This policy applies to information I collect about Individuals who are:
- Visitors to the website;
- People who contact us through this website, email or any other manner;
- People who use our services (Clients).
For the purpose of this document Clients will be referred to as individuals who use and receive our services and Customers will be referred to as companies, organisations and other legal entities that may be the payees of our services for their employees or third-party contractors.
The purposes of processing
Personal data is collected in order for EDC51 LTD, 71-75 Shelton Street, London, United Kingdom, WC2H 9JQ (hereinafter “EDC51” or “we”) to provide services to Clients, as well as for the following purposes: contacting people based on their enquiries, spam protection, analytics, managing contacts and sending messages.
Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, not accepting cookies may influence your experience using the site.
To find out more about how to handle cookies, please visit Google’s site here:
Search queries and results are logged anonymously to help improve our website and search functionality, no user-specific data is collected by us.
People who contact us
Contacting us may include emailing us or filling out the contact form on our website. By filling in the contact form or sending us an email with your personal data, you authorise this website and us to use these details for the purpose of replying to requests for information, quotes or any other kind of request as indicated in the email or by filling out the contact form. Any email sent to us, including any attachments, may be monitored and used by us for reasons of security. Email monitoring or blocking software may also be used.
Clients are considered all individuals that are users of our coaching, training or any other service, even in the case if and when the payee of the service (i.e. our Customer) is another party, such as, but not exclusive to their employer.
Clients’ personal information that we obtain
Personal information means any information about an individual from which that person can be identified. We may obtain, use, store and transfer different kinds of personal information about our Clients. Personal information that we store will usually be limited to:
- Identity and contact information, which may include your name, title, email address, postal address, telephone numbers, etc.
- Other information that may be specific to the service provided (e.g. assessments, tests, evaluations).
How we use Clients’ personal information
We use Clients’ personal information for the purpose of conducting of our services and meeting our professional and business obligations that we may have in relation to our Clients and our Customers.
The data is processed at our operating offices and in any other places where the parties involved in the processing are located.
Depending on the location of the parties, data transfers may involve transferring the data to a country other than UK. The location of data transfer will also depend on Individual’s location at the time. Individuals are also entitled to learn about the legal basis of data transfers to a country outside the European Union and about the security measures taken by us to safeguard your data.
We may use cloud service provider(s) to store data with, whereby we shall exercise care in using cloud service provider(s) with data protection policies in compliance with the EU principle and GDPR.
Personal information shall be processed and stored for as long as required by the purpose it has been collected for.
Personal data collected for purposes related to the performance of a contract between EDC51 and a customer that may involve the services relating to the Client shall be retained until such contract has been fully performed.
Personal data collected for the purposes of our legitimate interests shall be retained as long as needed to fulfil such purposes. You may find specific information regarding the legitimate interests pursued by us within the relevant sections of this document or by contacting us.
We may be allowed to retain personal data for a longer period whenever have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
You have the following rights:
- Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your personal data.
- Request access to your personal information (commonly known as a “data subject access request”). You can request a copy of your personal information that we hold and check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to request for any incomplete or inaccurate data I hold about you corrected.
- Request erasure of your personal information. You may ask us to delete or remove personal information 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 law.
- Object to processing of personal information where we are relying on our legitimate interests (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.
- Request restriction of processing of your personal information. You may ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’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 information but we need to verify whether we have overriding legitimate interest to use it.
These rights are subject to various legal exceptions. If you make any of the requests above, we would explain to you in our response if we have relied upon any of these exceptions.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). Full details can be found on the ICO’s website www.ico.org.uk. However, if you have any concerns, we would be grateful for a chance to deal with these before you approach the ICO.
If you have any questions or concerns about my use of your personal information, please contact us here.
Changes to this privacy notice
We keep this privacy notice under regular review also with the aim to reflect changes in law and practice.
Date: July 2018