We keep this policy under review and it may be revised from time to time. Please check this page for any future updates. This policy was last updated on 21/4/20.
Who we are and important information
This website is not intended for children and we do not knowingly collect data relating to children.
Our registered address is HOOK training ltd, Unit 605, Moat House, 54 Bloomfield Avenue, Belfast, BT5 5AD. For all data matters please contact our Data Protection Officer, Paul McCrory, using this form.
Third-party links outside of our control
The personal data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you, including:
- your name and contact details (e.g. your organisation, postal address, telephone number, email address);
- information about the services and products you buy from us;
- details about how you use our services and products;
- enquiries or recommended resources which you may have submitted through this site;
- comments, reviews, feedback and testimonials which you may have submitted on our site;
- the email lists that you have signed-up to and how you interact with the emails we send you (e.g. opening and clicking within an email);
- financial information when you purchase a service or a product.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data, but is not considered personal data in law as this data does 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 in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How we collect your personal data
We use different methods to collect data from and about you including through:
- information you supply us - you may give us your contact information by filling in forms online or by corresponding with us by post, phone, email or otherwise. For example, this includes personal data you provide when you subscribe to a mailing list; complete a survey; correspond with us; submit a testimonial or feedback; or order a service or product from us.
- information which is available publicly - some of your personal information may be available to us from external public sources (e.g. online directories; your website; press reports; your social media accounts).
How we use your personal data
Why we use your personal information
We use your personal data for a variety of purposes, including:
- to communicate with you and respond to your enquiries;
- to provide you with email newsletters communicating original and curated resources and sharing our latest products with you;
- to collect comments, reviews, feedback and testimonials you have submitted;
- to collect recommended resources you have submitted;
- to conduct surveys to find out more about your experiences and how we can better meet your needs;
- to register you as a customer and process your order for our services / products;
- to manage any payments you make to us;
- to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, reporting and hosting of data);
- to use data analytics to improve your experience on our website.
The legal grounds on which we process your 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:
- Performance of Contract - this 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.
- Legitimate Interest - this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the 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).
- Comply with a legal or regulatory obligation - this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
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.
When we rely on our legitimate interests to process personal information, these interests are:
- the performance of a contract with you for a service or a product;
- the need to maintain accurate records of our subscribers and customers;
- the need to communicate and respond efficiently to our customers / prospective customers;
- the need to market our services and products;
- the need to study how our customers use our services and products, so that we can improve them;
- the need to keep our website effective, accessible and secure for our visitors;
- the necessity to comply with a regulatory or legal obligation.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing a product or service.
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 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.
Who we share your personal data with
We will not rent or sell your personal information with any company outside HOOK training ltd for their marketing purposes. In order to provide our services and run our business we share data with selected third parties from the following categories:
- Providers acting as processors who provide IT and system administration services.
- Third parties which are involved in processing online and manual purchases of our services and products.
- Professional advisers acting as processors (including lawyers, bankers, auditors and insurers based) who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.
- 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 notice.
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.
Some of our external third parties are based outside the European economic area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it, for example, by working with third parties that operate under the EU-US Privacy Shield.
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 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.
In some circumstances, you can ask us to delete your data - see Your legal rights below for further information.
In some circumstances, we may 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.
Your legal rights
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- the right to request a copy of the personal data which we hold about you;
- the right to request that we correct any personal data if it is found to be inaccurate or out of date;
- the right to request your personal data is erased where it is no longer necessary to retain such data;
- the right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- the right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- the right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- the right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer using this form, specifiying your country of residence and the nature of your request.
No fee required – with some exceptions
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 may 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.
Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact Paul McCrory using this contact form.
If this does not resolve your enquiry or concern to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 0303 123 1113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.