LaSA Training Programmes – PRIVACY NOTICE
LaSA Training Programmes (we, us, or our), understand that protecting your personal data is important. This Privacy Notice sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when providing our Training Services or when otherwise interacting with you. It is important that you read this Privacy Notice together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you so that you understand our privacy practices in relation to your data.
● Identity Data including first name, middle name, last name, title, gender, job title, photographic identification, marital status, title, and images of you.
● Contact Data including billing address, delivery address, email address and telephone numbers.
● Financial Data including bank account and payment card details (through our third-party payment processor, e.g. Stripe or Pay Pal.
● Background Verification Data including your photographic identification or other details requested as part of our [onboarding OR verification OR Know Your Customer] process to comply with our due diligence obligations, anti-money laundering laws and related ongoing monitoring commitments.
The information we collect:
Personal information: information that relates to an identified or identifiable individual. We may collect, use, store, and disclose different kinds of personal data about you which we have listed below:
● Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
● Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.1
● Profile Data including support requests you have made, content you post, send receive, and share through our platform, information you have shared with our social media platforms, your interests, preferences, feedback, and survey responses.
● Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys, contests, promotions, activities or events.
● Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
● Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.
● Special Categories of Personal Data is a special category of personal data that 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.
We do not actively request special categories of data about you, nor do we collect any information about criminal convictions and offenses. If at any time we need to collect special categories of data about you, we will only collect it and use it as required or authorised by law.
We collect and process personal data about you only where we have a legal basis for doing so under applicable laws. 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 reach out to us if you need further details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out below:
How we collect personal information
We collect personal data in a variety of ways, including:
● Directly: We collect personal information which you directly provide to us, including through the ‘contact’ form on our website or when you request our assistance via email, or over the telephone.
● Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as e.g. when you use our website, in emails, over the telephone and in your online enquiries or whilst providing our Training Services.
● From third parties: We collect personal information from third parties, such as e.g. from your employer where they invite you to access our Services and details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
Purposes and legal bases for processing
Purpose of use/disclosure: To enable you to access and use our software including to provide you with a login.
Type of Data: Identity and Contact Data
Purpose of use/disclosure: To provide our services to you, including to register your attendance at our events, assess your application, manage your appointments.
Type of Data: Identity and Contact Data
Legal basis for processing: Performance of a contract with you.
Legal basis for processing: Performance of a contract with you.
● From publicly available sources: We collect personal data from publicly available resources such as Companies House and professional networking sites such as LinkedIn.
Purpose of use/disclosure: To contact and communicate with you about our Services, including in response to any support requests you lodge with us or other enquires you make with us.
Type of Data: Identity, Contact and ProfileData
Legal basis for processing: Performance of a contract with you.
Purpose of use/disclosure: To contact and communicate with you about any enquiries you make with us via our website.
Type of Data: Identity and Contact Data
Legal basis for processing: Legitimate interests: to ensure we provide the best client experience we can offer by answering all your questions.
Purpose of use/disclosure: For internal record keeping, administrative, invoicing and billing purposes.
Type of Data: Identity, Contact, Financial and Transactional Data
Legal basis for processing: Performance of a contract with you. To comply with a legal obligation. Legitimate interests: to recover debts due to us and to ensure we can notify about changes to our terms of business and any other administrative points.
Legal basis for processing: Legitimate interests: to keep our website updated and relevant, to develop our business, to improve our Services and to inform our marketing strategy.
Type of Data: Profile, Technical and Usage Data
Purpose of use/disclosure: For analytics, including profiling on our website, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.
Legal basis for processing: Legitimate interests: to develop our Services and grow our business.
Type of Data: Identity, Contact, Profile, Technical and Usage, Marketing and Communications Data
Purpose of use/disclosure: For advertising and marketing, including to send you promotional information about our events and experiences, and information we consider may be of interest to you.
Legal basis for processing: Legitimate interests: to facilitate engagement with our business and to grow our business.
Type of Data: Identity, Contact, Profile, Interaction, Marketing and Communications Data
Purpose of use/disclosure: To run promotions, competitions and/or offer additional benefits to you.
Legal basis for processing: Legitimate interests: to consider your employment application.
Type of Data: Identity, Contact and Professional Data
Purpose of use/disclosure: You applied for employment with us, to consider your employment application.
Legal basis for processing: To comply with a legal application.
Type of Data: Identity, Contact, Profile, Transactional, Interaction and Professional Data
Purpose of use/disclosure: To comply with our legal obligations or if otherwise required or authorised by law.
If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.
Our disclosure of personal information to third parties
We may disclose personal information to:
our employees, contractors and/or related entities;
IT service providers, data storage, web-hosting and server providers such as Hostinger;
marketing or advertising providers;
professional advisors, bankers, auditors, our insurers and insurance brokers;
payment systems operators such as e.g. Stripe, PayPal.
our existing or potential agents or business partners;
sponsors or promoters of any promotions or competition we run;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses];
any other third parties as required or permitted by law, such as where we receive a subpoena.
Google Analytics: We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.
You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On Android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.
Where we disclose personal data to the third parties listed above, these third parties may store, transfer or access personal data outside of the United Kingdom including The EU, The USA, Canada, Australia, and New Zealand. The level of data protection in countries outside of the United Kingdom may be less comprehensive than what is offered in the United Kingdom. Where we transfer your personal data outside of the United Kingdom, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal data in accordance with this Privacy Notice. This includes:
Overseas transfers
only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or
including standard contractual clauses in our agreements with third parties that are overseas.