CLA Mediation & Training Ltd
WEBSITE PRIVACY POLICY
BACKGROUND:
CLA Mediation & Training Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website www.clamediation.com (“Our Sites”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it.
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 Sites;
“Service Provider” means CLA Mediation & Training Ltd.
“The Client”, “you” or “your” means the customer, website visitor or client of CLA Mediation & Training Ltd
Information About Us
Our websites are operated by CLA Mediation & Training Ltd, a limited company.
Registered address: Rowan House Barnett Way, Barnwood, Gloucester, England, GL4 3RT.
What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Sites. Our Sites 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.
What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
1 Data Protection
1.1 The Service Provider consents to the Client holding and processing data relating to him for legal, personnel, administrative and management purposes and in particular to the processing of any “sensitive personal data” (as defined in the Data Protection Act 1998) relating to the Service Provider.
1.2 The Service Provider consents to the Client making such information available to those who provide products or services to the Client.
2 GDPR Information
2.1 The Service Provider is committed to protecting the privacy and security of your personal data.
2.2 The Service Provider is the ‘controller’ and responsible for your personal data and the person responsible to whom any queries or requests should be directed is CLA Mediation & Training Ltd who can be contacted at the Service Provider’s registered address, which is Rowan House Barnett Way, Barnwood, Gloucester, England, GL4 3RT or by emailing admin@clamediation.com .
2.3 You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2.4 Your duty to inform us of changes 2.4.1 It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
2.5 The data we collect about you 2.5.1 We may collect, use, store and transfer the types of personal data about you listed in Table 1 of Clause 3, which also sets out where and how that data is stored.
2.5.2 Failure to provide personal data 2.5.2.1 We need your personal data in order to fulfil our contract with you to provide services or products and, if you fail to provide it, we may not be able to perform that contract and may have to cancel it. In the event of a purchase, we may not be able to fulfil the order. We will notify you of this at the relevant time.
2.6 How personal data is collected 2.6.1 We are usually provided with your data by the person requesting services or offering to purchase a product.
2.7 How we use your personal data 2.7.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data: (Please see Table 2 at Clause 4 for further data collection purposes.) 2.7.1.1 to perform the contract we are to enter into or have entered into with you;
2.7.1.2 to comply with a legal obligation; and
2.7.1.3 where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
2.7.2 Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.
2.7.3 We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us by emailing admin@clamediation.com .
2.7.4 If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
2.7.5 In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
2.8 Disclosure of your personal data 2.8.1 We may have to share your personal data with third parties. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. They can only process your personal data for specified purposes and in accordance with our instructions.
2.9 Data security 2.9.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
2.9.2 We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
2.10 Data retention 2.10.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, conflict of interest or reporting requirements. Please see Table 2 in Clause 4 for specific purposes of collecting data.
2.10.2 We will retain your file for 6 years in case of queries about the decisions made. We are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes and will retain contact and identity details indefinitely for conflict of interest checks.
2.11 Your legal rights 2.11.1 You have certain rights in certain circumstances under data protection law. If you wish to exercise any of your rights, please contact CLA Mediation & Training Ltd.
2.11.2 You have the following legal rights in relation to your personal data to ask for: access to, and a copy of your personal data; any incomplete or inaccurate data to be corrected; a transfer of your personal data which is held in an automated manner; and to restrict processing where: 2.11.2.1 you want us to establish the accuracy of your personal data;
2.11.2.2 our use of your personal data is unlawful, but you do not want us to erase it;
2.11.2.3 you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or
2.11.2.4 you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.
2.11.3 You can also object to the processing of your personal data where: 2.11.3.1 where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms.
2.11.3.2 In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms and in such circumstances, we can continue to process your persona data for such purposes.
2.11.4 Erasure - you can ask us to delete or remove your personal data where: 2.11.4.1 there is no good reason for us continuing to process it;
2.11.4.2 you have successfully exercised your right to object (see below);
2.11.4.3 we may have processed your information unlawfully; or
2.11.4.4 we are required to erase your personal data to comply with local law.
2.11.4.5 We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request.
2.11.5 We may request specific information from you to help us confirm your identity when you contact us to ensure that personal data is not disclosed to any person who does not have the right to receive it.
2.11.6 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
3 Table 1.
We will only store or transfer some of your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
Data Collected
How We Collect the Data
Identity Information including your name and email address
Subscriber form or Purchaser form.
Contact information including your name, email address, telephone number
Subscriber form or Purchaser form.
Business information including your profession, title and company name
Through any content submitted through the website by the Client, or any other replies or comments.
Payment information including card details and name for the purpose of processing with our payment platform.
The data is held and controlled for the purposes of processing payment by our payment platform. No payment information is held on file, except if requested expressly by the Client or if for the purposes of fulfilling the contract, a different method of payment processing is required.
Profile information including preferences, interests, comments, purchases, downloads, replies, user information and user history.
Through any content submitted through the websites by the Client, or any other replies or comments.
Table 2 - How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we use your personal data, and our lawful bases for doing so:
What We Do
What Data We Use
Our Lawful Basis
Registering you on Our Sites
Identity and Contact Information.
For the purposes of identifying and effectively providing the appropriate product and service.
Providing and managing your Account.
Identity and Contact Information.
User information and history.
For the purposes of correctly identifying and providing services to you.
For the purposes of understanding what services or products have been used or purchased.
Providing and managing your access to Our Sites.
Identity Information or User login details, Profile information.
For the purposes of identifying and effectively providing the appropriate product and service.
Personalising and tailoring your experience on Our Sites.
Identity Information, User login details, Profile information.
For the purposes of identifying which services or products have been used or purchased.
For the purposes of marketing to those who have subscribed.
Administering Our Sites.
Identity Information, Profile Information.
For the purposes of ensuring services or products are in working order.
For the purposes of making necessary amendments to products or services.
Administering our business.
Identity Details, Contact Details, Payment Information.
For the purposes of ensuring that services or products purchased are paid for by you and all necessary receipts, acknowledgements or invoices can be sent.
Supplying our products and/or services to you.
Identity details, Contact details, Payment information.
For the purposes of contacting you to provide the service or product requested by you.
Managing payments for our products and/or services to you.
Identity details, Contact details, Payment Information.
For the purposes of delivering the requested service or product requested by you.
Personalising and tailoring our products and/or services to you.
Identity details, Contact details.
For the purposes of contacting, replying to and understanding your requirements for any personalised service or product.
Communicating with you.
Identity details, Contact details.
For the purposes of contacting you for legal marketing purposes or to fulfil a contract for services or products, or in response to any contact made by you to Us.
Supplying you with information by email and/or that you have opted-in-to (you may opt-out at any time by subscribing to receiving products or marketing.
Identity details, Contact details, Profile details.
For the purposes of legal marketing or providing information on our services or products to you.
5. Marketing
5.1. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or post and/or telephone with information, news, and offers our products and/or services. You will not be sent any unlawful marketing or spam.
5.2. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
5.3. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
6. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: admin@clamediation.com
Postal Address: CLA Mediation & Training Ltd, Rowan House Barnett Way, Barnwood, Gloucester, England, GL4 3RT.
7. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on our Sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use Our Sites following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 9thMarch 2024.
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