[vc_section][vc_row][vc_column]
This Policy sets out the obligations of Squaricle Group Limited, a company registered in England and Wales under Companies House number 12647309<\/strong>\u00a0, whose registered office is at \u00a01 Tower View, Kings Hill, West Malling, Kent, ME19 4UY<\/strong>\u00a0(\u201cthe Company\u201d) regarding data protection and the rights of clients and their employees (\u201cdata subjects\u201d) in respect of their personal data under EU Regulation 2016\/679 General Data Protection Regulation (\u201cGDPR\u201d).<\/p>\n The GDPR defines \u201cpersonal data\u201d as any information relating to an identified or identifiable natural person (a \u201cdata subject\u201d); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.<\/p>\n This Policy sets the Company\u2019s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.<\/p>\n The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.<\/p>\n This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:<\/p>\n 2.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Processed lawfully, fairly, and in a transparent manner in relation to the data subject.<\/p>\n 2.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.<\/p>\n 2.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.<\/p>\n 2.4\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.<\/p>\n 2.5\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to the implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.<\/p>\n 2.6\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.<\/p>\n The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):<\/p>\n 3.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The right to be informed (Part 12);<\/p>\n 3.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The right of access (Part 13);<\/p>\n 3.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The right to rectification (Part 14);<\/p>\n 3.4\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The right to erasure (also known as the \u2018right to be forgotten\u2019) (Part 15);<\/p>\n 3.5\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The right to restrict processing (Part 16);<\/p>\n 3.6\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The right to data portability (Part 17);<\/p>\n 3.7\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The right to object (Part 18);<\/p>\n 3.8\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The right to withdraw consent;<\/p>\n 3.9\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The right to complain to the\u00a0Information Commissioner\u2019s Office<\/a>\u00a0(the \u201cUK supervisory authority\u201d under the GDPR).<\/p>\n 3.10\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 To activate your rights as outlined above requests should be made to the Data Protection Team: dataprotection@wordpress-617697-2152419.cloudwaysapps.com<\/p>\n 4.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:<\/p>\n 4.1.1\u00a0\u00a0\u00a0\u00a0 The data subject has given consent to the processing of their personal data for one or more specific purposes;<\/p>\n 4.1.2\u00a0\u00a0\u00a0\u00a0 The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;<\/p>\n 4.1.3\u00a0\u00a0\u00a0\u00a0 The processing is necessary for compliance with a legal obligation to which the data controller\u00a0is subject;<\/p>\n 4.1.4\u00a0\u00a0\u00a0\u00a0 The processing is necessary to protect the vital interests of the data subject or of another natural person;<\/p>\n 4.1.5\u00a0\u00a0\u00a0\u00a0 The 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 data controller;<\/p>\n or<\/p>\n 4.1.6\u00a0\u00a0\u00a0\u00a0 The processing is necessary for the purposes of the legitimate interests pursued by the data controller 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.<\/p>\n 4.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 If the personal data in question is \u201cspecial category data\u201d (also known as \u201csensitive personal data\u201d) (for example, data concerning the data subject\u2019s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:<\/p>\n 4.2.1\u00a0\u00a0\u00a0\u00a0 The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);<\/p>\n 4.2.2\u00a0\u00a0\u00a0\u00a0 The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);<\/p>\n 4.2.3\u00a0\u00a0\u00a0\u00a0 The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;<\/p>\n 4.2.4\u00a0\u00a0\u00a0\u00a0 The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;<\/p>\n 4.2.5\u00a0\u00a0\u00a0\u00a0 The processing relates to personal data which is clearly made public by the data subject;<\/p>\n 4.2.6\u00a0\u00a0\u00a0\u00a0 The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;<\/p>\n 4.2.7\u00a0\u00a0\u00a0\u00a0 The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;<\/p>\n 4.2.8\u00a0\u00a0\u00a0\u00a0 The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;<\/p>\n 4.2.9\u00a0\u00a0\u00a0\u00a0 The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or<\/p>\n 4.2.10\u00a0 The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.<\/p>\n 5.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company collects and processes the personal data set out in Part 19 of this Policy. This includes:<\/p>\n 5.1.1\u00a0\u00a0\u00a0\u00a0 Personal data collected directly from data subjects and<\/p>\n 5.1.2\u00a0\u00a0\u00a0\u00a0 Personal data obtained from third parties.