Privacy Policy & Cookies
Why you should read this policy
We ask that you read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
Our app [ link] (App) is operated by Sevenhill Group Limited. We are a training development consultancy specialising in team and behavioural training, incorporated and registered in England and Wales under company number 05626962, whose registered office address is at Foxley Barn, Church Road, Tadley, Hampshire, RG26 3AU.
Sevenhill Group (‘We’ or ‘us’) collect, use and are responsible for certain personal information about you. When we do so we are regulated under various UK laws, including the UK General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and the Data Protection Act 2018. We are responsible as ‘controller’ in respect of some of that personal information (see below) for the purposes of those laws and we are responsible as ‘processor’ for other parts of that personal information. Your employer is also the ‘data controller’ of that personal information. Please see your employer’s Privacy Policy for further information regarding their processing of the personal data that they obtain via the App.
Our data protection officer is Jane Ansell and she can be contacted by email at: [email protected]
Our collection and use of your personal information
Information that you provide
We may collect personal information about you when you USE THE APP, SEND FEEDBACK, POST MATERIAL, CONTACT US FOR ANY REASON AND BY ANY MEDIUM, SIGN UP TO A SERVICE, SHARE INFORMATION VIA THE APP’S SOCIAL MEDIA FUNCTIONS, OR REPORT A PROBLEM WITH THE APP.
We collect this personal information from you either directly, such as when you contact us via our App or indirectly, such as your browsing activity while on our App.
We collect data that is specifically and voluntarily provided by a visitor to our App. In most circumstances, this data includes limited identifiable information. Where we store any information collected via our App we will ensure that it is adequately protected.
We may retain a record of any contact you make with us.
The personal information we collect about you depends on the particular activities carried out through our App. Such information includes:
- your name, address and contact details;
- your IP address;
- your location;
- your interactions within the APP;
- special category data such as health information when engaging with us for the provision of an ‘off-site’ training day;
- details of any feedback you give us by phone, email, post or via social media; and information about the services we provide to you.
Personal information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has
appointed you to act on his/her behalf and has agreed that you can:
- give consent on his/her behalf to the processing of his/her data;
- receive on his/her behalf any data protection notices;
- give consent to any transfer of his/her data.
If we are in any doubt that you do not have the permission of the other person to provide us with their data, we reserve the right to cease processing their personal data and stop your access to our App.
Information from third parties
Occasionally we may receive information about you from other sources, which will be added to the information already held about you in order for us to help supply our services and products to you.
Information that will be collected automatically
Data Tracking: The App contains data tracking software which enables your employer to track your movement on the App. For example, an employer may monitor how long you use the App for, or an employer can check whether an employee has completed the compliance training module. This data will identify you as the user of the App and for further information on the use of tracking information on the App (including for how long this data is stored), please see the appropriate section of your employer’s Privacy Notice.
How your personal data will be used
We use this personal information to:
- create and manage your account with us;
- verify your identity;
- enquire for further information;
- provide our services to you;
- administration;
- fraud prevention and detection;
- customise our App and its content to your particular preferences;
- notify you of any changes to our App or to our services that may affect you;
- improve our services; and
- where you have consented to receive marketing from us by electronic means or we are otherwise lawfully entitled to use your personal data for marketing purposes.
Our legal basis for processing your personal information
When we use your personal information, we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
- contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
- legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations);
- legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).
- consent: where you have given us clear consent for us to process your personal information for a specific purpose.
Disclosure of your personal data
We may disclose your personal data to:
- your employer and co-workers;
- other companies that become partners or part of a group with Sevenhill Group;
- a third party who acquires Sevenhill Group or acquires substantially all of its assets, in which case the personal data shall be one of the acquired assets;
- our agents and service providers;
- law enforcement and regulatory agencies in connection with any investigation to help prevent unlawful activity or as otherwise required by applicable law;
- our clients when as part of a contracted service such as collating data sets collected from surveys.
Our App does not collect or compile personally identifying information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.
Transfer of your information out of the EEA
Your personal information may be transferred to third party service providers who process information on Sevenhill Group’s behalf, including providers of information technology, identity management, Website and/or our App hosting and management, data analysis, data back-up, security and storage purposes. As a result, your personal data may be transferred outside of the country where you are located, including outside of the European Economic Area (EEA). Where we use data servers that may transfer data out of the UK and/or the EEA we will take steps to ensure adequate protections are in place to ensure the security of your information and give you remedies in the unlikely event of a security breach. We will use Standard Contractual Clauses where appropriate in respect of any international transfer of personal data.
Please note that we review all processors we utilise and ensure that there are adequate safeguards in place to protect your personal data.
If you would like further information regarding the transfer of your information out of the EEA please contact our Data Protection Officer using the details provided in the ‘How to contact us’ section below.
Marketing
If you have provided your consent to receive news, special offers or promotions from us, we may contact you by MAIL, TELEPHONE AND EMAIL, about our PRODUCTS, SERVICES, PROMOTIONS, SPECIAL OFFERS AND CHARITABLE CAUSES that may be of interest to you.
The App may contain links to other websites or apps which we or our partners own, or websites or apps of our partners or third parties. Please note that if you follow any of these links, the websites, apps and services provided through them will have their own privacy policies/terms of use. We do not accept any responsibility or liability for their respective privacy policies/terms of use or the collection and use of any personal data collected through these websites, apps or services. Please ensure that you review the relevant privacy policies/terms of use prior to providing any personal data to, or using these websites, apps and services.
Monitoring
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of QUALITY ASSURANCE, TRAINING, FRAUD PREVENTION AND COMPLIANCE.
Your Rights
We will collect and store information about you, as detailed above.
You have the right of access to your personal records or other information that we hold about you. There is no administrative charge for this service.
You have the right to rectify any errors in the data we hold about you. If any data or information we hold about you is inaccurate, or out of date, please contact us and we will correct this immediately.
In certain circumstances, you may have the right to have the data we hold about you erased.
If you wish us to continue to store your information but wish us to keep your data separate and not process it in any way, please let us know.
You have the right to ask us to stop processing your personal data for direct marketing purposes. You may also specify that you object to direct marketing by particular channels such as by email of telephone. If this is the case, please specify the channels you are objecting to in your communications with us.
You have the right to data portability. If you wish to obtain your data for your own purposes across different services, we will provide this information to you in a CSV file. There is no administrative charge for this service.
To revise your consent, access, amend or remove your records or assert any of your rights set out above, you should send your request in writing to us at [email protected]
You may need to provide proof of identity and address (eg a copy of your driving licence or passport, and a recent utility or credit card bill); and specify the personal data you want access to, amended or removed.
How long we will store your data
We will store your data for as long as is reasonably necessary for the purpose of processing, typically six years from your last interaction with us. This may vary depending on the type of data collected and the nature of processing.
The data may be deleted in the following circumstances:
- you have withdrawn your consent to data processing;
- the original purpose for processing the data is no longer relevant or cannot be performed any more;
- the data is no longer up to date or accurate; or
- where we no longer have a reason to store your data as determined by our Data Retention Policy.
Children
We do not contract directly with children and therefore, we do not actively process the personal data of children. In using our services, you confirm that you have read and consented to this Policy and verify that you are over the age of 18.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also confirm that your data will be stored on secure servers.
We also have procedures 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.
Concerns and questions
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Changes to this Privacy Policy
We may change this Policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version that will apply each time you use our App.