- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- Important Information And Who We Are
Email address: firstname.lastname@example.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.
This version was last updated in January 2020.
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.
- The Data We Collect About You
Personal data (or personal information), means any information about a living individual where that individual can be identified using all or part of that information. 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 as follows:
- Identity Dataincludes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Dataincludes billing address, residential address, business address, personal email address, business email address and telephone numbers.
- Financial Dataincludes bank account and payment card details.
- Aspiration Dataincludes personal and professional information for the purpose of your development programme such as psychometric results, your development goals, notes regarding your personal and professional situation, concerns and aspirations, your progress and actions.
- Home Life Dataincludes details about your family, financial plans and personality traits.
- Transaction Dataincludes details about payments to and from you and other details of services you have purchased from us.
- Technical Dataincludes 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 Dataincludes your username and password, orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
- Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.
With your explicit consent, we may collect Special Categories of Personal Data about you during the course of our provision of the services to you. The GDPR refers to the processing of ‘special categories of personal data’ and this means personal data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, criminal convictions or offences, political opinions, trade union membership, information about your health and genetic and biometric data (“Sensitive Personal Data”).
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 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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
- 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, Financial Data, Aspiration Data, Home Life Data and Sensitive Personal Data by filling in forms, by corresponding with us (whether by post, phone, email or otherwise) or verbally during the course of our provision of services to you. This includes personal data you provide when you:
a) apply for or order our services;
b) create an account on our website;
c) subscribe to our service, newsletter or publications;
d) request marketing to be sent to you;
e) enter a promotion or survey; or
f) 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. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
- Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:
a) Technical Data from analytics providers, for example, we use a third party service, Google Analytics, to collect standard internet log information about and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of our website. This information is 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 upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it. For more information about how Google Analytics processes data, please see https://policies.google.com/privacy/partners?hl=en-GB&gl=uk.
b) Contact, Financial and Transaction Data from providers of technical and payment services based inside the EU.
c) Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
d) Identity and Contact Data from publicly availably sources such as LinkedIn, Facebook, Twitter and various search engine search results.
- How We Use Your Personal Data
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.
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 that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please contact us about your preferences relating to your personal data use by email to email@example.com
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details for that purpose and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside Rise & Lead Ltd for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers
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 and/or related to the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with and/or related to 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.
- Disclosures Of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties as set out in the Glossary.
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.
- International Transfers
Some of our External Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
We will only transfer data outside of the EEA where it is compliant with data protection laws and the means of transfer providers adequate safeguards in relation to your data, for example:
- By way of data transfer agreement, incorporating the current standard contractual clauses approved by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
- By ensuring that any US-based organisations we transfer data to have signed up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from the EEA to the United States of America (or ensuring that any equivalent framework agreement is in place respect of other jurisdictions); or
- By transferring your data to a country whose data protection laws have been found to be adequate by the European Commission; or
- Where you have expressly consented to the data transfer (having been informed of any relevant risks involved).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Data Security
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.
- Data Retention
How Long Will You Use My Personal Data For?
By law, for tax purposes, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 7 years after they cease being customers.
In some circumstances you can ask us to delete your data: see “Request erasure” below for further information.
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.
- Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
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 two months. 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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 impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means 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.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
- Service providers such as:
- Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third part outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections).
Your Legal Rights
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 and to check that we are lawfully processing it.
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 good 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:
a) if you want us to establish the data’s accuracy;
b) where our use of the data is unlawful but you do not want us to erase it;
c) 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; or
d) 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 services to you. We will advise you if this is the case at the time you withdraw your consent.