1. Commitment to user privacy
The Future Factory Training is committed to protecting your privacy.
Please read the following information carefully to understand our views and practices regarding your personal data and how we will look after it.
2. Data controller
3. Contact details
Full name of legal entity: The Future Factory Training Limited
Email address: email@example.com
Postal address: 2a Wrotham Business Park, Barnet, Hertfordshire EN5 4SZ
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.
4. Types of information collected
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 (anonymous data).
We may collect and process the following personal data about you:
a) Identity Data includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, job title, employer details, personal description and photograph.
b) Contact Data includes address, email address and telephone numbers.
c) Financial Data includes bank account and payment card details.
d) Transaction Data includes details about payments to and from you, details of services you have purchased from us, and feedback and survey responses
e) Technical Data includes internet protocol (IP) address, browser type and version, browser plug-in types and versions, operating system and platform, referring website addresses and information about your visit including access times, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods to browse away from the page.
f) Usage Data includes information about how you use our website and services.
g) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Unfortunately, the transmission of information via the internet is not completely secure. Although we have strict procedures and security measures in place, we cannot guarantee the security of your data transmitted to us by email.
5. Methods of data collection
We use different methods to collect data from and about you including through:
a) Direct interactions. You may provide us with personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
b) 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 cookies policy).
c) Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below
i) Technical Data from analytics providers, advertising networks and search information providers:
ii) Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
6. Storage of personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In 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.
7. Data retention
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 customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
8. Use of personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
a) Where we need to perform the 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.
We may use the personal data which we collect about you in the following ways:
a) to register you as a new customer;
b) to carry out our contract with you;
c) to manage our relationship with you;
d) to administer and protect our business (including our website):
e) to deliver relevant website content and advertisements to you;
f) to use data analytics to improve our website, services, marketing, customer relationships and experiences; and
g) to make suggestions and recommendations to you about services that may be of interest to you.
9. Marketing communications
We aim to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages at any time
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You have the right to withdraw consent to marketing at any time by contacting us.
10. Disclosure of your personal data
We may share your personal data with the parties set out below for the purposes set out in paragraph 7:
a) Service providers and sub‐contractors retained to perform functions on our behalf or to provide services to us (such as data processing, software development, website hosting and management, market research, information technology and office services);
b) Professional advisers acting as processors including lawyers, bankers, accountants, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
c) HM Revenue & Customs, regulators and other authorities acting as processors based who require reporting of processing activities in certain circumstances;
11. International transfers
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:
1) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
2) Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
3) Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
12. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as follows:
a) 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.
b) 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.
c) 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.
d) 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.
e) 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:
i) If you want us to establish the data's accuracy.
ii) Where our use of the data is unlawful but you do not want us to erase it.
iii) 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.
iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
f) 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.
g) 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our DPO at firstname.lastname@example.org
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.