Policy key definitions:
- “I”, “our”, “us”, or “we” refer to the business, [Business name & other trading names].
- “you”, “the user” refer to the person(s) using this website.
- GDPR means General Data Protection Act.
- PECR means Privacy & Electronic Communications Regulation.
- ICO means Information Commissioner’s Office.
- Cookies mean small files stored on a users computer or device.
Processing of your personal data
Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.
- We are exempt from registration in the ICO Data Protection Register because we only process information for core business purposes.
- Lawful basis: Legitimate interests
The reason we use this basis: Positive Psychology Training uses this basis to allow us to respond to enquiries and provide the services offered.
We process your information in the following ways: Information is processed solely for the purpose of responding to enquiries, an annual newsletter and the occasional communication with clients. Name and email address of previous clients is held on a database in Word. Information for those who sign up to the newsletter is stored securely on the email marketing system: Mailchimp.
Where enquiries are sent via the contact form or directly to our business email address, the email address/name of the sender is saved securely in the email providers address book.
Data retention period: As long as is required.
Sharing your information: We do not share your information with third parties and have never done so.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
Your individual rights
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options.
Cookies that we use are;
- PHPSESSID – Provided by Positive Psychology Training.co.uk
This cookie creates a unique session for your device. No personal information is stored or collected.
The session allows us to display a simple message upon any form being submitted by the user. eg. If a contact form is submitted with errors, the sessionID is used to return the error to the user stating the errors so that they can be corrected.
- _ga – Google
This allows us to use Google Analytics to analyse visitors to a page and how you use our site so we can improve the user experience. No Personal information is collected or stored.
Data security and protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Transparent Privacy Explanations
We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all MailChimp lists, by following this link, otherwise contact the EMS provider.
Our EMS provider is; MailChimp. We hold the following information about you within our EMS system;
- Email address
- I.P address
- Subscription time & date
Resources & further information