Etheo Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Etheo Limited
Etheo Limited is a company registered in England and Wales under the number 11115064 and whose registered office is at 80-83 Long Lane, London, EC1A 9ET.
Data Protection main point of contact: Rebecca Godfrey
Email address: email@example.com
Telephone number: +44 (0) 7974 787 464.
2. What Does This Notice Cover?
This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are Your Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10.
- The right to access the personal data we hold about you. Part 9 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 10 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 10 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
Etheo Limited is registered with the Information Commissioner’s Office under reference number ZA405613.
5. What Personal Data Do We Collect and how do we use it?
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.
We will only process your personal data if at least one of the following basis applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
We may collect some or all of the following personal data (this may vary according to your relationship with us):
Communication data that includes any communication that you send to us whether that be through email, text, phone, social media messaging, social media posting, our online registration and application forms or any other communication that you send us. We process this data for the purposes of communicating with you. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer data that includes data relating to any purchases of goods and/or services such as your name, title, company name, billing address, delivery address, email address, phone number and contact details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User data that includes data about how you use our website(s) and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our websites and ensure relevant content is provided to you, to ensure the security of our websites, to maintain back-ups of our websites and/or databases and to enable publication and administration of our websites, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our websites and our business.
Technical data that includes data about your use of our website(s) and online services such as your IP address, your login data, details about your browser, length of visit to pages on our websites, page views and navigation paths, details about the number of times you use our websites, time zone settings and other technology on the devices you use to access our websites. The source of this data is from our analytics tracking system. We process this data to analyse your use of our websites and other online services, to administer and protect our business and websites, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our websites and our business and to grow our business and to decide our marketing strategy.
Cookies. We run a number of websites which include www.etheolimited.com and www.etheo.thinkific.com. Each website has a cookie banner (provided by CookieBot) explaining all of the cookies for that site and allows visitors to set their cookie preferences upon arrival to the site. Prior consent in enabled on both of our websites. For further details on the cookies for each site please refer to the cookie banner “Show details” tab.
Photography and videography. From time to time we may take photographs or video footage to document our workshops or programmes which will be used online (on our website and/or social media accounts), for the purposes of sharing our work with external audiences. We shall ensure participants are informed in advance of the photography/filming taking place and of the use of their images. All participants shall be given the option to refuse to be photographed and/or filmed whilst they take part in the event. All such refusals shall be respected and adhered to. In our workshops using LEGO® SERIOUS PLAY® we may, if requested by the client, take a video clip of the story of the shared model. Such videos shall not contain the faces or names of participants but will include the voice of the person telling the story. Such videos shall only be used in order to provide a transcript of the model and therefore shall only be used for internal use at Etheo Limited. On such occasions only those comfortable with being recorded for this purpose shall be recorded, if none of the participants wish to volunteer for such a recording, Etheo Limited will arrange for alternative solutions to capture the story of the model. Our lawful ground for this processing is based on explicit consent for any footage collected for marketing purposes or for the inclusion in a workshop report. Our lawful grounds for the collection of footage relating to the story of the model is for the fulfilment of a contract where we share with the client the transcript of the model.
Dietary requirements. We request that you notify us of any special dietary requirements prior to attending one of our courses where catering is provided. This information is securely stored on our system and shared with the relevant third-party provider in order to fulfil our contractual obligations with you.
Myers Briggs Type Indicator (MBTI) report. Where our workshops and/or programmes include an MBTI session, participants are invited to complete an MBTI questionnaire. The resultant reports from these questionnaires are stored on the Etheo account within OPP Assessment, the Myers Briggs company online platform. Our lawful ground for this processing is the performance of a contract between you / your employer and Etheo Limited.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, phone or post with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for a purpose it was collected for, or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
6. How Long Will You Keep Our Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Details of our retention periods for data are included in our Data Retention Policy which can be provided upon request.
7. How and Where Do You Store or Transfer Our Personal Data?
We will store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that this storage of personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
That being said, through our use of certain systems, we may also store or transfer some or all of your personal data to countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. In all such instances we ensure safeguards are in place to protect your data. Such systems include:
- Our Gmail email system (@etheolimited.com) where data may be stored outside of the EEA. In terms of location Google advise that “data will be stored in Google’s network of data centers. Google maintains a number of geographically distributed data centers. Google’s computing clusters are designed with resiliency and redundancy in mind, eliminating any single point of failure and minimizing the impact of common equipment failures and environmental risks”. Google assures customers of their compliance with GDPR and that they provide “capabilities and contractual commitments created to meet data protection recommendations provided by the Article 29 Working Party.” The Article 29 Working Party (Art. 29 WP) is an advisory body made up of a representative from the data protection authority of each EU Member State, the European Data Protection Supervisor and the European Commission. Etheo Limited has reviewed and agreed to EU Model Contract clauses for G Suite.
