Privacy Policy
Policy version: 14 December 2023
1 INTRODUCTION
This Privacy Policy is provided by Compliance Learning & Development Limited trading as ComplianceLnD, a company registered in England and Wales under company number: 15303188 with its registered office at Bromley Old Town Hall, 30 Tweedy Road, Bromley, England, BR1 3FE (‘we’, ‘our’ or ‘us’) for use of our website www.compliancelnd.com, including the provision of products and services that may be offered via our website (Services).
Compliance Learning & Development Limited is registered with the Information Commissioner’s Office (ICO) as a Data Controller, Registration Number ZB634364. We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data). It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
2 WHAT THIS POLICY APPLIES TO
This privacy policy relates to your use of the Services only. This privacy policy applies only when we are the data controller of your personal data and explains how we use your personal data for our own purposes. For example, this privacy policy covers when you:
- visit our website that links to this privacy policy
- contact us with an enquiry about our products or services
- interact with us as a representative of a company that is one of our corporate clients
- enter into a contract with us for products or services where you act as an individual (rather than on behalf of a company)
- provide us with feedback about our products or services
- receive a sales or marketing communication from us
This privacy policy does not cover how we process personal data on behalf of our corporate clients as a data processor. If you are an employee of a company that uses our products or services and you have questions or concerns about the personal data we process on behalf of your employer (when we are a data processor), please direct your request to your employer.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
3 PERSONAL DATA WE COLLECT ABOUT YOU
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:
Customer account data
When you purchase products or services from us (e.g. completing a course offered via our website), we may collect the following information from you:
- Customer identity and contact details: name, date of birth, email address, home address and phone number
- Customer profile data: purchase history, course attendance and completion information, and qualifications, and preferences
- Customer billing data (to support the processing of payments and provide such information to third party payment processors): billing address, account and card information
If you are a representative of a company that is one of our corporate clients, we may collect your business contact information, including your company name and job title.
Identity and contact data
When you otherwise interact with us (e.g. enquiring about our products or services), we may collect the following information from you:
- name, email address and phone number
If you are a representative of a company that is one of our corporate clients, we may collect your business contact information, including your company name and job title.
Usage data
When you access our Services, we may automatically collect certain information about your device and usage. Usage data may include:
- information about how you access and use our Services, including device information, browser information, information about your network connection, online identifiers such as cookie data and your IP addresses, your preferences, interests, time of use and other usage and technical information regarding your interaction with the Services (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)
Marketing and communications data
When you sign-up to receive marketing communications or are an existing customer of ours, we may collect information about your preferences, including:
- marketing preferences and service communication preferences
Social media information
When you engage with us via social media, we may collect information, including:
- your username, name, and any other personal data which is publicly available or which you share with us
Customer events, feedback and comments
When you engage with us via any event, forum, comment, or other feedback functionality via our website, we may collect information including:
- your name and any views, opinions, suggestions, or other information you choose to share with us when sending a message through the Services.
- your photograph (e.g. we may capture photographs at events that feature identifiable individuals)
- testimonials attributed to you (e.g. you may provide testimonials after events or purchasing our products or services)
If you do not provide personal data we ask for where it is required, it may prevent us from providing services to you. We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
4 SENSITIVE DATA
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us. If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.
5 HOW YOUR PERSONAL DATA IS COLLECTED
We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, attend events hosted by us, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.
We also collect certain information automatically related to your use of the Services. Some of this information may be collected using cookies and similar tracking technology; while such data may not always be personal data as defined at law in all cases, we will assume it is and treat it in accordance with this policy as if it were. Please refer to our Cookies Policy for further information.
We may also obtain personal data about you from third parties, including service providers who may collect information on our behalf; for example, companies who support our website and Services. Any information we receive from third parties will be treated in accordance with this policy. We are not responsible for the accuracy of any information provided to us by third parties and we are not responsible for any third party’s policies.
6 HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
(i) where you have given consent
(ii) to comply with our legal and regulatory obligations
(iii) for the performance of a contract with you or to take steps at your request before entering into a contract, or
(iv) for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The following explains what we use your personal data for and why.
Providing services and/or the functionalities of the Services to you
To perform our contract with you or to take steps at your request before entering into a contract.
