to you;

 

·       enter a competition, promotion or survey; or

 

·       give us some feedback.

 

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

 

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.

 

Technical Data from the following parties:

 

·             analytics providers;  

 

·             advertising networks; and

 

·             search information providers.

 

Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

 

Identity and Contact Data from data brokers or aggregators.

 

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.

 

 

The data we collect about you

 

Personal data, or personal information, 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).

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

 

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

 

Contact Data includes billing address, delivery address, email address and telephone numbers.

 

Financial Data includes bank account and payment card details.

 

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

 

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 our 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 also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

 

Special categories of personal data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data. In limited circumstances, we collect special categories of personal data (mostly about your health) about you if you provide this information to us which allows us assess your dietary needs.

 

How we use your information

 

We will only use your personal data when the law allows us to. 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.

 

·       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.

 

·       Where we need to comply with a legal or regulatory obligation.

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

When someone visits www.circl.org we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

 

Potential Clients

 

When we receive an enquiry from you about our courses, we record your contact details including name, job title, business telephone number, email and postal address. We record this personal information in an electronic database and / or manual files in order to provide you with the information which you are seeking and also to follow up with you to enquire as to whether you have any questions or if you require any further information from us. Each time we contact you, we record a brief note on the file of the status of you enquiry.

 

We will make contact with you at monthly intervals unless we are asked not to make contact again. In such a case, we will record this information on our system and ensure that your wishes are respected. Occasionally, we may send you newsletters unless you request us not to send you such communications.

 

Clients

 

Once a potential client becomes a client, we will use your personal information on the client record for the purposes of managing the business relationship with you. This may also include us contacting you on a monthly basis and making a record of such contact on our systems. Occasionally, we may send you newsletters unless you request us not to send you such communications.

 

You can ask us to stop sending you marketing messages and/or newsletters at any time by contacting us at any time.

 

Where you opt out of receiving marketing messages and/or newsletters, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

 

Course Participants

 

Once a course has been booked, we collect personal information on the participants(s) from the client representative making the booking or from the participants directly. This including technical, profile, and usage data for the training course.

 

In some circumstances, depending on agreements made between us and our clients and / or participants, feedback (written or oral) may be provided to the participant directly and / or to the client.

 

Under no circumstances, unless required by law or regulatory body, will we pass your personal information to any third parties, with the exception of our contractors who need such personal information to assist us in performing our contracts with our clients. We have contractual protections in place to protect any of your personal information which we need to disclose to our contractors.

 

We take our obligations to protect your personal information seriously. Should you have any questions about privacy at Circl, please contact us.

 

Why does Circl need to collect and store personal data?

 

In order for us to provide you with information about our services, we need to collect personal data for correspondence purposes and/or detailed service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

 

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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

In terms of being contacted for marketing purposes Circl would contact you for additional consent.

 

If you fail to provide personal data

 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide these 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.

 

Will Circl share my personal data with anyone else?

 

We may pass your personal data on to third-party service providers contracted to Circl in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with our procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

 

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.

 

How will Circl use the personal data it collects about me?

 

Circl will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Circl is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

 

In some circumstances you can ask us to delete your data and in some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

Under what circumstances will Circl contact me?

 

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

 

Can I find out the personal data that the organisation holds about me?

 

Circl at your request, can confirm what information we hold about you and how it is processed. If Circl does hold personal data about you, you can request the following information:

 

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Circl or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • How long the data will be stored.

 

·        Request transfer of your personal data

 

  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter      into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.

 

Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.If you wish to exercise any of the rights set out above, please contact us.

 

What forms of ID will I need to provide in order to access this?

 

Circl will need two of the following forms of ID when information on your personal data is requested:

 

Passport, driving licence, birth certificate, utility bill or bank statement from the last 3 months, rent book.

 

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.

 

International transfers

 

Some of our third parties may be based outside the European Economic Area (EEA) so the processing of your personal data may involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

 

·       Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.  

 

·       Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

Third-party links

 

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

 

Changes to the privacy notice and your duty to inform us of changes

 

This version was last updated on 26th February 2020 and historic versions can be obtained by contacting us.

 

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.

 

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. Contact details of the Data Protection Officer:

 

Data Protection Officer contact details

 

Contact Name: Charlie Stainforth

 

Address line 1: 321 Market Place

 

Address line 2: Cirencester

 

Address line 3: GL7 2NX

 

Email: hello@circl.org

 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.

 

No fee usually required

 

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 may refuse to comply with your request in these circumstances.

 

What we may need from you

 

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.

 

Time limit to respond

 

We try to respond to all legitimate requests within one month. Occasionally it may 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.