We ask that you read this privacy notice 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.
- We use your data to provide our webinars, courses and other content to people who request or register for it, and to manage our relationships with those people and educational establishments we partner with.
- We delete your data when it is no longer needed for these things.
- Generally, we do not give your information to third parties, but there are some exceptions where we use external service providers to power our operations – some of these are outside Europe.
- We are happy to answer your questions about any of this – email us at email@example.com.
Who we are
Sensible Media Ltd collects uses and is responsible for certain personal information about you, in the course of our website (Paynegotiation.com, AlumniExtra.com) operations and in running our webinars. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
The personal information we collect and use
Information collected by us
In the course of running our business we collect the following personal information when you provide it to us. References to the basis of processing (e.g. “Basis: Legitimate Interest”) are a reference to the article of the General Data Protection Regulation under which we undertake the processing in question. More information is provided on the different bases for processing here.
- Registration information, including your name and email address. Depending on the service you are registering for, we may also ask you about your course of study, the year you graduated, the campus you study or studied at, and the territory in which you are resident. We use this to register you for the service, to validate your entitlement to free or discounted services, and to manage our relationships with any educational establishment of which you may be a student or alumnus. Basis: Performance of a contract; legitimate interest.
- In some cases, your payment details. We use our service provider, PayPal, to process this to collect any payment charged in respect of our services. Basis: Performance of a contract.
- In order to send you information from us regarding professional development or other webinars we offer we will ask you for your email address. Basis: Consent, legitimate interest.
- Information about people with whom we have discussed possible partnerships. We use this to document and progress those discussions.
- If you get in touch with us to raise a question or make a comment, we will use this to help us to resolve any issues or reply to your question. Basis: Performance of a contract; legitimate interest.
Information collected from other sources
We also obtain personal information from other sources as follows:
- If you are registering as part of a relationship we have with an educational establishment, we may obtain from them confirmation of your status as being connected with it. We do this by sharing with them the registration details (including your name and email address) you used to sign up.
- We receive from Mailchimp, our email service provider, an indicator of your level of engagement with our emails. We use this to tailor what we communicate to you and how best to do it.
Who we share your personal information with
If you view one of webinars by means of a website of one of our partner educational establishments, we will provide them with confirmation that you are entitled to view the webinar. If you register for a webinar as a student or alumnus of our partner educational establishments, we share your registration details with them.
We will share personal information with law enforcement or other authorities if we are subject to a legal obligation to do so. Mailchimp, Eventbrite and GoToWebinar are based outside the European Economic Area, in the USA — for further information including on how we safeguard your personal data when we share data with them, see ‘Transfer of your information out of the EEA’ below.
Whether information has to be provided by you, and if so why
The provision of the registration and any payment information is required from you to enable us to provide you with our service.
How long your personal information will be kept
- We will hold your registration data for 2 years following the end of our relationship with the educational establishment of which you are a student or alumnus;
- If you have not registered for our service but have asked us to send you information, we will keep your name and email address for a period of 5 years since our last interaction with you;
- If we hold information about you in relations to a possible partnership with an educational establishment, we will keep that data for 5 years from the end of our relationship with that establishment or (if no partnership results from the discussions) 5 years from our having obtained your information.
Transfer of your information out of the EEA
We may transfer your personal information to Mailchimp, GoToMeeting, ProsperWorks and Eventbrite, which are located in the USA, outside the European Economic Area (EEA). We may also share your information as set out above, with the educational establishment of which you are an alumnus or student – that may involve transferring your data outside the EEA.
Sometimes this will be to a country for which the European Commission has not given a formal decision that it provides an adequate level of data protection similar to those which apply in the United Kingdom and EEA. Examples are the USA, India and China. This is necessary for the performance of a contract in your interests, between ourselves and the educational establishment, under which we facilitate your free or discounted access to our webinars, courses and events.
Any transfer of your personal information will be subject to one of the of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. In the case of Mailchimp, GoToWebinar , ProsperWorks and Eventbrite, this is their EU-US Privacy Shield certification. See here for more details about the EU-US Privacy Shield – https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en
If you would like further information, please contact us (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email or write to us (see ‘How to contact us’ below)
- let us have enough information to identify you (your name and email address),
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates, including any account or webinar reference numbers, if you have them.
If you would like to unsubscribe from any email information we send you, you can also click on the ‘unsubscribe’ button at the bottom of the email.
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 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.
How to complain
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, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. 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 notice
This privacy notice was last updated on 22 May 2018. We may change this privacy notice from time to time, when we do in any material way we will inform you via email.
How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you. If you wish to contact us, please send an email to firstname.lastname@example.org, or write to us at Newcombe House, 45 Notting Hill Gate, London W11 3LQ.
Legal Bases for Processing
In the section of this notice which sets out what data we collect and how we use it, we refer to different legal bases for processing. Further details on each of those are set out here.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of Contract means processing your data where it is necessary for the performance of a contract between us and you or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Last updated 22 May 2018