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Website Privacy Policy

 

 

1. DATA PROTECTION

This privacy policy relates to your use of our website only. Strengthscope is committed to protecting and respecting your privacy, and to acting in compliance with the UK Data Protection Act 2018 and GDPR regulations. Our lawful basis for processing the data is consent.

Simply visiting Strengthscope’s website does not require you to reveal personal data. But if you ask us for information, order products or services, register with us, use our services or report a problem, we collect any personal data you submit to us, and details of the transactions between you and us. In addition, we store information you may give us about your interests, or we may learn about these from your use of our goods and services.

This policy will explain how we collect, use and process the data that you give us.

We adopt a layered approach to privacy and data protection of which this privacy policy is one aspect. We also have fair collection notices at various points on our website and other operational systems where data is collected. These fair collection notices appear as pop-ups or as forms for completion at the relevant points where data is collected.

Whenever you give us personal data via our website, you are consenting to its collection and use in accordance with this privacy policy and any fair collection notice which is notified to you at the time of giving us such data.

Any special category data that is collected is only used to provide demographic verification and reporting on the validity of the Strengthscope® tools. This information is always optional, and if used for verification purposes it will be aggregated and anonymous.

 

2. OUR SERVICES

We hold the data necessary to offer services provided on our website. We do not ask for or use more data than necessary to provide you with a proper service. This means we process and hold data related to free resource requests, purchases, subsequent support related to those purchases and completion and use of our products. This is in accordance with Article 6(1)(b) of the General Data Protection Regulation (GDPR). Any processing of your data is only done to provide or perform the services or products you have requested and purchased.

 

3. PERSONAL DATA WE COLLECT ABOUT YOU

The personal data we collect about you depends on the particular activities carried out through our website. We may collect and use the following personal data about you:

  • your name, address and contact information, including email address and telephone number.
  • Educational qualifications.
  • Cultural background and industry you work in.
  • Current employment status, occupational level and employer details.
  • What area of work you are employed in.
  • your gender.
  • Your age
  • your account details, such as username and login details.
  • your personal or professional interests.
  • information about the services we provide to you.
  • information about how you use our website and technology systems.

You must provide this personal data  to use our website and the services on it unless we tell you that you have a choice.

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website or any services on it.

 

4. HOW YOUR PERSONAL DATA IS COLLECTED

We collect personal data from you:

  • directly, when you enter or send us information, such as when you  eg register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website, and
  • indirectly, such as your browsing activity while on our website; we may collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below

 

5. HOW AND WHY WE USE YOUR PERSONAL DATA

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

  • where you have given consent
  • to comply with our legal and regulatory obligations
  • for the performance of a contract with you or to take steps at your request before entering into a contract, or
  • for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

 

6. HOW AND WHY WE USE YOUR PERSONAL DATA— Special category personal data

Certain personal data we may collect is treated as a special category to which additional protections apply under data protection law:

  • personal data revealing racial or ethnic origin
  • personal data regarding gender

Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws.

 

7. HOW AND WHY WE USE YOUR PERSONAL DATA— Sharing

We only share client data with our partners as part of the product fulfilment process.

All of our partners operate their own privacy policy in full accordance with the General Data Protection Regulation (GDPR).

 

8. MARKETING

We will use your personal data to send you updates (by email, text message, telephone or post) about our  services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

  • using the ‘unsubscribe’ link in emails.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it with other organisations outside the group for marketing purposes.

We may send emails to existing customers or prospective customers who have enquired or registered with us, regarding products or services directly provided by us.

In accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003, we never send bulk unsolicited emails, (popularly known as Spam) to email addresses. We never sell, rent or exchange mailing lists.

 

9. WHO WE SHARE YOUR PERSONAL DATA WITH

We routinely share personal data with:

  • third parties we use to help deliver our  services to you, e.g. payment service providers.
  • other third parties we use to help us run our business, e.g. marketing agencies or] website hosts and website analytics providers
  • our bank.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

  • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

 

10. WHO WE SHARE YOUR PERSONAL DATA WITH— Further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

 

11. HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data. Further details on this are available on request.

If you stop using your account we will delete or anonymise your account data after seven years.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

 

12. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

  • our service providers located outside the UK.
  • As we are based in the UK we will also transfer your personal data from the EEA to the UK.

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

  • the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available at :-

International data transfers: building trust, delivering growth and firing up innovation - GOV.UK (www.gov.uk).

in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here :-

Adequacy decisions | European Commission (europa.eu)

  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
  • a specific exception applies under relevant data protection law

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or where this is not available we will do so under a transfer mechanism such as a legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

 

13. COOKIES

Our website uses “cookies” to track use and allow customers to purchase from our website. Please note that these cookies do not contain or pass any personal, confidential or financial information or any other information that could be used to identify individual visitors or customers purchasing from our website. Please note that you are free to refuse cookies. However, for purely technical reasons this may prevent you from purchasing from our website.  

 

14. CUSTOMER REQUESTS AND RIGHTS

As a customer, you can at any time (and free of charge) request details of the data we hold relating to you – and you can also request any such data is amended or deleted. Please note that if you request deletion of your data, this may prevent us from offering any further support relating to your previous purchases. We recognise and uphold all individual rights as specified in the General Data Protection Regulation (GDPR)

You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself  and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates

 

15. KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. 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.

 

16. HOW TO COMPLAIN

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

  • the Information Commissioner in the UK

The UK’s Information Commissioner may be contacted using the details at Make a complaint | ICO or by telephone: 0303 123 1113.

 

17. CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you.

 

18. HOW TO CONTACT US

If you have a question or complaint relating to our Privacy Policy, please email us at [email protected] or use our contact form.