We may update this policy occasionally and, therefore, recommend that you revisit this page from time to time to review any changes that we may have made.
What is Personal Data?
This policy refers to the terms ‘personal data’ and ‘personal information’. These terms both mean any information relating to you as an identifiable individual. For example, your name and contact details. The terms also relate to information which may not, on its own, identify you but which can be linked to you because we store it alongside your identifiable information, for example, a record of your progress within one of our online courses.
Our legal company name is Upsell Consulting Limited (and we trade as, and use the brand name of, ‘Business Minded’). Upsell Consulting Limited is registered in England and Wales under company number 8277028.
Within this policy we may be referred to as ‘we’, ‘us’, ‘our’ and ‘Business Minded’.
Business Minded is the Data Controller and we are responsible for collecting and handling your personal data.
If you wish to contact us you can do so by emailing us at firstname.lastname@example.org.
When We Collect Information
We collect information from you and about you in a variety of ways, depending on the nature of our interactions with you. The occasions we collect information include:
- When you enquire about us, our services or our courses;
- When you purchase our services or courses;
- When you register for, undertake and progress through a course;
- When you utilise any of our services, such as our online stress and mindfulness assessments;
- When you tell us about your experiences of our services or courses;
- When you contact us for support or advice.
We may collect information about you through a variety of channels including online (for example via contact forms or assessments), email correspondence, over the telephone, or during in-person or Skype meetings or conversations.
We may also collect information about you from your employer, for example, when they purchase and register you onto a course. We require them to seek your permission before they give us your data and you can find out more about this in the section below.
What Information We Collect
We may collect the following information from and about you:
- Your full name;
- Your job title;
- Your contact details including telephone number and email address;
- Your company name and address;
- Your company sector;
- Number of employees within your company;
- Your company bank details (usually in the event of a requirement to refund);
- Information regarding your organisation’s wellbeing activities;
- Your opinions, ratings and feedback about our services or courses;
- Information about your experiences of stress and your wellbeing;
- Stress and mindfulness assessment data (collected if you choose to complete an online assessment);
- Online course user data (such as your course progression, time spent completing course modules);
- Information from your computer or the device you use to access our website, services or courses, for example the type of device you are using, the browser you are using.
When Buying Course Places Online
When you purchase a course online, we will ask you for:
- Your first name and last name;
- Your company name (if applicable);
- An e-mail address;
- Credit or debit card details;
We do not collect your credit or debit card details and they are not made available to us. They are collected over a secure link by Stripe (www.stripe.com/gb).
Stripe will use the personal information you provide to process your online payment. When you make a payment online, Stripe will use industry standard software which encrypts your information. For further details about the security of this information, please refer to www.stripe.com/gb.
If You Provide Us With Information on Behalf of Other People
Sometimes you might provide us with information about and on behalf of other people, for example, if you are registering employees onto one of our courses on behalf of your organisation. When you provide us with information about another person, the other person must have agreed to:
- Us processing all their personal data contained within the information you provide;
- You receiving any data protection notices in relation to them;
- You passing their data to us.
When you send another person’s information to us you are confirming that you have agreed the above with them. You are also confirming that you have told them:
- Which data they must give;
- Which information is voluntary;
- How they can access and, if necessary, correct the data we hold about them;
What We Do With Your Information
We use your personal information to:
- Deliver our services, for example delivering courses that you have access to, or providing outcomes of any online assessments you complete;
- Provide course content, materials and supporting email information;
- Carry out administration and record keeping;
- Respond to your queries or complaints;
- Provide technical support;
- Improve, optimise and secure our website, services and courses;
- Meet any contractual obligations entered into with you, including billing, collections or similar financial transactions;
- Gather general, aggregated statistics and research data, for example data about website use or course progression;
- Ensure our website, services or courses are usable and your user experience is optimised, for example by changing the way we display information based on the type of device you are using;
- Obtain any relevant professional advice as may be required by law or in connection with legal proceedings (including where we intend to take legal proceedings), or as may be necessary to establish, exercise or defend our legal rights, or to meet any legal obligations placed upon us.
Advising You of Our Services and Offers
If you give us your express consent, we will use your information to send you regular updates about:
- Our services, courses and offers;
- Additions to our website; and
- Specific activities such as customer feedback surveys and competitions.
You may opt out of receiving this information at any time either by using an opt-out link at the end of an email update or by contacting us at email@example.com.
Sharing Your Information
We may need to share your information with third parties so that we can properly provide our website, services and courses to you.
We require third parties to handle your information in a legally compliant and secure manner, and to only process in such a way as to fulfil our service obligations to you.
The types of third party suppliers we share your information with include:
- Payment processing companies to securely process any purchases you make from us;
- Email management and distribution service suppliers who handle the delivery of any newsletters or promotional information, if you have signed up to receive these;
- Learning management system suppliers, for example to deliver emailed course information to you;
- Internet tracking tool providers so we can monitor our website use and access routes;
- Online cloud storage providers.
