Privacy Policy
BACKGROUND:
VocAL Intuition understands that your privacy is important
to you and that you care about how your
personal data is used and shared online. We respect and value the
privacy of everyone who visits this
website, https://vocalintuition.learnhownow.com
(“Our Site”) and will only collect and use personal data in ways that
are described here, and in a manner that is consistent with Our obligations and
your rights under the law.
Please read this Privacy Policy carefully and ensure that
you understand it. Your acceptance of Our Privacy Policy is deemed to occur
upon your first use of Our Site. If you do not accept and agree with this
Privacy Policy, you must stop using Our Site immediately.
1.
Definitions and Interpretation
In this Policy, the following terms shall have the following
meanings:
“Account” |
means an account required to access and/or use
certain areas and features of Our Site; |
“Cookie” |
means a small text file placed on your computer
or device by Our Site when you visit certain parts of Our Site and/or when
you use certain features of Our Site. Details of the Cookies used by Our Site
are set out in section 13, below; |
[“Cookie Law” |
means the relevant parts of the Privacy and
Electronic Communications (EC Directive) Regulations 2003;] |
“personal data” |
means any and all data that relates to an
identifiable person who can be directly or indirectly identified from that
data. In this case, it means personal data that you give to Us via Our Site. This definition shall,
where applicable, incorporate the definitions provided in the EU Regulation
2016/679 – the General Data Protection Regulation (“GDPR”); and |
“We/Us/Our” |
means VocAL Intuition, owned by Anne Leatherland whose
main trading address is 8 Windsor
Drive, Stapenhill, Burton on Trent, Staffordshire, UK |
2.
Information About Us
2.1
Our Site
is operated by HowNow, itself owned and operated by Wonderush Limited, a
limited company registered in England and Wales under company number 09644569 whose
registered office is at PO Box 1373, Barking, IG11 1HN
2.2
Our Data
Protection Officer is Anne Leatherland and can be contacted by email at anne@vocalintuition.co.uk by
telephone on +44283 568785 or by post at 8 Windsor Drive, Stapenhill, Burton on
Trent, Staffordshire, UK
2.3
We are a member of ICO
2.4
The data
collected for online courses and for operation of Our site is controlled and monitored
by HowNow. Please see their full privacy policy here for details https://learnhownow.com/privacy-policy
or contact hello@learnhownow.com
2.5
Where
payments are made for courses through Paypal, Stripe or Go Cardless, details
will be handled and stored by these agencies and governed by their own privacy
policies. Data will be controlled by their own data controllers, as is usual
for such agencies.
3.
What Does This Policy Cover?
This Privacy Policy
applies only to your use of Our Site. Our Site may contain links to other
websites. Please note that We have no control over how your data is collected,
stored, or used by other websites and We advise you to check the privacy
policies of any such websites before providing any data to them.
4.
[Your Rights
4.1
As a data subject, you have the following rights
under the GDPR, which this Policy and Our use of personal data have been
designed to uphold:
4.1.1 The
right to be informed about Our collection and use of personal data;
4.1.2 The
right of access to the personal data We hold about you (see section 12);
4.1.3 The
right to rectification if any personal data We hold about you is inaccurate or
incomplete (please contact Us using the details in section 14);
4.1.4 The
right to be forgotten – i.e. the right to ask Us to delete any personal data We
hold about you (We only hold your personal data for a limited time, as
explained in section 6 but if you would like Us to delete it sooner, please
contact Us using the details in section 14);
4.1.5 The
right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The
right to data portability (obtaining a copy of your personal data to re-use
with another service or organisation);
4.1.7 The
right to object to Us using your personal data for particular purposes; and
4.1.8 Rights
with respect to automated decision making and profiling.
4.2
If you have any cause for complaint about Our
use of your personal data, please contact Us using the details provided in
section 14 and We will do Our best to solve the problem for you. If We are
unable to help, you also have the right to lodge a complaint with the UK’s
supervisory authority, the Information Commissioner’s Office.
4.3
For further information about your rights,
please contact the Information Commissioner’s Office or your local Citizens
Advice Bureau.
5.
What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or
all of the following personal and non-personal data (please also see section 13
on Our use of Cookies and similar technologies.
5.1
name;
5.2
date of birth;
5.3
gender;
5.4
business/company name
5.5
job title;
5.6
profession;
5.7
contact information such as email addresses and
telephone numbers;
5.8
demographic information such as post code,
preferences, and interests;
5.9
financial information such as credit / debit
card numbers;
5.10
IP address;
5.11
web browser type and version;
5.12
operating system;
5.13
a list of URLs starting with a referring site,
your activity on Our Site, and the site you exit to;
5.14
messages you leave on Our Site or by email, text
or other electronic messenger as part of an online course;
5.15
Material you submit to Us via Our Site or
otherwise as part of course participation;
6.