To evidence completion of our products (e.g. courses and qualifications provided by us)
Depending on the circumstances:
- to perform our contract with you
- for our legitimate interests i.e. to verify and maintain records of course completion for administrative or accreditation purposes
- to comply with our legal and regulatory obligations
To enforce legal rights or defend or undertake legal proceedings (e.g. in connection with civil, commercial, criminal or consumer protection matters, regulatory matters, corporate and taxation matters, or to exercise our legal rights in relation to a violation of any of our terms or policies)
Depending on the circumstances:
- to comply with our legal and regulatory obligations
- in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing (e.g. we use certain information to send you administrative or service related information including about changes to our terms or policies or changes to the services or other important notices)
Depending on the circumstances:
- to comply with our legal and regulatory obligations
- in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data (e.g. taking steps to detect, investigate and otherwise protect against intellectual property infringement, crime, suspected fraud, suspected violations of our terms and safety and security risks of all kinds).
To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.
Operational reasons (e.g. improving efficiency, training, and quality control or to provide support to you)
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you.
Statistical analysis to help us manage our business (e.g. in relation to our performance, customer base, and functionalities and offerings or other efficiency measures)
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our website and services
Marketing and advertising (please see the ‘Marketing’ section below for additional information)
Depending on the circumstances:
- with your consent i.e. where the law requires us to collect your consent e.g. when we use cookies to understand your interests or the law requires consent for email marketing
- for our legitimate interests i.e. for other marketing, promotion and advertising where the law does not require consent e.g. to better tailor the Services to you
Promotional purposes (e.g. using photographs from events or testimonials on our website)
For our legitimate interests i.e. to promote and market our products and services and future events.
Updating and enhancing user records
Depending on the circumstances:
- to perform our contract with you or to take steps at your request before entering into a contract
- to comply with our legal and regulatory obligations
- where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services.
To comply with our legal and regulatory obligations (e.g. to verify your identity, in response to lawful requests by public authorities (including tax authorities) and to meet law enforcement requirements)
Depending on the circumstances:
- to perform our contract with you or to take steps at your request before entering into a contract
- to comply with our legal and regulatory obligations
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring(e.g. including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency)
Depending on the circumstances:
- to comply with our legal and regulatory obligations
- in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets
In such cases information will be anonymised where possible and only shared where necessary
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
7 MARKETING
We intend to send you email marketing to inform you of our services such as promotions. We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:
- contacting us at contact@compliancelnd.com
- using an ‘unsubscribe’ link included in marketing emails you may receive from us
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes (except, we may share your personal data with selected third parties for marketing purposes where you have given your consent to do so). For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
8 WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including associate consultants, business partners, vendors, payment processors, or other third parties who perform services on our behalf (e.g. IT services, website developers, cloud storage).
We may also share your personal data with selected third parties for marketing purposes but only where you consent to us sharing your information (e.g. where you consent to this via an event registration form). We only allow service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
- external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors) — the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below). We will not share your personal data with any other third party.
9 HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We retain your personal data for as long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested, to evidence your completion of courses, or to comply with applicable legal, tax or accounting requirements). The criteria used to determine appropriate retention periods for personal information include:
- the length of time we have an ongoing business relationship with you
- the amount and nature of the personal data we process
- whether we have a legal obligation to retain personal information or whether retaining personal data is necessary to resolve disputes, including the establishment, exercise or defence of legal claims
When we have no ongoing legitimate business need to process your personal information, we will delete or anonymise your personal data.
10 TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
We comply with applicable legal requirements when we need to transfer, store or process your personal data outside the UK.
Under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we transfer your personal data from the UK to:
- The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
- Any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
11 YOUR RIGHTS
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
(a) Access to a copy of your personal data - The right to be provided with a copy of your personal data.
(b) Correction (also known as rectification) - The right to require us to correct any mistakes in your personal data.
(c) Erasure (also known as the right to be forgotten) - The right to require us to delete your personal data - in certain situations.
(d) Restriction of use - The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
(e) Data portability - The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations.
(f) To object to use - The right to object:
- at any time to your personal data being used for direct marketing (including profiling)
- in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
(g) Not to be subject to decisions without human involvement - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by the Services.
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please complete a request form - available on our website at www.compliancelnd.com or email, or write to us - see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
12 KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have processes in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
13 HOW TO COMPLAIN
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
14 CHANGES TO THIS PRIVACY POLICY
We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you, for example via a website publication, the Services or by other means, such as email.
15 HOW TO CONTACT US
You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Compliance Learning & Development Limited
Bromley Old Town Hall,
30 Tweedy Road,
Bromley,
BR13FE