- If you, or your organisation on your behalf, requests Myers Briggs Type Indicator (MBTI) as part of the services we provide, we will request name and email addresses for those involved in the MBTI sessions (respondents). We will enter these details into the Etheo Limited OPP Assessment profile which allows the system to contact respondents with the login details for their questionnaire. Respondents may then complete their questionnaire within the OPP Assessment system and the report will be provided to us via and stored within OPP Assessment. The Myers Briggs Company Limited, owners of the OPP Assessment system, is a UK based company however they advise that they may transfer personal data outside the EEA and to any third party located outside the EEA (including to their parent company, The Myers-Briggs Company, in the US) where they are permitted to do so for that transfer under Articles 44 to 49 of the GDPR. The Myers-Briggs Company advise that they are permitted to transfer personal data outside the EEA and to such third parties located outside the EEA as set forth in the List of Third Parties and Transfers ex-EEA, provided the appropriate safeguard mechanisms remain in place. Etheo Limited has entered into a Data Processing Agreement with The Myers-Briggs Company (previously named OPP Limited)
- Etheo Limited makes use of the Pipedrive platform for Customer Relationship Management. Pipedrive have ensured that any data stored outside of the EEA is adequately protected even after it leaves the EEA. They do this by making sure that their third-party service providers have either certified under the EU-US Privacy Shield framework or signed the EU Commission’s standard contractual clauses for data transfers with Pipedrive. The Data Processing contract is written into the Terms of Service in place between Pipedrive and their clients as Data Controllers, i.e. Etheo Limited.
- Etheo Limited makes use of the Quickbooks accountancy platform (provided by Intuit Inc) for Invoice and payment management. Invoices and receipts may contain personal information of those listed as points of contact in these documents. Intuit’s main data storage locations are in the USA. However, as a global company, data are accessed from various locations by their global teams and partners. Intuit have drawn into their Terms of Services Data Processing provisions with their clients, including Etheo Limited. Intuit certify to the EU-US Privacy Shield scheme for their use of personal data in the USA, and they apply guidelines and practices to protect all personal information, including the E.U.U.S. Privacy Shield Principles. When it comes to their partners, Intuit’s practice is to put contractual terms in place to ensure they follow Intuit’s instructions and have appropriate security in place to protect the personal data entrusted to them.
- Etheo Limited makes use of the Thinkific platform which provides webpage, landing page and also online learning platform Thinkific have assured, via their Data Processing Addendum that where the Data Subject is located in the European Economic Area, that Data Subject’s Personal Data will be processed by Thinkific based in Canada. As part of providing the Services, this Personal Data may be transferred to other regions, including to Canada and the United States. Thinkific have assured Etheo Limited, via their Data Processing Addendum that such transfers will be completed in compliance with relevant Data Protection Legislation.
- Etheo Limited makes use of the Formstack, a US based organisation, for our online registration and application forms. Formstack represents that it complies with the EU-US Privacy Shield and Swiss-US Privacy Shield Framework. Formstack complies with the EU-US Privacy Shield Principles for onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- Only encrypted laptops and hard drives are used;
- 2 step verification access is used for email access;
- All passwords used are unique and only known to the specified user;
- Malware protection is employed on all computers used for Etheo Limited business;
- Hardcopy documentation storage is kept to a minimum, and where hard copy documents are used these are stored in locked cabinets.
In addition, to ensure GDPR compliance, we enter into Data Processing Agreements with any company processing data on our behalf or ensure such provisions are either written into Terms of Service or a Data Processing Addendum.
8. Do You Share Our Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
- In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- We may sometimes contract with third parties, such as off-site event venues, virtual assistants, thinkific or OPP, to supply services to you on our behalf or to professional advisors, such as legal and accountancy firms, to support our business activities, those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 7.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 7.
9. How Can I Access Our Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
10. How Do I Contact You?
Rebecca Godfrey, Managing Director, is the Data Protection main point of contact for Etheo Limited. To contact Rebecca about anything to do with your personal data and data protection, including to make a subject access request or to withdraw consent at any time, please use the following details:
Email address: firstname.lastname@example.org
Telephone number: +44 (0) 7974 787 464 or +44 (0) 208 194 7000
11. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.