How Do We Use Your Data?
6.1
All personal data is processed and stored
securely, for no longer than is necessary in light of the reason(s) for which
it was first collected. We will comply with Our obligations and safeguard your rights under GDPR at all times. For more details
on security see section 7, below.
6.2
Our use of your personal data will always have a
lawful basis, either because it is necessary for Our performance of a contract
with you, because you have consented to Our use of your personal data (e.g. by
subscribing to emails), or because it is in Our legitimate interests.
Specifically, We may use your data for the following purposes:
6.2.1 Providing
and managing your Account;
6.2.2 Providing
and managing your access to Our Site;
6.2.3 Personalising
and tailoring your experience on Our Site;
6.2.4 Supplying
Our services to you (please note that We require your personal data in order to
enter into a contract with you);
6.2.5 Personalising
and tailoring Our services for you;
6.2.6 Replying
to emails from you;
6.2.7 Supplying
you with emails that you have opted into (you may unsubscribe or opt-out at any
time by contacting info@vocalintuition.co.uk
6.2.8 Market
research;
6.2.9 Analysing
your use of Our Site and gathering feedback to enable Us to continually
improve Our Site and your user experience;
6.3
With your permission and/or where permitted by
law, We may also use your data for marketing purposes which may include
contacting you by email, telephone, text
message, via social media or
post with information, news and offers on Our products and services. We
will not, however, 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 the GDPR and the Privacy and Electronic Communications
(EC Directive) Regulations 2003.
6.4
Third parties (including HowNow, Youtube, Prezi.
Paypal, Go Cardless and Stripe whose content appears on Our Site, may use third
party Cookies, as detailed below in section 13. Please refer to section 13 for
more information on controlling Cookies. Please note that We do not control the
activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of
any such third parties.
6.5
You have the right to withdraw your consent to
Us using your personal data at any time, and to request that We delete it.
6.6
We do not keep your personal data for any longer
than is necessary in light of the reason(s) for which it was first collected.
6.7 Personal data will be kept by VocAL Intuition for the duration of the purchased course and the services provided (3 months) plus a further 12 months so that follow-up may be made to clients when requested.
6.8 For Vocal Process Approved courses your personal data (contact details) may be shared with Vocal Process so that we can supply you with any promised free materials e.g. webinars, and keep you updated of relevant courses and events. You can unsubscribe at any time.
6.9 The personal data may be kept for contact and
marketing purposes if you have opted in to this and until you withdraw your
permission for us to keep it or unsubscribe from our mailing and contact list.
7.
How and Where Do We Store Your Data?
7.1
We only keep your personal data for as long as
We need to in order to use it as described above in section 6, and/or for as
long as We have your permission to keep it.
7.2
Some or all of your data may be stored outside
of the European Economic Area (“the EEA”) (The EEA consists of all EU member
states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and
agree to this by using Our Site and submitting information to Us. If We do
store data outside the EEA, We will take all reasonable steps to ensure that
your data is treated as safely and securely as it would be within the UK and
under the GDPR including:
7.2.1 Requesting
details of the procedures of the hosting platform, HowNow and marketing platform
Mailchimp, who endeavour to implement appropriate security measures, including
physical, electronic and procedural measures. These third parties have their
own data handling and security measures and you should check their privacy
policies for further details. VocAL Intuition has it’s own such measures in
place for data held directly through Us.
7.3
Data security is very important to Us, and to
protect your data We have taken suitable measures to safeguard and secure data
collected through Our Site.
7.4
Steps We take to secure and protect your data
include:
7.4.1 We
take all reasonable steps with deleting your data from Our course on the
platform or Our mailing lists, at your request or when it is no longer needed
by Us to provide services to you as agreed. We cannot control how HowNow
handles its data internally and advise that you check their privacy policy for
details.
7.4.2 Where
We store your data locally on computer or in the cloud (e.g. Dropbox, iCloud)
your data will be encrypted.
8.
Do We Share Your Data?
8.1
We may sometimes contract with third parties to
supply products and services to you on Our behalf. These may include payment
processing, delivery of goods, search engine facilities, advertising, and
marketing. In some cases, the third parties may require access to some or all
of your data. Where any of your data is required for such a purpose, We will
take all reasonable steps to ensure that your data will be handled safely,
securely, and in accordance with your rights, Our obligations, and the
obligations of the third party under the law.
8.2
We may compile statistics about the use of Our
Site including data on traffic, usage patterns, user numbers, sales, and other
information. All such data will be anonymised and will not include any
personally identifying data, or any anonymised data that can be combined with
other data and used to identify you. We may from time to time share such data
with third parties such as prospective investors, affiliates, partners, and
advertisers. Data will only be shared and used within the bounds of the law.
