This Policy applies to both personal information supplied to us either by an individual or by others. We may use personal information supplied to us for any of the purposes as set out in this Policy, or as otherwise disclosed at the point of collection.
This Policy is an important document. We recommend that you read it carefully and print and keep a copy for your future reference.
In this Policy, we use the terms:
- “Thriving”, “we”, “us”, and “our” (and other similar terms) to refer to Thriving London Ltd (registered company number: 09438902)
- “Personal Information” is any information relating to an identified or identifiable natural person;
- “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identification number, or to one or more factors; and
- “you” and “your” (and other similar terms) refer to our clients, individuals associated with our clients, coachees, contacts, suppliers, consultants and subcontractors, business contacts, job applicants, learning platform users, staff and visitors to the Thriving London Ltd website, thriving.london
Your rights in relation to Personal Information and how to exercise them
Under certain circumstances you have the following rights:
- the right to ask us to provide you, or a third party, with copies of the Personal Information we hold about you at any time and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of local law;
- the right to request erasure, anonymisation or blocking of your Personal Information that is processed in breach of the law;
- the right to object on legitimate grounds to the processing of your Personal Information. In certain circumstances we may not be able to stop using your Personal Information, if that is the case, we’ll let you know why;
- withdrawal of consent – while we do not generally process Personal Information on the basis of consent, if Personal Information is ever processed on the basis of consent an individual may withdraw this consent at any time (this may apply to processing of special categories of Personal Information including the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership).
To exercise such rights and if you have any questions about how we collect, store and use Personal Information, then please contact us using the details as set out at the end of this Policy.
What basis do we have for processing your Personal Information?
We will only process personal Information where we have a lawful reason for doing so. The lawful basis for processing Personal Information by us will be one of the following:
- the processing is necessary in order for us to comply with our legal obligations (such as compliance with legislation);
- the processing is necessary for the pursuit of our legitimate business interests including that of the delivery of our services (for example, we have been introduced to you, to potentially provide coaching services to you or your organisation);
The Information we collect:
Depending on the circumstances, the information we may hold for you may include:
Your full name
Your contact details (email, preferred contact numbers, home address)
Your company name and job title
Your area of business
Other business contact information
Your full name
Your company name and job title
Your job role and areas of responsibility
Information shared by you as part of the briefing or coaching arrangement
Coaching briefs on either the coaching to be undertaken or the work you have undertaken with Thriving London Ltd
Details of work undertaken with Thriving London Ltd, such as session rates and timings
Online Course Participant:
Your full name
Your company name (if applicable)
Your email address
What we do with that information?
We use your contact details to:
- Keep you informed of developments at Thriving London Ltd and the services we offer which (changed that to which) we believe may be relevant to you
- Schedule meetings
- Maintain billing purposes
- Share news about any events we are organising or participating in
- Perform analytics – such as trends and course evaluation and metrics.
Thriving London Ltd’s relationship with you:
Clients – We are required to keep a record of the number of hours we have worked with you. Each year, your name, company and email address are kept for 5 years but this information is only ever shared with the professional body to ensure we as coachees are maintaining the standards necessary for professional registration.
Session notes may be kept for a maximum period of five years from the completion of the coaching assignment and then archived for a maximum of seven years before being destroyed. You can request a copy of your data as stipulated by the legislation.
Who else may have access to your Personal Information?
On occasion, in addition to the specific sharing set out above, we may need to share your Personal Information with third parties. We will only share Personal Information where we are legally permitted to do so.
Where you supply us with Personal Information as a client we will assume, unless you instruct us otherwise in writing, that we can disclose your Personal Information in such manner as we believe is reasonably necessary to provide our services (including as described in this Policy), or as is required under applicable law. For example, we may pass your Personal Information to third parties such as:
- professional regulatory bodies
- providers who administer psychometric tests where appropriate for a coaching relationship. We will provide contact details to those providers only for the purpose of initiating the service. Some of these providers may be outside the EU and we endeavour to ensure they comply with the relevant data protection legislation
- disclosures required by law or regulation: in certain circumstances, please note that we may be required to disclose Personal Information under applicable law or regulation, including law enforcement agencies or in connection with proposed or actual legal proceedings
- credit checkingagencies for credit control reasons
- events: we may need to pass on your Personal Information (e.g. name, company, occupation) to a third party in connection with management of an event, in which case the details will only be used by the third party for that specific purpose
- business partners, service providers and other affiliated third parties: to enable us to provide our services to you, we may need to share your Personal Information with our business partners (including professional advisers such as accountants or auditors), or external service providers. Our arrangements with external service providers currently cover the provision of support services including IT, events management, document production, business research, accounting, administration, bookkeeping and secretarial services.
How we hold your data: Confidentiality & Security
Thriving London Ltd works with Daylite or Thinkific (for online courses) to keep and maintain the personal information we hold. Daylite and Thinkific are based outside the EU but comply with all the privacy and security provisions required by GDPR.
Thriving London Ltd treats the information you provide us with as confidential and we do not sell any personal data on to third parties and we only share any personal information for legitimate business reasons.
Thriving London Ltd protects your information through administrative measures from all our staff both electronically and physically.
The conditions where we cannot maintain confidentiality is where we become aware of illegal activity or where the physical or mental health of the coachee or others is, in our judgement, seriously at risk.
Links to other websites
The Thriving London Ltd website www.thriving.londonmay link to other, unaffiliated third-party websites. Please note that Thriving is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third-party websites. You must always carefully review the privacy and confidentiality policy of any third-party website that you may visit in order to understand how the operators of that website may collect, store and use your Personal Information.
Our online courses are hosted by Thinkific Labs Inc. (“Thinkific”). They provide us with the online course creation platform that allow us to sell our product/services to you.
Your data is stored through Thinkific’s data storage, databases and the general Thinkific application. They store your data on a secure server behind a firewall.
If you make a purchase on our site, we use a third-party payment processor such as Stripe or Paypal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.
For more insight, you may also want to read Thinkific’s Terms of Service here https://www.thinkific.com/resources/privacy-policy/ or Privacy Statement here https://www.thinkific.com/resources/terms-of-service/.
Updates to this Policy
This Policy was last updated in 8thMarch 2019. Please check back regularly to keep informed of updates to this Policy.
Removing your data:
You can be deleted from our database at any time by contacting Colette Preston (firstname.lastname@example.org) and we will ensure you are not contacted in the future, unless we receive a written request from you.
Data Controller and Privacy Officer:
Thriving London Ltd is a data controller and our CEO is our Privacy Officer. If you would like to exercise your rights as set out in this Privacy Notice, you may contact Mark Mulligan on email@example.com
Whilst we hope that you will not need to, if you do wish to complain about our use of Personal Information please send an email detailing your complaint to the Privacy Officer above.
You also have the right to lodge a complaint with the supervisory authority at:
Information Commissioner’s Office
Wycliffe House, Water Lane
Tel: 0303 123 1113
Tel: 029 2067 8400 (calls in Welsh)
If you have any questions concerning this policy document or if you require any additional information please do not hesitate to contact us at: firstname.lastname@example.org