In addition to the above, we may disclose your information to enforce any contractual terms between us, or to prevent, detect or prosecute any illegal or suspected illegal activities, or in response to a binding request for information from an authority such as a court.
Sharing Information with Your Employer
If your employer has purchased a course place for you then we may share some of your personal information with them to help them assess the uptake of the course and monitor your learning and course completion. We will not share your personally identifiable stress and / or mindfulness assessment data – please see below for more information on how we handle this data.
IMPORTANT – Sharing Information to Protect the Wellbeing of You or Others
Our courses and services are designed to be personal and workplace development tools and are not therapeutic interventions. Occasionally our website, service and course users contact us with information about their personal experiences of stress, mental health and wellbeing, and sometimes ask for support or advice. Unfortunately, we are unable to provide clinical or therapeutic advice or support and we always recommend an alternative point of contact, such as your GP or your organisation’s HR or wellbeing services.
If you contact us with information about your personal experiences of stress, mental health or wellbeing we do not share this information with anybody unless we reasonably believe there may be a risk to the safety and wellbeing of either you or somebody else. If we reasonably believe there is a risk then we will share your personal information (including your identity, contact information and details of the reasons for our concern) with a relevant third party such as the police or, if you have accessed a course via your employer, your HR (or appropriate alternative) team.
Sharing Your Information Across International Borders
Some of our service providers are based outside of the European Economic Area (EEA), such as Stripe, who process online card payments for us. Working with such service providers may mean that we need to transfer some of your personal data outside of the EEA and UK.
Not all countries have the same levels of personal data and privacy protections required by EEA and UK law, therefore, if we transfer your personal data outside of the EEA and UK we will take all reasonable steps to ensure that it is secured and processed in a way equivalent to that required by EEA and UK law. The steps we take may include:
- Only transferring your personal information to countries that the European Commission have approved as providing adequate levels of personal data protection;
- Asking certain providers to adhere to European Commission approved contractual clauses or codes of conduct which require them to provide similar levels of personal data protection as those required by EEA law;
- Asking you for your specific consent prior to transferring your personal information, if the above options are not available to us.
Stress and / or Mindfulness Assessment Data
We will conduct statistical analysis of stress and / or mindfulness assessment data to help us assess and improve our services and for reporting and marketing purposes. Such data will be aggregated with that of other relevant users and personal information relating to your individual identity will be removed to maintain confidentiality and anonymity.
If your employer has purchased a number of course places then we may provide them with anonymised, aggregated assessment data to help them assess the effectiveness of a course. Should the number of relevant data samples be insufficiently low as to be unable to ensure your anonymity then we will decline to provide your employer with any assessment data.
How Long We Keep Your Personal Information
We keep personal data:
- For as long as is necessary to fulfil the purposes we collected it for;
- As required by law; or
- To enforce or defend legal claims.
Sometimes we will keep information that you have deleted, for example messages sent by you to us. We will keep this information for a reasonable time.
Securing Your Personal Information
Your personal information may be stored in either secure cloud storage or secure hard-drive storage. We maintain security measures to protect your personal information from unauthorised access, misuse or disclosure. However, no exchange or storage of data can be guaranteed as 100% secure. While we make every effort to protect your personal information you acknowledge that the personal information you share with us could be accessed or tampered with by a third party. You agree that we are not responsible for any intercepted information shared through our website, services or liaison with you in respect of any courses.
Additionally, you release us from any and all claims arising out of or related to the use of such intercepted information.
The term “cookies” refers to small text files which a website sends to your computer’s hard drive and stores information on your device for a limited amount of time while you are viewing the website or using an application.
We use two main types of cookies:
- Session cookies, which are removed once you close your browser and leave our website. They are removed because they don’t need to store any information between website visits;
- Persistent cookies, which stay on your computer until they either reach a specified expiry date or you delete them. This is because they store information between website visits so that our website and services are able to recognise you when you make a return visit.
We may send cookies to your computer for the following reasons:
- Because they are essential to the functionality of our website, services or courses;
- To optimise the delivery of our website, services or courses – for example, cookies help us to recognise the device you are using to browse our website so we can change the way we display our content in order that you get a better user experience;
- To help us understand how our website and services are being accessed and used, so we can make changes and improve our services to meet your needs.
You can choose to decline cookies using your web browser settings. However, please be aware that if you choose to disable cookies, some areas of our website, services and courses may not work properly or at all.
You can also clear your computer of cookies, again by using your web browser settings.
Third Party Links
We are not responsible for the privacy policies or practices of any third parties.
You have the right to ask for a copy of all the information we hold about you (we may charge you a small fee for this) and to correct any inaccuracies. To obtain a copy of this information, please e-mail us at firstname.lastname@example.org.
Updating Your Information
You may access and correct personal information relating to your course registration via the “Your Courses” page of the learning management system website. Other personal information and privacy preferences can be updated by emailing us at email@example.com.
Updated June 2018