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We collect and process personal information so we can provide our Services to you. It's 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 and process about you is explained in the sections below.
1.1 Data you give us
- 1.1.1 You give us information about you by filling in forms on our Sites or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use one of our Sites, request a quote, subscribe to our marketing database, subscribe to our services, or place an order on a Site. Although it is not personally identifiable information, note that we also collect data about users' performance on our preparation and/or assessment services.
- 1.1.2 For general users, the information you give us includes your full name, email address or login details, payment information, current level of career experience and any assessment(s) you are preparing for.
- 1.1.3 In addition to the data you provide during registration, we may request verification of your identity at any time, including supporting documentation to confirm your name, email address, and that you are using our Site for personal (non-commercial) purposes.
- 1.1.4 This data is necessary for our legitimate interests and for us to fulfil our contractual obligations to you, and we rely on this as a lawful basis to use and process the data described above.
1.2. Data we automatically collect
- 1.2.1 Each time you visit or use a Site, we automatically collect the following information:
- 1.2.1.1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform;
- 1.2.1.2. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Sites (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- 1.2.2 We use this information as statistical data about your browsing actions and patterns, for system administration, and to evaluate, provide, protect or improve our Services (including by developing new products and services). We also use this data to:
- 1.2.2.1 Monitor usage patterns to detect potential breaches of our Terms & Conditions;
- 1.2.2.2 Identify commercial or competitive use of our Site;
- 1.2.2.3 Investigate suspected false identities or misrepresentations;
- 1.2.2.4 Analyse usage patterns to distinguish personal training use from commercial intelligence gathering.
- 1.2.3 Because we collect, use and share aggregated statistical information, it does not identify any individual. However, where we detect potential breaches of our Terms & Conditions, we may analyse individual usage data and account information to investigate the breach.
1.3. Data we receive from third parties
- 1.3.1 We use third parties such as Stripe (for payment facilitation) and Mailchimp and Mandrill (for marketing automation). For more information on how these companies handle your personal data, please refer to their privacy policies.
2.1 We use your data to carry out our Sites and Services in the following ways:
- 2.1.1 To administer and manage your account, to provide you with information you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.
- 2.1.2 To ensure that content from our Sites is presented in the most effective manner for you and for your device.
- 2.1.3 To allow you to participate in interactive features of our Service when you choose to do so.
- 2.1.4 To respond to communications from you and to provide you with information about our Services, including notifying you about changes to our Sites or Services.
- 2.1.5 To verify your identity, detect breaches of our Terms & Conditions, and investigate suspected commercial or competitive misuse of our Site.
2.2 We also use your data to make our Sites and Services better in the following ways:
- 2.2.1 To administer the Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- 2.2.2 To detect, investigate, and prevent breaches of our Terms & Conditions, including monitoring for commercial use, competitive intelligence gathering, or use of false identities.
2.3 As part of our efforts to keep the Sites safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.
2.4 We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable data protection laws. If you are an existing customer, we will only contact you by electronic means (e-mail) with information about services similar to those which were the subject of a previous enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have expressly consented to this.
2.5 You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us by email at [email protected].
3.1 All of your personal information is protected and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect. Your information is stored on secure cloud databases, internal servers, and on third party softwares. Your information is only accessible by employees who have authorised access rights to such information. All of your payment information is encrypted using SSL technology.
3.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we use strict procedures and the security features described above to try to prevent unauthorised access.
We only keep your personal information for as long as it's necessary for our original legitimate purpose for collecting the information and for as long as we have your permission to keep it.
5.1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. As mentioned above, we use third parties such as Stripe (for payment facilitation) and Mailchimp and Mandrill (for marketing automation). These third parties have access to data we share with their platforms.
5.2. The only other circumstances under which we would share your personal data are:
- 5.2.1 If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
- 5.2.2 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- 5.2.3 If the Site or substantially all of its assets are acquired by a third party, in which case personal data will be one (1) of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.
- 5.2.4 If we're under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of the Site, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
- 5.2.5 To payment processors (including PayPal, Stripe, and others) where you have initiated a payment dispute or chargeback and we need to share information about breaches of our Terms & Conditions to defend our position in that dispute.
