This Privacy Policy tells you the types of information we collect about you when you visit our website, use our services, which we otherwise obtain directly from you or from a third party, how we use that information and the instances in which we share your information. This Privacy Policy may change from time to time so please check this policy regularly.
Our website and services are not intended for children and we do not knowingly collect data relating to children.
For the purposes of this Privacy Policy, the term “personal data” means any information which identifies you or which allows you to be identified when combined with other information.
Truecourse Limited is the controller and responsible for your personal data (collectively referred to as (“Truecourse”, “we”, “us” or “our” in this Privacy Policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Full name of legal entity: Truecourse Limited
Data privacy manager: Managing Director
Email address: j.strassberg@truecourselaw.com
Postal address: 86-90 Paul St., 3rd Flr, London EC2A 4NE
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (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.
This version was last updated on December 9, 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
In connection with the conduct of our business, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier, title.
• Contact Data includes work address, email address and telephone numbers.
• Technical and Usage Data includes information about how you access and use our website, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website, the pages you have visited on our website and the links you have followed on them.
• Profile Data is only collected should you decide to engage our services and is not collected via the website. It includes your job title, your employer, feedback and other information necessary to provide services to you.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Technical Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We use different methods to collect data from and about you including through:
You may give us your Identity, Contact Data, Profile Data and Marketing and Communications Data in person, or by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• request our services;
• meet with one of our employees or consultants;
• participate in an event which we have organised;
• subscribe to our publications;
• request marketing to be sent to you;
• make a complaint or give us some feedback.
As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the “Cookies” section below for further details.
We may receive personal data about you from various third parties as set out below:
• Technical and Usage Data from the following parties:
(a) analytics providers;
(b) advertising networks;
(c) and search information providers.
• Identity and Contact Data from publicly availably sources such as Companies House.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where it is necessary for our legitimate interests (or those of a third party) and we have assessed that your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
In general, we do not rely on consent as a legal basis for processing your personal data. You have the right to opt out of receiving marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To manage our relationship with you and your business which may include:
(a) taking instructions for our services; (b) ordering products and services from you; (c) managing payments and fees; (d) collecting and recovering money owed to us; (e) dealing with your enquiries and complaints; (f) notifying you about changes to our terms or privacy policy; (g) asking you to leave a review or take a survey. |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Necessary for our legitimate interests (to be able to provide our services to our clients, to obtain products and services from our suppliers)
(b) Necessary to comply with a legal obligation |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical and Usage |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
(b) Necessary to comply with a legal obligation |
| To use data analytics to improve our website, services, marketing, customer relationships and experiences | (a) Technical and Usage | Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about products and services that may be of interest to you | (a) Identity
(b) Contact (c) Technical and Usage (d) Profile (e) Marketing and Communications |
Necessary for our legitimate interests (to develop our services and grow our business) |
| To enable you to complete a survey | (a) Identity
(b) Contact (c) Profile (d) Technical and Usage (e) Marketing and Communications |
Necessary for our legitimate interests (to study how clients use our services, to develop them and grow our business) |
| Purpose/Activity |
|---|
| To manage our relationship with you and your business which may include:
(a) taking instructions for our services; (b) ordering products and services from you; (c) managing payments and fees; (d) collecting and recovering money owed to us; (e) dealing with your enquiries and complaints; (f) notifying you about changes to our terms or privacy policy; (g) asking you to leave a review or take a survey. |
| Type of data |
| (a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
| Lawful basis for processing including basis of legitimate interest |
| (a) Necessary for our legitimate interests (to be able to provide our services to our clients, to obtain products and services from our suppliers)
(b) Necessary to comply with a legal obligation |
| Purpose/Activity |
|---|
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
| Type of data | (a) Identity
(b) Contact (c) Technical and Usage |
| Lawful basis for processing including basis of legitimate interest | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
(b) Necessary to comply with a legal obligation |
| Purpose/Activity |
|---|
| To use data analytics to improve our website, services, marketing, customer relationships and experiences |
| Type of data | (a) Technical and Usage |
| Lawful basis for processing including basis of legitimate interest | Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| Purpose/Activity |
|---|
| To make suggestions and recommendations to you about products and services that may be of interest to you |
| Type of data |
| (a) Identity
(b) Contact (c) Technical and Usage (d) Profile (e) Marketing and Communications |
| Lawful basis for processing including basis of legitimate interest | Necessary for our legitimate interests (to develop our services and grow our business) |
| Purpose/Activity |
|---|
| To enable you to complete a survey |
| Type of data |
| (a) Identity
(b) Contact (c) Profile (d) Technical and Usage (e) Marketing and Communications |
| Lawful basis for processing including basis of legitimate interest |
| Necessary for our legitimate interests (to study how clients use our services, to develop them and grow our business) |
We strive to provide you with choices regarding marketing and advertising. We may use your Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you.
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
You can ask us or third parties acting on our behalf to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Our website uses cookies and similar technologies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website. We may share information about your use of our websites with our analytics partners. For more information about our use of cookies, please see our cookies policy.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
• Our third-party service providers who perform functions on our behalf in connection with the operation of our business such as IT service providers and system administrators, third parties who host and manage data, deliver our products and services etc.
• Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services.
• Our third-party analytics partners to analyse website traffic and understand customer needs and trends.
• Third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our website or customers.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy. To enable you to complete a survey(a) Identity (b) Contact (c) Profile (d) Technical and Usage (e) Marketing and CommunicationsNecessary for our legitimate interests (to study how clients use our services, to develop them and grow our business)
• 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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Our third-party service providers may be located outside the EEA, in which case their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
• Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will notify you and any applicable regulator of a breach where we are legally required to do so.
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, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
You can request details of retention periods for different aspects of your personal data by contacting us. In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms (other than in the case of direct marketing).
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
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.