<\/p>\n 5.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company only collects, processes, and holds personal data for the specific purposes set out in Part 19 of this Policy (or for other purposes expressly permitted by the GDPR).<\/p>\n 5.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed.<\/p>\n The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 19, below.<\/p>\n 7.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up to date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14, below.<\/p>\n 7.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out of date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.<\/p>\n 8.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company shall not keep personal data for any longer than is necessary for the purpose or purposes for which that personal data was originally collected, held, and processed.<\/p>\n 8.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.<\/p>\n The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 20 to 23 of this Policy.<\/p>\n 10.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company\u2019s Data Protection Team email address, which is to be used for all matters relating to Data Protection and GDPR is: dataprotection@tedlearningroup.com<\/strong><\/p>\n 10.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Data Protection Team shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company\u2019s other data protection-related policies, and with the GDPR and other applicable data protection legislation.<\/p>\n 10.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:<\/p>\n 10.3.1\u00a0 The name and details of the Company, its Data Protection Team, and any applicable third-party data processors;<\/p>\n 10.3.2\u00a0 The purposes for which the Company collects, holds, and processes personal data;<\/p>\n 10.3.3\u00a0 Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;<\/p>\n 10.3.4\u00a0 Personal data will be retained by the Company in line with statutory obligations and will otherwise be reviewed every two years;<\/p>\n 10.3.5\u00a0 Descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.<\/p>\n 11.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company shall carry out Data Protection Impact Assessments for new uses of personal data which involve the use of new technologies and where the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR.<\/p>\n 11.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Data Protection Impact Assessments shall be overseen by the Data Protection Team and shall address the following:<\/p>\n 11.2.1\u00a0 The type(s) of personal data that will be collected, held, and processed;<\/p>\n 11.2.2\u00a0 The purpose(s) for which personal data is to be used;<\/p>\n 11.2.3\u00a0 The Company\u2019s objectives;<\/p>\n 11.2.4\u00a0 How personal data is to be used;<\/p>\n 11.2.5\u00a0 The parties (internal and\/or external) who are to be consulted;<\/p>\n 11.2.6\u00a0 The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;<\/p>\n 11.2.7\u00a0 Risks posed to data subjects;<\/p>\n 11.2.8\u00a0 Risks posed both within and to the Company; and<\/p>\n 11.2.9\u00a0 Proposed measures to minimise and handle identified risks.<\/p>\n 12.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company shall provide the information set out in Part 12.2 to every data subject:<\/p>\n 12.1.1\u00a0 Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and<\/p>\n 12.1.2\u00a0 Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:<\/p>\n a)\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 if the personal data is used to communicate with the data subject when the first communication is made, or<\/p>\n b)\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 if the personal data is to be transferred to another party before that transfer is made; or<\/p>\n c)\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 as soon as reasonably possible and in any event not more than one month after the personal data is obtained.<\/p>\n 12.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The following information shall be provided:<\/p>\n 12.2.2\u00a0 Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;<\/p>\n 12.2.3\u00a0 Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the \u201cEEA\u201d), details of that transfer, including but not limited to the safeguards in place (see Part 25 of this Policy for further details);<\/p>\n 12.2.4\u00a0 Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.<\/p>\n 13.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Data subjects may make subject access requests (\u201cSARs\u201d) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.<\/p>\n 13.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Data subjects wishing to make an SAR may do so in writing. SARs should be addressed to the Company\u2019s Data Protection Team at dataprotectionteam@tedlearinggroup.com<\/strong>\u00a0 or Data Protection Team, Squaricle Group, 2nd Floor, 1 Tower View, Kings Hill, West Malling, Kent ME19 4UY. Upon receipt of an SAR further documentation may be required in order to confirm the identity of the requester.<\/p>\n 13.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Responses to SARs shall normally be made within one month of receipt, however, this may be extended by up to two months if the SAR is complex and\/or numerous requests are made. If such additional time is required, the data subject shall be informed.