1. Important information and who we are
Email address: firstname.lastname@example.org
You have the right to make a complaint at time to relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the Authorities so please contact our DPO.
2. 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 as follows:
• Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender. We may also collect the name and contact details of individual consumers receiving the benefit of our services.
• Contact Data includes billing address, delivery address, email address and telephone numbers. We may also collect details of phone numbers used to call our organisation and the date, time and duration of any calls.
• Employee Data if you work for one of our customers, the information we collect about you may include your contact information, details of your employment and our relationship with you.
• Financial Data we do not store any financial data as all payments are done thru payment gateways and they are the custodian of any financial data.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Visitor Data includes information about your attendance at one of our programs, workshops, events, including the date and time, who you are visiting and the type of event.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may collect in addition Special Categories of Personal Data about you in the following situations:
• Information you provide about your dietary requirements in the booking process for an event for providing appropriate food and beverage.
• Information you provide about your health, including any medical condition, health and sickness records for the purposes of ensuring access at any of our events.
We will only process special categories of personal data when you have provided the data and for the reasons set out above.
We do not collect any information about criminal convictions and offences.
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.
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 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 Identity, Contact and Financial Data by filling in forms or by corresponding with us directly in person (for example at a program, workshop, an event) or by post, phone, email or otherwise or when attending an online webinar. This includes personal data you provide when you:
• attend one of our workshops
• attend one of our events;
• attend one of our online webinar;
• apply for our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a poll, promotion or survey;
• give us feedback or contact us; or
• or your organisation makes a complaint or there is a dispute with you or your organisation
• Visitor Data. When you attend one of our program, workshop or events, we will automatically collect Visitor Data as detailed above.
• Employee Data from your organisation who should have informed you that your information would be provided to us, and provided you with a copy of this policy.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Identity, Contact, and Transaction Data from our business partners and subcontractors providing technical, payment and delivery services and credit information on you from third party reference agencies.
• Identity, Contact Data and Employee Data from publicly available sources such as Companies House, the Electoral Register, your employer website or LinkedIn.
• Identity and Contact Data from a third party (such as our sub-contractors, event trainers and speakers or internally from one of the Anaiah Edutrainment companies) for the purposes of sending you information about our relevant products and services which you might be interested in. If a third party collected your name and contact details, we will give you a fair processing notice and respect any communication preferences you give us.
• Identity, Contact and Transaction Data from one of our group companies, resellers, business partners, joint venture partners and service providers. In this case the relevant group company party will have informed you when we collected the data if we intend to share the data internally.
4. 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 obligation.
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.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||Performance of a contract with you|
|To process and deliver your order including:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) If you are an employee of the organisation that entered a contract with us as necessary for our legitimate interests (in managing our relationship with your organisation)
|To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey
|(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 enable you to take part in a poll, complete a survey or feedback||(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business||(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 advertisements to you andmeasure or understand the effectiveness of theadvertising we serve to you||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 make suggestions and recommendations toyou about goods or services that may be ofinterest to you||Necessary for our legitimate interests (to develop our products/services and grow our business)|
|Collecting and using Visitor Data||Necessary for our legitimate interests in administering your visit, ensuring site security and visitor safety.|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Transaction and Visitor 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 products, 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 goods or services from us and 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 external third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by sending us an email on email@example.com.
When 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.
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 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 the parties set out below for the purposes set out in the table above.
• Internal Third Parties which are other companies in the Anaiah Edutrainment acting as joint controllers or processors and who are based worldwide for the purposes of sharing CRM and finance systems, as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, and for system maintenance support and hosting of data and to provide you with information about products and services we think you might be interested in unless you have opted out of receiving such marketing messages.
• External Third Parties such as our contractors and designated agents so that they can carry out their services. The following activities are carried out by third-party service providers: administration, CRM system, email marketing system, event administration and management, event sponsors, event technology systems, event venues, feedback and review platforms, IT services, payment processing systems, trainers and speakers at events and training partners.
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.
6. International transfers
We share your personal data within the Anaiah Edutrainment Companies and other assocIated companies, . This will involve transferring your data outside India.
Also many of our external third parties are based outside India so their processing of your personal data will involve a transfer of data outside the India
Whenever we transfer your personal data out of India, 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.
• Where we use providers based in the USA /UK / UAE, we may transfer data to them.
7. 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.
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.
8. Data retention
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. 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.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we will 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.
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 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:
• 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.
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 could 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 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.