Data Protection Principles
We will comply with data protection law. This means that your personal data that we hold must be:
- used lawfully, fairly and in a transparent way
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- relevant to the purposes we have told you about and limited only to those purposes
- accurate and kept up to date
- kept only as long as necessary for the purposes we have told you about
- kept securely.
How We Obtain Your Information.
We may collect any information that you provide to us yourself, for example when you:
- buy or apply for any products or services from us
- communicate with us by any method, or use communication services or platforms provided by us, for example, email, chat, applications, shared meetings or documents spaces, social media messages, comments or posts, calls, meetings, training, post, webinars or via our websites or apps or any online tools;
- (if available) create an account on our website or in any of our apps or online tools;
- make an enquiry, provide feedback, or make a complaint;
- subscribe to any of our marketing, promotions, surveys, newsletters, articles or mailing lists;
- register for and/or attend classes, parties or other events in person or online with us
- interact directly with us (e.g. at exhibitions, conferences and/or other meetings or events, in person or online) or provide us with any contact details for networking purposes;
- link to or share information with any of our personnel through social media or business forums or groups (for example LinkedIn, business or industry associations or alumni networks);
- submit a CV and/or an application for a job or to become an employee or service provider of ours and/or attend an interview or assessment with us.
We may also receive information about you from other people. For example:
- Security: We may collect information from cybersecurity service providers, about any actual or attempted misuse of our website, apps, emails or other communication methods or devices;
- Publicly available sources: We use publicly available sources such as search engines, listings sites, social media, websites, Companies House, Electoral Register, for instance, to carry out identity and compliance checks and to gain background information and research;
- analytics providers, advertising networks and search information providers: We may collect personal information from external providers of these services (see later sections);
- Employers, recruitment agencies and referees: If you are an applicant for a job or to become a service provider, franchisee or class leader of ours, we may contact your recruiter, current and former employers and/or referees to provide information about you and your application;
- Referrers: We may receive information about you from other people if you communicated to them that you would like to hear from us or from specified categories of business that include us;
- Official Sources: We may receive information about you from government authorities or bodies, police, crime or fraud prevention or other authorised entities.
What Information We May Collect and Process
The personal information we collect and process about you may include some or all of the following:
- Identity: including title, names, usernames, passwords,
- Contact information: including email addresses, phone numbers,
- Your communication: including any personal data that you include in any communication by any of the methods referred to How We Obtain Your Information and in any content that you upload on to any of our websites, apps or shared online environments;
- Identification and background information: including information provided by you if required as part of our customer or franchisee acceptance or contract processes, for example your government-issued identification information, social security numbers, tax identifiers, passport, utility bills or other personal identification documents;
- Transactions and profile data: including details about products and services that you bought from us or any of our franchise network and payments that you made via our payment service providers (who have their own separate privacy policies that you should read), your interests, preferences, feedback and survey responses and your marketing and communication preferences;
- Website, social media and app usage and other technical data: including information about your interactions with our websites, apps or social media pages and the device that you use to access them, which may include information such as IP addresses, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers). This information may be collected by third-party analytics service providers on our behalf and / or may be collected using cookies or similar technologies (see sections below)
On What Basis We Use Your Information
We use your personal information as permitted by law. Most commonly, this will be on the basis of one or more of the following
to enter into or perform a contract with you;
the legitimate interests of us or a third party as a business;
to comply with a legal or regulatory obligation;
your consent (if needed and where we request it), although see below.
Where we use your information for our legitimate interests, we consider any potential impact that such use may have on you. Our legitimate interests do not automatically override yours. We do not use your information if we think your interests should override ours unless we have other grounds to do so. If you are concerned, see Your Rights Relating to Your Information or contact us if you want more information about how we balanced your rights and our legitimate interests.
Generally, we do not rely on consent as a legal basis for processing your personal data other than for certain types of marketing where we need your consent and for use of your image or video (and in both those cases, only where you opt in). You have the right to withdraw consent at any time by contacting us.
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