COOKIE & PRIVACY POLICIES

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PRIVACY POLICY

Definitions:
We, Us, Our,  The Confidence Vault Ltd (“TCV”) – refers to The ConfidenceVault Limited and any of its subsidiary companies.
Data Protection Legislation – refers to all applicable privacy and data protection laws including (i) the General Data Protection Regulation ((EU) 2016/679), the Data Protection Act 2018 and any further or additional national implementing laws, regulations and secondary legislation in England and Wales relating to the processing of Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426).

Introduction
This page explains to you our Privacy Policy.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you how we look after your personal data. It will also tell you about your privacy rights, and how the law protects you.

Purpose of this Privacy Policy
This policy aims to give you information on how we collect and process your personal data through your use of this website.
This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you. This is important so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller
The ConfidenceVault Ltd is the controller and responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details below.

Changes to this Privacy Notice and your duty to inform us of changes to your Personal Data
We keep this privacy policy under regular review. This version was last updated in August 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.

Third-party links
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.

What we mean by 'Personal Data' / 'Personal Information' we receive
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (this is known as anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  • Identity data (including your first name, last name,  marital status, title, gender and multi media images);
  • Contact data (including your billing address, delivery address, email address, telephone contact numbers and social media contact information);
  • Financial Data (including bank account and payment card details).
  • Transaction Data (including details about payments to and from you and other details of products and services you have purchased from us).
  • Technical Data (including internet protocol (IP) address, your login data, 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 this website).
  • Profile data (includes your username and password, purchase history, preferences, feedback and survey responses);
  • Usage Data (including information about how you use our website, products and services].
  • Marketing and Communications data (including your preferences in receiving marketing from us and your communications preferences);
  • Special Category Data (dietary or access requirements when booking and attending events)

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage 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 generally collect any Special Categories of Personal Data about you on Our Site (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.

There may be unavoidable requirements or occassions where there may be a prerequisite for some special category data and that may be collected on a multimedia device at a ConfidenceVault event or when applying for some volunteer positions with The ConfidenceVault. In these cases prior consent will be sought from you to process the data.

Risks to receiving product/ service if you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions.
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you

  • apply for membership;
  • apply for one of our training courses;
  • express an interest in one of our training courses;
  • sign up to our newsletter;
  • express an interest in ConfidenceVault Club membership;
  • express an interest in other membership;
  • purchase and/ or register for one of our training courses;
  • Subscribe to emails communication as a non-member;
  • Subscribe to emails communication as a non-client;
  • request information about TCV services;
  • attend a TCV event;
  • enter a competition, promotion or survey: or give us feedback or contact us.

Automated technologies or interactions.
As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Please see our Cookie Policy for further details.

Third parties or publicly available sources.
We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers, such as Google based outside the EU;
    • search information providers, such as Google based outside  the EU;
  • Identity, Contact and Financial Data from TCV coaching and training Associates
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators based inside the EU.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
  • Profile data from TCV service providers

How will your personal data be used?
  1. We will only use your data in circumstances where the data protection legislation allows us to. Most commonly, we will use your personal data in the following circumstances:
  • a. Where we need to perform a contract we are about to enter into or have entered into with you;
  • b. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • c. Where we need to comply with a legal obligation;
  • d. Where we have received your informed and specific consent to do so.

We have set out below, in a table format and within the numbered paragraphs thereafter, 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.

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 data. Please contact us if you need details about the specific legal grounds 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
To register you as a client, TCV Club member or subscriber
(a) Identity data
(b) Contact data
(a) Performance of a contract with you
As a client or TCV Club member, to provide you with

(a) information about your client services
(b) information about Club membership benefits

(c) local news and events,

(d) sponsor-mentor and matching activity

(e) TCV newsletters, other publications, email and webinars
(a) Identity data
(b) Contact data
(c) Marketing and Communications data
(b) Contact data
(c) Marketing & Communications data
(a) Necessary for our legitimate interests (to ensure that clients are made aware of the support services offered by TCV)
As a non-club member, or potential client, to provide you with  information about  our club membership and services
a) Identity data(b) Contact data
(c) Marketing & Communications data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing & Communications data
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To promote the work of TCV and the contribution of female and black minority career professions to the UK economy
(a) Identity
(a) Necessary for our legitimate interests (to promote clients and sponsor-mentor arrangements)
(b) Consent (where special category data has been collected)
To administer events and register you as an attendee or applicant
(a) Identity data
(b) Contact data
(c) Special category data
(a) Performance of a contract with you
(b) consent (dietary and access requirements)
To enable you to partake in or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing & Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how clients and TCV Club members use our products/services, to develop them and grow our career or sponsor-mentorship of specific contracted personal development)
To process, verify and validate nominations for a TCV volunteer task allocation
(a) Identity
(b) Contact
(a) Consent
To use data analytics to improve our website, products/services, marketing, events, customer relationships and experiences
(a) Technical
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
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
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing & Communications

