SWInnerCircle.com is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
SWInnerCircle.com may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 1st May 2018.
In order to supply you with your online ‘membership’ of Sarah’s Inner Circle Online CPD, we may collect the following information:
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
We do not ask for, or store, any data which does not pertain to the information given above.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
You may choose to restrict the collection or use of your personal information in the following ways:
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties (for example, the brilliant work of other behaviour specialists and trainers) which we think you may find interesting if you tell us that you wish this to happen.
By law, SWInnerCircle.com may only process personal data where it has a legal justification or requirement to do so.
In accordance with that law, SWInnerCircle.com processes personal data as described above because it is:
1) Necessary for the performance of our subscription contracts with our members: and/or
2) Necessary for the purposes of SWInnerCircle.com legitimate interests, namely to fulfil its function in accordance with applicable law and regulations and to conduct and manage our relationship with specific individuals. Where we use your personal data for SWInnerCircle.com legitimate interests, we make sure that we take into account any potential impact that such use may have on you. If we believe your interests or fundamental rights and freedoms override our legitimate interests then we won’t use your personal data on this basis and may seek your specific consent, and/or
3) Necessary for compliance with its legal obligations.
SWInnerCircle.com would not be able to fulfil its function as an educational subscription service as set out without processing personal data as described in this policy.
If you have any concerns about our processing please refer to details of “Your Rights in Relation to Personal Data” below.
Individuals whose personal data we process have certain rights in respect of that data, including:
You have the right to request access to the information that we hold about you.
In accordance with data protection laws, members also have the right to receive a copy of any information we hold about them in connection with the performance of our contract with them. On request, SWInnerCircle.com will provide members with copies of their personal data in a convenient format (via electronic means or otherwise).
You have the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances. In responding to such requests, SWInnerCircle.com will communicate to the individual concerned the impact of such restrictions or deletions, for example, on SWInnerCircle.com’s ability to allow access to their online educational course.
SWInnerCircle.com takes reasonable steps to ensure that the personal data it holds about you is accurate and up-to-date and we will comply with any requests to rectify any inaccurate data we may hold about you. We do ask that you notify us immediately if you change any part of your data so we can update our records.
You have the right to object to SWInnerCircle.com using your information on the basis of its legitimate interests and the right to ask us not to process your personal data for marketing purposes, where relevant (see “What do we do with your personal data?” section above).
SWInnerCircle.com is committed to respecting individuals’ rights. You may action your rights by contacting us using the details provided above and we will comply with your requests unless we have a lawful reason not to do so. SWInnerCircle.com will endeavour to handle any requests within a reasonable period and, in any event, within a month of the original request.
SWInnerCircle.com will only share personal data with third parties in the following circumstances:
SWInnerCircle.com employs external IT consultants to provide support and development services in relation to SWInnerCircle.com’s systems and databases. These consultants may from time to time need to access information which may contain personal data for the purposes of systems testing and development.
SWInnerCircle.com also uses third party providers to facilitate certain communications on its behalf, such as mail-outs, which requires them to access contact data. All such third parties are vetted by SWInnerCircle.com to ensure they provide adequate levels of security when processing data.
In some circumstances, SWInnerCircle.com may need to share your personal data where necessary with other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
We require third parties to maintain appropriate security to protect information from unauthorised access or processing.
SWInnerCircle.com will take appropriate technical and organisational measures to protect the personal data we transmit, store or otherwise process against accidental or unlawful destruction, loss, alteration or unauthorized disclosure or access.
The members’ area of the SWInnerCircle.com website requires entering a username/email address and password which is encrypted and known only to the member. The data that Members provide on-line to SWInnerCircle.com is also encrypted protected by Secure Sockets Layer (SSL) encryption technology. The SWInnerCircle.com members’ area is secured and hardened against attacks according to industry best practices and is regularly tested to ensure security provisions remain adequate. Bank account information is never accessible, either by our employees or by third parties.
Data files shared by SWInnerCircle.com with third parties are password protected. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, although SWInnerCircle.com strives to protect your personal data online, including through use of encryption and other measures, we cannot guarantee the security of any Internet communication or transmission. If you have reason to believe that your interaction with us is not secure, please notify us of the problem immediately by contacting us using the details below.
Prior to introducing new systems or technologies relevant to the processing of personal data, SWInnerCircle.com will undertake the necessary impact assessments with a particular focus on any associated risks.
SWInnerCircle.com will only retain personal data for as long as is necessary to provide our services or for as long as we reasonably require to retain the information for our lawful business purposes or comply with a statutory or other legal requirement.
In the event of any breach of SWInnerCircle.com’s systems impacting on the security of a member’s or any other individual’s personal data, SWInnerCircle.com will inform the affected member(s) or individuals at the earliest opportunity describing the nature of the breach, the possible consequences and the measures being taken to remedy the situation in accordance with our procedures and applicable law.
If you are unhappy with the way in which SWInnerCircle.com processes your personal data, please contact us using the information provided below. You also have the right to lodge a complaint before the Information Commissioner’s Office (ICO), the UK data protection authority. Their contact details as are follows: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; Tel: 0303 123 1113 (local rate) or 01625 545 745; or see their website.
Please direct any comments or enquires relating to this policy to: Sarah Whitehead’s Inner Circle, PO Box 372, Windsor, SL4 4WH. firstname.lastname@example.org
From time to time we may change our data processing activities. We will notify you of any changes to this policy as required by law. We will also post an updated version on our website.
Date: 1st May 2018