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Last Updated 22 April 2021
When you visit our Website, we may collect certain personally identifiable information from you (“Personal Data”). For the purposes of the General Data Protection Regulation or “GDPR”) we operate as the “data controller”, meaning that we decide the purposes for using your personal data and are responsible for safeguarding it.
What this Policy Explains
Information We Collect:
We collect Personal Data in two ways:
The information you might choose to provide to us includes:
Third Party Cookies and Tracking Technologies:
As with many websites, we do not honor “Do Not Track” signals transmitted by web browsers as there is no industry standard for implementing such programs. To find out more about DNT, please visit http://allaboutdnt.com.
For more information about third-party advertisers and how to prevent them from using your information, visit the NAI’s consumer website at http://www.networkadvertising.org/choices, http://www.aboutads.info/choices/, or http://www.youronlinechoices.com/uk/. If you do want to opt out using these tools, you need to opt out separately for each of your devices and for each web browser (such as Chrome, Edge Firefox, Safari or others) that you use on each device.
How We May Use Your Personal Data
|Purpose||What data||Legal basis|
|Signing up to an event or to receive our newsletters, download content, or to register your interest in membership of Leaders Performance Institute; responding to your customer support requests; providing you with opportunities to provide feedback or participate in surveys; contacting you about Leaders’ or third party products and services we believe may be of interest to you; and to share your Personal Data with third parties when you have agreed to allow them to contact you directly.||Identity, Contact, Profile, Technical, Usage||Your Consent|
|Administer, analyze, and improve our Website, services, marketing, user relationships and experiences, including statistical analyses of users of the Website, viewing and participation patterns, for product development, reviewing job applications; customizing your Website experience by delivering more relevant content and advertising while you browse.||Identity, Contact, Technical, Usage||Your consent|
|For internal administration and record keeping purposes, including to process payments which you make and to fulfill your customer support requests; provide your Leadership Performance Institute membership including allowing you to log in to member areas, and fulfill your customer support requests.||Identity, Contact, Profile, Financial, Technical, Usage||Performance of a contract with you; Necessary for our legitimate interests (for effective business administration and service provision); Necessary for our legal interests|
|Protect our organization and this Website (including troubleshooting, data analysis, testing, system maintenance, support, identifying and detecting fraud and security issues, and reporting and hosting of data).||Identity, Contact, Technical, Usage||Necessary for our legitimate interests (for running our organization, provision of administration); Necessary to comply with a legal obligation|
|Contact you about third party products and services which we believe may be relevant to you or pass on your details to third parties to enable them to contact you directly about the same (in each case, only where you have indicated you would like to hear about these).||Identity, Contact, Profile||Consent|
We may also pseudonymize and aggregate your Personal Data in a way which means you can no longer be readily identified. This may be helpful to us for our lawful purposes, such as testing our internal systems, carrying out research and general customer data analysis.
Sharing Your Personal Data
We may share your Personal Data with:
We may also need to disclose your personal information in the following circumstances:
In addition, as our business changes, we may buy or sell various assets owned or controlled by us. In the event all or a portion of the assets are sold, assigned, transferred or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or otherwise, your Personal Data may be transferred.
Personal Data Transfers Outside of the EEA
Our offices are located in the United Kingdom and the United States, and your Personal Information may be processed, transferred to, and maintained on, servers and databases located outside of the jurisdiction in which you are based and where the privacy laws may not be as protective as your jurisdiction. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your Personal Data is adequately protected. For more information on the appropriate safeguards in place, please contact us by email at [email protected] or as described at the end of this section.
Securing Your Personal Data
We have put in place commercially reasonable physical, technical and administrative controls to help protect the confidentiality, accuracy and availability of your Personal Data. We also make sure that third parties who need to handle your data when helping us to deliver our services are subject to suitable confidentiality and security standards.
Despite the security measures we implement, please be aware that the transmission of data via the internet is not 100% secure. On such basis, we cannot guarantee the security of the information transmitted to us via the internet and any transmission is at your own risk.
How Long We Keep Your Personal Data
If you are a member of the Leaders Performance Institute, we will keep your Personal Data for as long as is necessary to perform the service for which it was provided. Once you no longer wish to be engaged with Leaders we may still need to retain limited Personal Data if there is a legal reason for doing so.
Third Party Websites and Social Media
Our Website also contains social network sharing widgets. These widgets may provide information to their associated social networks or third parties about your interactions with pages that you visit on our Website, even if you do not click on or otherwise interact with the plug in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address and the URL of the web page where the widget appears. If you use social network tools or visit social networking websites, we encourage you to read their privacy disclosures to understand what information they collect, use, and share.
