1. Information We May Process
Personal Information means information that is about any individual, or from which any individual is directly or indirectly identifiable.
Process, processing or processed means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We may process the following categories of Personal Information about you:
- Personal details: your name; courses of interest.
- Accessibility information: assisted learning requirements; catering requirements.
- Contact details: postal address; telephone and/or mobile number; email address.
- Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
- Course details: records of course bookings; invoice records; payment records; billing address; payment method; payment amount; and payment date; *we do not record card payment details*
- Course feedback & opinions: any course feedback and opinions that you or other users choose to send to us, or publicly post about us on social media platforms.
We may also collect other kinds of information which we refer to as Other Information in this Policy, which may include but is not limited to:
- Information about your interactions with our website and course attendance, such as usage data and statistical information, which will be anonymised.
- Browsing history including the websites or other services you visited before interacting with the our website.
- Non-precise information about the approximate physical location (for example, at the city or country level) of a user’s computer or device derived from the IP address of such computer or device.
- Internet Protocol (IP) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
- Device type, settings and software used.
- Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customised links.
- Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a mailing service.
- Local storage objects such as browser cookies.
- Embedded Scripts which are programming codes designed to collect information about your interactions with our website by temporarily downloading onto your device from our web server or a third party service like Youtube or Google Maps. These scripts are only active while you are connected to our website and are deleted or deactivated thereafter.
Personal Information together with Other Information is hereinafter referred to as User Information.
2. Sensitive Information
We do NOT collect or otherwise process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR in the ordinary course of our business. Where it becomes necessary to process Sensitive Information under GDPR, we would rely on one of the following legal bases:
- Compliance with applicable law: We may process your Sensitive Information where the processing is required or permitted by applicable law;
- Detection and prevention of crime: We may process your Sensitive Information where the processing is necessary for the detection or prevention of a crime;
- Establishment, exercise or defense of legal rights: We may process your Sensitive Information where the processing is necessary for the establishment, exercise or defense of legal rights;
- Consent: We may process your Sensitive Information where we have, in accordance with applicable law, obtained your prior, express consent prior to processing your Sensitive Information.
With regards to children, our training services, and therefore our website, are not intended for use by children, especially those under 17. No one under the age of 17 should provide any Personal Information. Minors under the age of 17 are not permitted to make bookings through the website and attend training courses. If it is discovered that we have collected information from anyone under the age of 17 years old, we will delete that information immediately.
3. How We Collect or Create Information
We may collect User Information about you from the following sources:
- Data you provide: We may obtain your Personal Information when you provide it to us across our website (e.g., when you book on a training course; where you sign up for emails or newsletters; provide course feedback or opinions; contact us via email, telephone or by any other means, etc.).
- Business relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you attend a course with us).
- Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us).
- Service data: We may collect or obtain your Personal Information when you visit, use or book a training course via our website or over the phone.
- Content and advertising information: If you choose to interact with any third party content or advertising on the Channels, we may receive User Information about you from the relevant third party.
- Third party information: We may collect or obtain information from service providers and third parties who provide it to us. This may include channels such as social network sites or services (e.g., Facebook, Twitter, Mailchimp, etc.). We may also obtain information about course bookings you make from our billing processors such as Stripe and PayPal including information about the status of a payment.
We may also create User Information about you, such as records of your interactions with us and details of your course booking history, for internal administrative purposes only.
4. Purposes for Which We May Process Your Information
The purposes for which we may process User Information, subject to applicable law, include:
- Provision of our website: (i) offering of training course information, (ii) processing of your course booking information, (iii) management of your course booking, (iv) offering promotional information to you, and (v) customer support and relationship management.
- Delivery of training courses: operating and managing the training course for you; in some cases, providing personalised content to you; communicating and interacting with you during and post course; identifying required content changes with the training course and planning bespoke training; and notifying you of changes to any course date or venue.
- Course Feedback: engaging with you for the purposes of obtaining your opinions and views on our training courses.
- Communications: communicating with you via any means (including via email, telephone or social media) regarding information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent. We may provide direct marketing to you as set out in Section 5 below.
- Advertising: providing advertising based on your training course attendance.
- Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels.
- User Engagement and Purchases: tracking course interest traffic and activity across our website; provision of analytics and measurement of cost of traffic against money being made.
- Fraud Prevention: Our payment gateway uses third party fraud prevention software designed to prevent your credit card and other Personal Information from being used in a fraudulent purchase through our website. This offering works by analysing user behavior and detecting patterns that indicate fraud; these third parties may also track your activity over time and over a network of sites.
