Privacy Statement
Last Updated June 2021

Rethink Academy Ltd
Privacy Statement
(for customers)

CONTENTS

 - Introduction 
 - What Data Do We Collect and Why? 
 - What We Do With Your Personal Data
 - When And How Do We Collect Your Data?
 - How Do We Store and Protect Your Data?
 - Who We Share Your Data With And Why?
 - Your Data Protection Rights
 - Contact Us
 - How To Complain 

Introduction

We respect your privacy and protect your personal data like it is our own personal data.

This is the Privacy Statement of Rethink Academy Limited (referred as ‘we’, ‘us’, ‘our’) registered with the Information Commissioner’s Office with number ZA346901. In legal terms, we are the Controller of your data. The objective of this Privacy Statement is to explain to you in a simple and transparent manner, what personal data we collect, why and how we protect it. This applies to you if you are:

 - A current or previous customer
 - Contacting us with a query
 - Visiting our website, or social media platform

What Data Do We Collect and Why?

Personal data is any information that identifies or can be linked to a natural person for identification. Personal data we collect about you includes:

 - Identification data such as your first name, last name, and password.
 - Contact data such as address, email address, telephone, or mobile number.
 - Financial data such as investments, income, credit card details and any other payment method you provide to us. When paying online, this stays with our payment provider and we do not have any access to it. We keep it when you enrol manually or ask for a refund.
 - Information about the training courses you sign up to and attend.
 - Information about your interaction with our emails, and website.
 - Information from any workshop or coaching course you attend.
 - Details about lifestyle, previous training experience, and occupation information, if provided during a workshop.

In certain circumstances,

 - We ask you for marital or dependants’ information. For example, when you want your partner or dependent to join a training to which you subscribed.
 - We may take photographs and otherwise record your presence or interaction. In such cases, you are pre-informed with a choice to opt-out of such recording.

Most of our services are designed for those above 16 years of age. For products that are designed for children, we may collect the name of your child if the product relates to children. However, we do not directly communicate or contact your children.

We do not collect any ‘special category’ data. For information, this includes any data that is relating to your health, ethnicity, religious, philosophical or political beliefs, genetic or biometric data, or sexual preference data.

What We Do With Your Personal Data

We use your personal data for the following purposes:

 - To provide, and improve, our services to you and others.
 - To answer your queries or to contact you for a scheduled appointment or otherwise. For example, when you make contact using our contact form, we will answer your query.
 - To contact you as part of the contract (or service) and if you are not yet a customer, we rely on your request as your consent when you submitted the information.
 - To create, send and follow-on invoices or payments in line with the contract
 - To check if payments due have been received in line with your contract
 - To validate your identity prior to login into our systems
 - To share relevant offers with you if you have opted for it
 - To send you emails relating to products you have subscribed to and/or products we believe you may be interested in
 - To review and improve our emails by analysing which emails are opened, deleted, or clicked
 - To make a recording of our trainings or sessions
 - To perform internal management, administration and reporting as per the applicable laws and industry practices.

The lawful basis for using your information in this way are:

  1.  To perform the contract with our customers
  2.  Because we have a legal obligation (e.g. to report tax/ income)
  3.  For our ‘legitimate interests’ to send marketing material to you, to grow and administer our business and to understand our performance and protect our business

When And How Do We Collect Your Data?

We collect your personal data when you provide your personal data by visiting our website, meeting us in person, attending a workshop or coaching, filling in a form, signing a contract, calling us, emailing us or messaging us (through any means including social media) with interest in our services. For example, you contact us for purchase of a course that you are interested in.

How Do We Store and Protect Your Data?

We aim to keep your data safe and protected i.e., we do not disclose this to others unless strictly necessary for performance and delivery of the service we provide you. And, when data is with us, the data stays in a password protected computer or cloud or software.

How Long Do We Keep Your Data?

We keep your personal data until you unsubscribe. If you are a customer, we keep your personal data to provide the ‘lifetime’ access to the membership site. We keep personal data as long as necessary for compliance with law and to maintain our records. For example, accounting data is kept for 7 years years from the end of our relationship with you.

Who We Share Your Data With And Why?

As a small company, we rely on providers to provide us with specialized services. When doing so, we focus on sharing only the necessary data and implement appropriate safeguards to protect your personal data. For example, we ensure we have a contract in place, that we have carried out due diligence on those third parties, that they use password protection and limit access to relevant staff within the company. To ensure that we deliver you the services in an effective way, we share your personal data with following categories of third parties:

 - Providers of technical and operational support services like website hosting and maintenance, email provisioning, calendars, payment processing, back-ups, customer relationship management, electronic signatures of documents etc.
 - Contractors who work on our behalf as coaches or support staff only to the extent necessary for them to provide their services.
 - Law enforcement agencies and courts when it is necessary to do so, or we are obliged by laws to share such information.
 - Group companies
 - Advisors, including legal providers, and accountants.
 - Those organisations involved in a merger or acquisition, or who are involved in a corporate reorganization, joint venture, assignment, sale, or transfer or other disposition of all or any portion of our business (including in connection with a bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

Your Data Protection Rights

Your privacy is important, and we respect your rights. You have the following rights:

  1. Right to access i.e., get a copy of your personal data.
  2. Right to rectification i.e., get your personal data corrected when necessary.
  3. Right to erasure i.e., delete your personal data if it is no longer necessary for the purpose of processing. Remember, this is possible only when we do not have legal reason to keep your personal data.
  4. Right to restrict processing i.e., limit processing for specific reasons.
  5. Right to object to processing i.e., object to processing when you believe processing is unlawful or not necessary
  6. Right to data portability i.e., have your data given to you or someone you choose.

To exercise your rights, please contact us via email privacy@therethinkacademy.com

Contact Us

If you have any queries or want to know more about our privacy approach or need more details on how we collect, use, disclose and protect your personal data, you can contact us at privacy@therethinkacademy.com

You can also contact us by writing to us at the following address: Rethink Academy Ltd, Unit 107, Moat House, 54 Bloomfield Ave, Belfast, BT5 5AD

How To Complain

We are sorry that you did not like something about us. We are always looking to help you and would like to hear about your concern directly at privacy@therethinkacademy.com

The law allows you to contact the Information Commissioner’s Office (ICO) if you are unhappy with the way we manage your personal data. You can contact the ICO by clicking here.
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