Privacy Notice
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- GLOSSARY
Introduction
Welcome to Training-Progress Ltd’s privacy policy.
Training-Progress respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website at https://www.training-progress.com/ (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- GLOSSARY
- IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy policy
This privacy policy aims to give you information on how Training Progress Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you provide feedback to us, sign up to our newsletter, purchase a product or service or take part in a competition. This policy does not cover the data that your employer instructs us to process in order to provide our services to you.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Training Progress Ltd is the controller and responsible for your personal data (collectively referred to as “Training Progress”, “we”, “us” or “our” in this privacy policy). This policy does not describe our use of personal data where we act as a processor on behalf of and under the instruction of another data controller in relation to that data. Where we collect data directly from you for our own purposes then we will be the Controller. Where a third party instructs us to process your data for their purposes, such as your employer, they are the Controller.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the Contact details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Training-Progress Ltd
Email address: info@Training-Progress.com Postal address: Training-Progress Ltd, Milner Mount Farm, Menwith Hill, Harrogate HG3 2RN
Telephone number: 01423 313323
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in October 2022. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications, including those of third party content or other such training providers advertised on our website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
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, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Health Data (special category data): includes things like your dietary requirements (which could reveal that you are celiac, diabetic etc) or details of an allergy, disability or any other sensitivity, phobia or condition that may necessitate any kind of adjustment or advance preparation to ensure either your safety or the efficient delivery of services to you. We will make it clear to you whenever we ask you to provide Health Data why we need it and who we will share that with, and this will almost always be processed by us according to your employers instruction and they will remain the Data Controller for that data despite the fact we use it to provide certain services.
- Identity Data includes first name, maiden name, last name, national insurance number, passport details, driving license, username or similar identifier, employer name or related business name, title, date of birth and gender.
- Contact Data includes billing address, delivery or performance address, personal and/or business email address and contact telephone numbers including area codes.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from or through us.
- Technical Data includes the type of device you use, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username (and any similar identifiers) and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services including which courses you have taken, how long you spent taking those courses, your success rates in any assessments or tests we provide to you, certificates and qualifications you have acquired or maintain, and how long you have been a user for.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties such as our partners and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data as set out above but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used and protected in accordance with this privacy policy.
Special Categories of Personal Data (such as Health Data)
We do not intentionally collect any Special Categories of Personal Data about you without your express consent although you may choose to provide them voluntarily in which your consent is implied (this includes Health Data as described above and also any details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, other information about your health including mental health, and genetic and biometric data).
Your employer organisation is usually going to be the data controller for this type of personal data and we process it under their instructions. You should therefore ask your employer for copies of their policy regarding your special category data if you have any questions though we try to set out what we do with that type of information in this policy we are a not a Data Controller when it comes to your special category data.
You can withdraw your consent at any time to any part of this type of processing, but that won’t affect the lawfulness of processing carried out before you withdrew your consent, including the retention of data required to deal with claims and other legal obligations as further described below in the section entitled Data Retention.
We do not collect any information about criminal convictions and offences. If you volunteer or otherwise provide any data of this type to us in any way where we haven’t explicitly asked you to provide it as part of our services, we reserve the right to delete that information when we become aware of it, we will only retain it if there is a proper legal basis or an otherwise compelling and legitimate reason to do so under the circumstances such as protecting your vital interests.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
If you do not provide Health Data relevant to the delivery of services, there is a chance that your particular requirements may not be met, and you may not be able to use some or all of the services at all depending on what they are and how they are delivered or we may not be able to protect your vital interests or health and safety.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Health, Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to or participate in our service or publications;
- tell us about a requirement you have relating to your health;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- in an emergency; or
- give us feedback or contact us.
- 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, server logs and other similar technologies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
analytics providers such as Google who provide Google Analytics and are based in the USA;
advertising networks such as those operated by Facebook and Meta Platforms Inc (https://en-gb.facebook.com/privacy/policy/) and LinkedIn Ireland Unlimited (https://www.linkedin.com/legal/privacy-policy) based in Ireland; and
search information providers such as Google Adwords operated by google based in the USA.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe Payments Europe Limited or GoCardless Ltd based inside the UK.
- Identity and Contact Data from data brokers or aggregators such as tracing or debt recovery service providers based inside the UK.
- Identity and Contact Data from publicly available sources such as public facing websites operated by your business, social media networks such as LinkedIn, Facebook, Companies House and the Electoral Register based inside the UK.
- Profile, Transaction and Usage Data provided back to us by the third party service provider partners we work with to deliver services to you, which we will use in accordance with this policy as though you provided it to us directly.
- Health Data from your employer, where they are legally allowed to share that with us, we won’t use that data for any purpose other than providing services and protecting you as set out in this policy.
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:
- Where you consent to our processing of Health Data, which is a special category of data that requires extra protection.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal obligation.