(f) Technical
(a) Necessary for our legitimate interests (to study how customers and TCV Club members use our products/services, to develop them, to grow our business and to inform our marketing strategy)
2.  We will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  We can explain this to you.  If we need to use your data for an unrelated purpose, we will notify you and explain why we can do this.  Please note that we can process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing 
Your personal data may be used to:- 
  1. Provide you with a more personalised experience whilst using our website, including advertisements for relevant services and products.
  2. Keep you informed about services and products available to you as an client, or TCV Club member, unless you have told us that you do not wish to receive such information. This could be by email, postal mail, phone or text.
Opting out    
You can ask us to stop sending you marketing messages at any time by logging into the website and adjusting your communication preferences.   Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of your membership.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Sharing Personal Information 
We may disclose your personal information to third parties in the following circumstances:
  • When a specific service is being provided on our behalf. We will ensure that your personal information is handled as if we were processing it ourselves and under the same terms as this privacy notice. We will only share the minimum information that they need to undertake the service and we will ensure that they keep your information secure.
  • When we are providing a service on your behalf. This data will be collected through online application forms, which are to be completed voluntarily, and will only be shared with the organisations identified at the time it is received.
  • When you have requested information about a service or product provided by an affiliated partner and only with your specific consent.
  • When you are a member to your local membership adviser to ensure you receive the best support from TCV.

International Transfers
In general personal data collected from you will be stored at a destination within the UK or European Economic Area (EEA). However we may also transfer your 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 or organisations which have been deemed to provide an adequate level of protection for personal data by the United Kingdom
  • Where we use certain service providers, we may use specific contracts approved by the United Kingdom which give personal data the same protection it has in Europe.  
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security
We have put in place appropriate security measures to prevent your personal data from 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 have put in place procedures 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.

Data retention
For how long will we use your personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our members (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being clients or TCV Club members for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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. 

Your Legal Rights
Under the data protection legislation you have a number of rights with regard to your personal data. 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.

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: 
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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. 
  • 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.
You do not have to pay any fee to request access to the personal information that we hold.  However, if your requests become unfounded, repetitive or excessive we have the right to refuse your request or charge you a reasonable fee.



How to remove cookies
The option to delete cookies is from your browser usually under Settings, History or Security.
For browser and social media specific instructions please see below:
Internet Explorer
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More information can be found in our Cookie Policy

Embedded content from other websites
Our websites may include embedded content (e.g. videos, images, forms, etc.). Embedded content from other websites may behave as if the visitor has visited the the website directly. Once you have interacted with these embedded scripts websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.


Links to other websites
Our websites may contain links to other websites not under our control. If you leave our websites using one of these links we cannot be held responsible for the protection and privacy of any information which you provide whilst visiting sites not governed by this privacy statement. Please exercise caution and look at the privacy statement on the website in question.


Changes to Our Privacy Policy
We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations.

We recommend that you check this page regularly to keep up-to-date.


Additional Information
If you have any questions about how theConfidenceVault uses your personal data, or you want to exercise your rights concerning your personal data, please contact us via hello@theconfidencevault.com or write to Data Protection Enquiries, TheConfidenceVault, 41 Whitcomb Street, London WC2H 7DT 

Under the GDPR, you have:
  • The right to request access to, deletion of or correction of, your personal data held by Us
  • The right to complain to a supervisory authority
  • Be informed of what data processing is taking place
  • The right to restrict processing
  • The right to data portability
  • Object to processing of your personal data
  • Rights with respect to automated decision-making and profiling
.
Complaints
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. 


Where to Make a Complaint
Identity and contact details of controller and data compliance advisor
ConfidenceVault Limited is the controller of data for the purposes of the data protection legislation.
If you have any concerns as to how your data is processed, or if you have any questions about this privacy policy or our privacy practices more generally, you can contact our data compliance managers at data.controller@theconfidencevault.com or you can write to us at:
FAO Data Compliance Manager
The ConfidenceVault Ltd
41 Whitcomb Street
London
WC2H 7DT

If you have a complaint regarding any aspect of your personal data or this privacy policy, please write to us at the above address.

If you are still not satisfied with the outcome of your complaint, you may write to the Information Commissioner’s Office at the following address:
Information Commissioner’s Office, 
Wycliffe House, 
Water Lane, 
Wilmslow, 
Cheshire, 
SK9 5AF

You can also contact the Information Commissioner’s Office using their online form: https://ico.org.uk/global/contact-us/email/