1. Who are we?
In this policy, references to ‘we’ or ‘us’ are to https://courses.nicolaaskham.com/ a Thinkific platform used by Nicola Askham Ltd which is a registered company in England and Wales.
2. What information do we collect and what do we do with it?
What we need
The Nicola Askham Limited is what’s known as the ‘controller’ of the personal information you provide to us.
When you enrol as a student or subscriber (“learner”) on our site or related courses, as part of the enrolling process, we collect the personal information you give us. We usually collect basic personal information such as your name, email address, telephone number and your payment details if you are purchasing from us.
Why we need it
The information is either needed to fulfil your request or to enable us to provide you with a more personalised service. You don't have to disclose any of this information to browse our site. However, if you choose to withhold requested information, we may not be able to provide you with certain services.
Sometimes, with your consent, we will process your personal information to provide you with information about our work or our activities that you have requested or are expecting.
On other occasions, we may process personal information when we need to do this to fulfil a contract (for example, if you have purchased training courses) or where we are required to do this by law or other regulations.
Nicola Askham Limited processes your information when it is in our legitimate interests to do this and when these interests do not override your rights. Those legitimate interests include providing you with content on Data Governance, information on our upcoming events, services, newsletter requests, feedback, changes to the course, and other activities.
How do we obtain your details?
When you provide us with personal information to become a learner on our site, make a purchase, or participate in the course, you imply that you consent to our collecting it and using it.
We will also hold information about your details so that we can respect your preferences for being contacted by us. We collect your personal information in a number of ways:
- When you provide it to us directly.
- When we collect it as you use our websites or apps.
- When you have given it to a third party and you have provided permission to pass your information on to us.
If you are under 16 please ensure you obtain your parent/guardian's consent before sending any personal information to any website or Nicola Askham Limited.
Please note that we will not knowingly market to or accept orders for goods or services from persons aged under 18 years. As a parent or guardian, we encourage you to be aware of the activities in which your children are participating, both offline and online. If your children voluntarily disclose information, this may encourage unsolicited messages. We suggest that you discourage your child from providing any information without your consent.
How do I withdraw my consent?
If you would like to change the way you hear from us or no longer wish to receive direct marketing communications from us then use the contact form on our Contact page.
3. Legitimate Interests
The new data protection requirements have a number of reasons by which we can use the personal information you provide to us. One of these is called ‘legitimate interests'.
This means that we have the potential to use your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests. So, what does this mean? When you provide your personal details to us we may use your information to help you understand more about what we do as an organisation. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights.
Some typical examples of when we might use the approach are for preventing fraud, direct marketing, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns.
How we may use your personal information
Direct Marketing: We will send email marketing which further the aims and objectives of the company. We will also make sure our email marketing is relevant for you, tailored to your interests.
Event registration: In order for us to register you for an event, payment has to be taken and contact information collected, such as name, credit card number and telephone number, provided.
Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.
Personalisation: Where the use of the information enables us to personalise, enhance or otherwise improve our communications for the benefit of our customers.
Analytics: To use your personal information for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.
Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.
Due Diligence: We need to undertake due diligence on potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.
We will also hold information about you so that we can respect your preferences for being contacted by us.
Before we use your personal information for our legitimate interests, we will always consider and balance any potential impact on you and your rights under data protection legislation and any other relevant law. Our legitimate business interests do not automatically override your interests – we will never use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
4. Sharing Your Information
We do not share your information with any other organisations or individuals unless we are when obliged to by law, for purposes of national security, taxation and criminal investigations and in the following instances:
- If you have agreed that we may do so.
- When we use other companies to provide services on our behalf, e.g. sending emails, customer analysis, assessment when using auditors/advisors or processing credit/debit card payments.
- If we merge with another organisation to form a new entity, information may be transferred to the new entity.
- We may disclose aggregate statistics about our site visitors, supporters, customers and sales to describe our services and operations to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics won’t include any personally identifying information.
- If we run an event in partnership with other named organisations your details may need to be shared. We will be very clear about what will happen to your data when you register.
And, we will never sell or rent your personal information to other organisations.
5. Retaining your information
We hold your information only as long as necessary for each reason that we use it. We have provided some examples of the time we will keep your information in this paragraph but you can contact us for more information.
If you decide not to support Nicola Askham Limited any more or request that we have no further contact with you, we will keep some basic information in order to avoid sending you unwanted materials in the future and to ensure that we don’t accidentally duplicate information.
If you make a purchase from us, we will keep the purchase information for a period of seven years for accounting purposes.
If you sign up for our newsletter we will retain your details for as long as you wish to receive the emails and will delete your details within one week of you unsubscribing.
Our course and site is hosted by Thinkific Labs Inc. (“Thinkific”). They provide us with the online course creation platform that allows 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.
For more information, you can read the following:
Thinkific’s Terms of Service: https://www.thinkific.com/resources/privacy-policy/
Privacy Statement: https://www.thinkific.com/resources/terms-of-service/
7. Third-Party Services
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
All the personal information we process is processed within the EEA. However, for the purposes of IT hosting and maintenance your information may be situated outside of the European Economic Area (EEA). This will be done in accordance with guidance issued by the Information Commissioner’s Office.
If you make a purchase on our site, we use Thinkific’s 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.
Web Analysis Tools
We may use web analysis tools that are built into our course site to measure and collect anonymous session information.
11. How to Contact Us
If you wish to raise a complaint on how we have handled your personal information, you can contact firstname.lastname@example.org who will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law you can complain to the Information Commissioner’s Office (ICO).
If you wish to talk to us about anything in the policy or the information we hold about you please contact us:
By telephone: +44 7854 983700
By email: email@example.com
By post: 1 Hillcrest Road, Orpington, Kent BR6 9AN, UK