- Where you are not able to consent in any situation where we reasonable believe that we need to take action to protect your vital interests, such as disclosing to first aiders or medical professionals an allergy or other Health Data you have made us aware of.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
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 contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a user |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To process and deliver your order or services including sharing relevant information as required with your employer and any third party service providers who provide services you have requested: · Checking to see if services meet your requirements; · Making adjustments to accommodate your circumstances; · Helping your employer assist us and third parties to protect your health and safety when attending services they arrange for you; · Managing dietary requirements.
|
Health Data
|
With your express consent, for the limited purpose we tell you about; or In the limited circumstances where you are not in a position to provide consent where we need to act to protect your vital interests such as a medical emergency. |
| For your employer to manage their legal obligations and manage their human resources generally in accordance with their employee personal data privacy notices. |
(a) Identity (b) Contact (c) Health Data (special category) (f) Usage
|
(a) Necessary for the legitimate interests of your employer (including where consent is not an appropriate legal asis) or (b) with your consent; or (c) your employer’s compliance with necessary legal obligations; and/or (d) Fulfilling contractual obligations owed to you as an employee (or as a contractor). |
|
To process and deliver your order including sharing relevant information as required with third party service providers who provide services you have requested: · Manage payments, fees and charges · Collect and recover money owed to us · Activate free Trials |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Usage (g) Profile |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: · Notifying you about changes to our terms or privacy policy · Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical (d) Usage |
(a) Necessary for our legitimate interests (for running our business, provision of administration and troubleshooting of IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics from providers such as Google Ireland Limited who operated Google Analytics to improve our website, products/services, marketing, customer relationships and experiences. |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, to help us decide how to expand or improve our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We ask you for your preferences when you first sign up to our marketing, or we use the same method of contact you used to get in touch with us (unless you’ve asked us not to do that) and you are always welcome to update your preferences or opt out of marketing at any time by contacting us.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile 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 products, 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 any goods or services, including digital content or a subscription to the same, from us and you have not opted out of receiving that marketing. Promotional offers that we send to you might relate to our products and services or they might relate to third parties who have asked us to share their offers with you. We perform this kind of marketing based on our legitimate interests where you have not opted out of this.
Third-party marketing
We will get your express opt-in permission before we share your personal data with any third party for their own marketing purposes. Where we send you offers from third parties, we don’t share your data with those third parties for marketing purposes and they won’t contact you directly unless you have agreed for them to do so.
The only exception to this is where you have signed up to a product or service through our website that is operated by a third party, we may share Contact Data with those third parties for the purpose of providing those products or services to you and their privacy policies will apply to their use of that data. Where we share data in this way the identity of the third party will be made obvious to you, and their use of your data will be subject to their own privacy policy.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the “opt-out” or “manage my subscription” links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions as we may need to contact you in relation to either of our contractual rights and or obligations.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
We only capture strictly essential cookies when you’re using our services, and we capture the standard information collected by Google Analytics which does not reveal your personal information to us. For more information about google analytics please visit https://policies.google.com/technologies/partner-sites?hl=en-US.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- External Third Parties as set out in the Glossary.
- Specific third parties listed in the table Purposes for which we will use your personal data above as further described in the Glossary, such as:
- Your employer; or
- A third party event/training provider
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not generally transfer your personal data outside the UK.
We share limited personal data with the Google Group. This will involve transferring your data outside the UK as described in their privacy policy.
Whenever we or one of our external third parties transfers your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed by an independent data protection supervisory authority to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. You may know these contracts as either the Standard Contractual Clauses or the UK Information Commissioner’s Office’s International Data Transfer Agreement; or
- Binding corporate rules used by our external third parties, which must have first been approved by an independent data protection supervisory authority.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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.
How long will you use my personal data for?
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. For us to comply with these legal requirements we may retain your data for up to seven (7) years in total, after which time it will be scheduled for deletion or full anonymisation if entered into a wider aggregated data set that is no longer deemed to be “personal data” in law.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
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.
LAWFUL BASIS (EXPLAINED)
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Service providers acting as processors based in the United Kingdom who provide IT and system administration services such as the customer relationship management platform we use to store customer information.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Google Ireland Limited, based in Ireland, who operate the Google Analytics and Google Adwords services. You can find out more about how Google protects your data at https://support.google.com/analytics/answer/6004245?hl=en and their full privacy policy is available at https://policies.google.com/privacy?hl=en.
- GoCardless Ltd, Sutton Yard, 65 Goswell Road, London EC1V 7EN, United Kingdom, registered company number 07495895, who act as a processor of payment card information, (and who are a separate and independent Data Controller in their own right under registration number ZA024862 in relation to data they collect directly from you as a “Payer”) as set out in their privacy policy available at https://gocardless.com/privacy/payers/; or
- Stripe Payments Europe Limited with their address at C/O A & L Goodbody, Ifsc, North Wall Quay, Dublin, D01 H104, Ireland who act as a processor of payment card information, (and who are a separate and independent Data Controller in their own right) in relation to data they collect directly from you as a “Payer”) who are supervised by the Irish Data Protection Commission as set out in their privacy policy available at https://stripe.com/gb/privacy.
YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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.
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.
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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.