- 5.2.6 To law enforcement authorities where we reasonably believe a breach of our Terms & Conditions may constitute a criminal offence (such as under the Computer Misuse Act 1990 or Fraud Act 2006).
- 5.2.7 To our legal advisers in connection with any actual or threatened legal proceedings relating to breaches of our Terms & Conditions.
6.1 Because we use third parties based outside the European Economic Area (EEA), the data that we collect from you may be transferred to or stored at a destination outside the EEA. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated as securely as it would be within the EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of Commission-approved Model Contractual Clauses. 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.
6.2 You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us.
7.1 Where we suspect a breach of our Terms & Conditions, we reserve the right to:
- 7.1.1 Analyse your account information, usage patterns, and any data you have provided to us;
- 7.1.2 Research whether your email address, name, or other identifying information is connected to any commercial entities or competing businesses;
- 7.1.3 Verify the authenticity of the personal information you provided during registration;
- 7.1.4 Request additional verification documents to confirm your identity;
- 7.1.5 Monitor your usage patterns to determine whether use is for personal training or commercial purposes.
7.2 The legal basis for this processing is our legitimate interest in:
- 7.2.1 Protecting our intellectual property and proprietary materials;
- 7.2.2 Enforcing our Terms & Conditions;
- 7.2.3 Preventing commercial espionage and competitive intelligence gathering;
- 7.2.4 Detecting fraud and misrepresentation;
- 7.2.5 Maintaining the integrity of our Site and Services for genuine users.
7.3 Where we identify a breach, we may share relevant information with:
- 7.3.1 Law enforcement authorities if we believe a criminal offence may have been committed;
- 7.3.2 Our legal advisers for the purpose of pursuing legal remedies;
- 7.3.3 Payment processors (such as PayPal) where you have initiated a dispute or chargeback, so they can make an informed decision;
- 7.3.4 Regulatory authorities where required by law.
8.1 Lawful Bases
- 8.1.1 We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one (1) of the following bases applies:
- 8.1.1.1 You have given your clear consent to the processing of your personal data for a specific purpose.
- 8.1.1.2 Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
- 8.1.1.3 Processing is necessary for our compliance with the law.
- 8.1.1.4 Processing is necessary to protect someone's life.
- 8.1.1.5 Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
- 8.1.1.6 Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests. Our legitimate interests include:
- (a) Effectively and efficiently managing and administering the operation of our business;
- (b) Maintaining compliance with internal policies and procedures;
- (c) Monitoring the use of our copyrighted materials and intellectual property;
- (d) Detecting and preventing breaches of our Terms & Conditions;
- (e) Verifying the identity and legitimacy of users;
- (f) Investigating commercial or competitive misuse of our Site;
- (g) Protecting our business from fraud, misrepresentation, and unlawful use;
- (h) Defending payment disputes and chargebacks;
- (i) Offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.
8.2 Data Subject Rights
- 8.2.1 Under the GDPR, you have the right to:
- 8.2.1.1 Withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation or to prevent misuse of the Site).
- 8.2.1.2. Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
- 8.2.1.3. Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
- 8.2.1.4. Correct or supplement any information we hold about you that is incorrect or incomplete.
- 8.2.1.5. Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
- 8.2.1.6. Object to the processing of your data.
- 8.2.1.7. Obtain your data in a portable manner and reuse the information we hold about you.
- 8.2.1.8. Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
- 8.2.1.9. Complain to a supervisory authority (e.g. the Information Commissioner's Office (ICO) in the UK) if you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).
- 8.2.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- 8.2.3 You have the right to ask us not to process your personal data for marketing purposes. We will get your express opt-in consent before we use your data for such purposes or share your personal data with any third parties for such purposes, but you can exercise your right to prevent such processing by contacting us via email at [email protected], or by unsubscribing using the links contained in the marketing emails.
- 8.2.4 You may revoke your consent for us to use your personal data as described in this Privacy Policy at any time by emailing us at [email protected], and we will delete your data from our systems. To enforce any of the above rights, please contact us at via email at [email protected].
- 8.2.5 We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.