8.3
We may sometimes use third party data
processors that are located outside
of the European Economic Area (“the EEA”) (The EEA consists of all EU member
states, plus Norway, Iceland, and Liechtenstein). Where We transfer any
personal data outside the EEA, We will take all reasonable steps to ensure that
your data is treated as safely and securely as it would be within the UK and
under the GDPR including:
8.3.1
HowNow, Paypal, Stripe, Go Cardless: Regularly checking their privacy policy and
data handling measures, in as much as is reasonably possible and updating Our
policy accordingly.
8.3.2
Dropbox and iCloud: Checking their privacy
policies and data handling measures, in as much as is reasonably possible and
updating Our policy accordingly.
8.3.3
In certain circumstances, We may be legally
required to share certain data held by Us, which may include your personal
data, for example, where We are involved in legal proceedings, where We are
complying with legal requirements, a court order, or a governmental authority.
9.
What Happens If Our Business Changes Hands?
9.1
We may, from time to time, expand or reduce Our
business and this may involve the sale and/or the transfer of control of all or
part of Our business. Any personal data that you have provided will, where it
is relevant to any part of Our business that is being transferred, be
transferred along with that part and the new owner or newly controlling party
will, under the terms of this Privacy Policy, be permitted to use that data
only for the same purposes for which it was originally collected by Us.
9.2
In the event that any of your data is to be
transferred in such a manner, you will not be contacted in advance and informed
of the changes.
10.
How Can You Control Your Data?
10.1
When you submit personal data via Our Site, you
may be given options to restrict Our use of your data. In particular, We aim to
give you strong controls on Our use of your data for direct marketing purposes
(including the ability to opt-out of receiving emails from Us which you may do
by unsubscribing using the links provided in Our emails and at the point of
providing your details.
10.2
You may also wish to sign up to one or more of
the preference services operating in the UK: The Telephone Preference Service
(“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the
Mailing Preference Service (“the MPS”). These may help to prevent you receiving
unsolicited marketing. Please note, however, that these services will not
prevent you from receiving marketing communications that you have consented to
receiving.
11.
Your Right to Withhold Information
11.1
You may access certain areas of Our Site without
providing any data at all. However, to use all features and functions available
on Our Site you may be required to submit or allow for the collection of
certain data.
11.2
You may restrict Our use of Cookies. For more
information, see section 13.
12.
How Can You Access Your Data?
You have the right to
ask for a copy of any of your personal data held by Us (where such data is
held). Under the GDPR, no fee is payable and We will provide any and all
information in response to your request free of charge. Please contact Us for
more details using the contact details below in section 14.
13.
Our Use of Cookies
13.1
Our Site may place and access certain first
party Cookies on your computer or device. First party Cookies are those placed
directly by Us and are used only by Us. We use Cookies to facilitate and
improve your experience of Our Site and to provide and improve Our products or
services.
13.2
In
addition, Our Site uses analytics services provided by Google Analytics, which
also use Cookies. Website analytics refers to a set of tools used to collect
and analyse usage statistics, enabling Us to better understand how people use
Our Site. For more details, please refer to HowNow for their cookie policy
which governs Our site.
13.3
In addition to the controls that We provide, you
can choose to enable or disable Cookies in your internet browser. Most internet
browsers also enable you to choose whether you wish to disable all cookies or
only third party Cookies. By default, most internet browsers accept Cookies but
this can be changed. For further details, please consult the help menu in your
internet browser or the documentation that came with your device.
13.4
You can choose to delete Cookies on your
computer or device at any time, however you may lose any information that
enables you to access Our Site more quickly and efficiently including, but not
limited to, login and personalisation settings.
13.5
It is recommended that you keep your internet
browser and operating system up-to-date and that you consult the help and
guidance provided by the developer of your internet browser and manufacturer of
your computer or device if you are unsure about adjusting your privacy
settings.
14.
Contacting Us
If you have any questions about Our Site or this Privacy
Policy, please contact Us by email at anne@vocalintuition.co.uk
by telephone on +441283 568785 or by post at 8 Windsor Drive, Stapenhill,
Burton on Trent, Staffordshire, DE15 9BH, UK. Please ensure that your query is
clear, particularly if it is a request for information about the data We hold
about you (as under section 12, above).
15.
Changes to Our Privacy Policy
We may change this
Privacy Policy from time to time (for example, if the law changes). Any
changes will be immediately posted on Our Site and you will be deemed to have
accepted the terms of the Privacy Policy on your first use of Our Site
following the alterations. We recommend that you check this page regularly to
keep up-to-date.