- Marketing to Customers: We may market to current customers who have indicated an interest in doing business with, or have previously conducted business with, Web Studio Training in order to further generate and promote our courses. Such efforts include sending opt-in marketing emails to drive the use of courses offered by Web Studio Training.
- IT Administration: administration of Web Studio Training’s information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
- Financial Management: general business and financial management purposes, including: economic, financial and administrative management; planning and reporting; sales; accounting; finance; corporate audit; and compliance with legal requirements
- Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
- Legal Proceedings: establishing, exercising and defending legal rights.
- Legal Compliance: Subject to applicable law, we reserve the right to release information concerning any user when we have grounds to believe that the user is in violation of applicable law or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, discovery requests and otherwise as required by law or regulatory obligations. We also may release information about users when we believe in good faith that such release is in the interest of protecting the rights, property, safety or security of Web Studio Training, any of our users or the public, or to respond to an emergency.
5. Direct Marketing
Only when requested (opt-in), we may process your User Information to contact you via email or other methods of communication to provide you with information regarding training courses that may be of interest to you. We may send information to you regarding the courses, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of response only.
6. Cookies, Tracking Technologies and Online Advertising
Tracking technologies on our website may be deployed by Web Studio Training and/or by our service providers. Certain tracking technologies enable us to anonymously assign a unique identifier to you, and relate information about your use of our website. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of providing you with relevant content.
We and our service partners (including but not limited to analytics providers) also may use technologies such as pixel tags, IP addresses, and Local Storage within HTML5 to analyse trends; administer our website; collect and store information such as user settings and anonymous browser identifiers; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around our website; gather demographic information about our user base; and to improve our understanding of traffic on our website and visitor behavior. We may receive reports based on the use of these technologies by these third party companies on an individual and aggregated basis. Various browsers offer their own management tools for removing Local Storage.
7. What is the Lawful Basis for Processing Personal Information
In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:
- Consent: We may process your User Information where we have obtained your prior, express consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way);
- Contractual necessity: We may Process your User Information where the Processing is necessary in connection with any contract that you may enter into with us;
- Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law;
- Vital interests: We may process your User Information where the processing is necessary to protect the vital interests of any individual;
- Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests or fundamental rights.
8. What Information We Disclose to Third Parties
We may disclose your User Information to Web Studio Training staff for legitimate business purposes (including operating the website, and providing training courses to you), in accordance with applicable law. In addition, we may disclose your User Information to:
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
- third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements noted in Section 7;
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
- any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
With respect to course feedback, in the event that responses are publicly disclosed, users will be notified at the time they make the feedback. Otherwise we will disclose only aggregate information regarding responses to feedback. Where feedbacks allow users to submit written comments, Web Studio Training will advise users of the possibility of such disclosure at the time. If we engage a third-party Processor to process your User Information, the Processor will be subject to binding contractual obligations to: (i) only process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.
9. Data Security
We have implemented appropriate technical and organisational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer (SSL) encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.
10. Data Accuracy
We take every reasonable step to ensure that your User Information that we process is accurate and, where necessary, kept up to date, and any of your User Information that we process that you inform us is inaccurate (having regard to the purposes for which they are processed) is erased or rectified.
11. Data Minimisation
We take every reasonable step to ensure that your User Information that we process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you to the website or access to the training courses.
12. Data Retention
We take every reasonable step to ensure that your User Information is only processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period.
Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need. Invoicing information will be maintained until invoices are settled in full and for accounting purposes the end of the financial period.
13. What Can You Do to Control Your Information?
If you are an EU resident, you may have certain rights including: the right not to provide your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of processing, of your Personal Information; the right to object to the processing of your Personal Information; the right to have your Personal Information transferred to another controller; the right to withdraw consent; and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.
You may directly take steps to change your preferences as follows:
- Your Email Subscriptions: You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. For training course correspondence, email communications are an integral part of informing you of course information and billing. You may continue to receive emails as part of that particular portion of the Services unless you cancel your booking. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.
- Pixel Tags and Cookies: You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you turn off, purge, or disable cookies or pixel tags, although you may still use the website, you may not be able to use all of the features, functions, or services available. There are currently (18th May 2018) no features of the website that are restricted in this way.
14. Contact Details
If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of User Information carried out by us, or on our behalf, please contact:
You may contact us at the addresses set out below or by emailing email@example.com
Web Studio Training
The Ingenuity Centre
If you are an EU resident, you may contact our Data Protection Officer at firstname.lastname@example.org