Personal Data Rights for EEA Residents
EEA residents are entitled to:
If you want to exercise any of these rights, please contact us at [email protected]. You don’t have to pay a fee, unless your request is clearly unfounded, repetitive or excessive (in which case we are allowed to charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances.
Where your request is legitimate, we will respond within the legally required time frame (unless there is a legal reason to take longer, such as where your request is particularly complex). We may also need you to confirm your identify before we proceed with your request if it is not clear who is making the request.
Please note that the rules in your country may provide you with additional rights or may limit these rights. In all cases, our provision of the rights will comply with the applicable laws.
Notice For California Residents
Residents of the State of California have specific rights with respect to their personal information. These include the right to:
To exercise your rights to request access to or deletion of the personal information we have collected about you in the past 12 months, please go here or contact us using the information below with any questions or concerns.
Before we may fulfil your requests, we are may seek to verify your identity in order to prevent unauthorized access to your personal information. For example, if you have an account with us, we may use your account information to verify your identity. However, if we cannot verify your identity from the information already maintained by us, we may request additional information from you. Any additional information we request in these circumstances shall only be used to verify your identity.
Note that your exercise of the above rights is subject to certain exemptions to safeguard the public interest (for example, prevention or detection of crime), our interests (for example, maintaining legal privilege), and to other legally required purposes. If we are unable to honor your request, we will notify you and provide you with the reasons for that.
California residents also have the right to opt-out of what California law refers to as a “sale” of their personal information. You can opt-out of the sale of your personal information by clicking on the “Do Not Sell My Personal Info” button at any time.
Authorized Agent: California residents may use an authorized agent on their behalf to exercise a privacy right described above. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the required authorization to act on behalf of the resident. To exercise rights on behalf of a California resident, please submit your request to the contact information below with supporting verification information.
Categories of personal information we collect:
· Identifiers such as your first and last name, username or similar identifier, title, company and position, country of residence and gender
· Online identifier, Internet Protocol address, device ID
· Personal information under subdivision (e) of California Business and Professions Code Section 1798.80, including your first and last name, physical address and telephone number;
· Internet or other electronic network activity information, such as browsing history, search history, and information regarding your use of our Website;
· Geolocation information (your address, including your country of residence);
· Professional or employment-related information;
· Records of subscriptions purchased;
· Inferences drawn from any of this information to create a profile reflecting your perceived preferences and characteristics.
|Categories of sources from which the personal information is collected
· We collect the personal information directly from you.
|Business or commercial purpose for collecting or selling personal information
We collect your personal information to operate the Website, respond to your requests and for the following business purposes:
· Providing the Website, responding to your requests, and maintaining your account;
· Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
· Debugging to identify and repair errors that impair existing intended functionality.
We also use your personal information in a way that would be considered a “sale” of your personal information when we permit third parties to use your perceived interests as part of a profile to serve you targeted advertising when you browse the internet. As noted above, you may opt-out of this use, though the “Do Not Sell My Personal Information” process.
Categories of third parties with whom we share personal information for a business purpose:
We may disclose your Personal Information to the following categories of service providers:
· Data storage and security providers
· Payment processors
· Database management providers
· Advertising, marketing, social media, and advertising facilitating companies
· Companies that help with our services recommendations
· Related entities, such as our family of companies, including our parent company and its operating companies as identified above
· Professional advisors (such as lawyers, accountants, and consultants)
· Governmental and law enforcement officials, or parties to legal proceedings
|Categories of third parties with whom we share personal information
We disclose your Personal Information to the following categories of third parties in a way that would be considered a “sale” of information:
· Advertising, marketing, social media and advertising facilitating companies.
|Specific pieces of personal information we may have collected
· Your first name, last name, username or similar identifier, title, company and position, country of residence, gender, email address, postal address, physical address and telephone number; your social media contact information, your perceived interests, preferences (including in relation to marketing), feedback and survey response, records of subscriptions purchased, online identifier, Internet Protocol address, device ID, browsing history, search history, and information regarding your use of our Website; your country of residence, your resume or CV, and your perceived preferences.
If you are a resident of California, you may also request certain information regarding our disclosure of personal information for marketing purposes. To make such a request, please contact us at: Leaders, Tuition House, 27-37 St George’s Road, Wimbledon, SW19 4EU, London, United Kingdom or Email us at [email protected].
How to Opt-out of Email Marketing
To unsubscribe from our newsletters or any other Leaders marketing emails, click on the unsubscribe link at the bottom of the relevant communication you have received. Alternatively, please contact us at [email protected], and indicate what newsletter or other subscription you would like to unsubscribe to.
Where you have consented to third party marketing you must opt-out using tools provided by each third party. To prevent us from further sharing your information with third parties, please contact us at [email protected].