<\/p>\n 13.4\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 All SARs received shall be handled by the Company\u2019s Data Protection Team.<\/p>\n 13.5\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.<\/p>\n 14.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.<\/p>\n 14.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.<\/p>\n 14.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.<\/p>\n 15.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:<\/p>\n 15.1.1\u00a0 It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;<\/p>\n 15.1.2\u00a0 The data subject wishes to withdraw their consent to the Company holding and processing their personal data;<\/p>\n 15.1.3\u00a0 The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);<\/p>\n 15.1.4\u00a0 The personal data has been processed unlawfully;<\/p>\n 15.1.5\u00a0 The personal data needs to be erased in order for the Company to comply with a particular legal obligation.<\/p>\n 15.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject\u2019s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.<\/p>\n 15.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 In the event that any personal data that is to be erased in response to a data subject\u2019s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).<\/p>\n 16.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.<\/p>\n 16.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).<\/p>\n 17.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Where data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers). The right to data portability only applies:<\/p>\n 17.1.1\u00a0 To personal data an individual has provided to a controller;<\/p>\n 17.1.2\u00a0 Where the processing is based on the individual\u2019s consent or for the performance of a contract; and<\/p>\n 17.1.3\u00a0 When processing is carried out by automated means.<\/p>\n 17.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the format of a CSV file.<\/p>\n 17.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.<\/p>\n 17.4\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 All requests for copies of personal data shall be complied with within one month of the data subject\u2019s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed. Upon receipt of a request further documentation may be required in order to confirm the identity of the requester.<\/p>\n 18.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Data subjects have the right to object to the Company processing their personal data based on legitimate interests or direct marketing (including profiling).<\/p>\n 18.2\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company\u2019s legitimate grounds for such processing override the data subject\u2019s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.<\/p>\n 18.3\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.<\/p>\n 19.1\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 For potential and current clients of Squaricle Group Limited the following personal data is collected, held, and processed by the Company for sales and marketing purposes:<\/strong><\/p>\n 19.1.1\u00a0 Information from website enquiries is input into the organisational Customer Relationship Management system (HubSpot – https:\/\/legal.hubspot.com\/privacy-policy?_ga=2.84352090.239678435.1589195761-761055662.1532970377<\/a> ); personal data recorded includes name, work email address, work phone number, and personal mobile number where provided;<\/p>\n 19.1.2\u00a0 Emails between ted Learning and current\/potential clients are centrally archived for consistency purposes;<\/p>\n 19.1.3\u00a0 Information from conferences attendance is input into the organisational Customer Relationship Management system (HubSpot); personal data recorded includes name, work email address, work phone number, and personal mobile number where provided;<\/p>\n 19.1.4\u00a0 Where conversations with potential clients occur on social media platforms, including LinkedIn, an individual\u2019s name, professional information, profile link and direct email address, where provided, are stored in HubSpot;<\/p>\n 19.1.5\u00a0 Proposal documents including individual client names are retained for business continuity purposes;<\/p>\n 19.1.6\u00a0 Hubspot is used to send newsletters; it uses cookies to log browsing history and pixels in emails to track engagement through recording an individual\u2019s IP address;<\/p>\n 19.1.7\u00a0 The company uses unsubscribe options for our business-to-business emails. If you would like to unsubscribe from emails, then please email our Data Protection Team at dataprotection@tedlearinggroup.com<\/p>\n 19.1.8\u00a0 The company uses MailChimp (https:\/\/mailchimp.com\/legal\/privacy\/<\/a>) for email responses;<\/p>\n 19.1.9\u00a0 The company undertakes market research prior to conferences and events to identify delegate information. Personal data provided by event\/webinar\/conference attendees is stored in Hubspot and MailChimp;<\/p>\n2.\u00a0The data protection principles<\/h3>\n
3.\u00a0The rights of data subjects<\/h3>\n
4. Lawful, fair, and transparent data processing<\/h3>\n
5. Specified, explicit, and legitimate purposes<\/h3>\n
6. Adequate, relevant, and limited data processing<\/h3>\n
7. Accuracy of data and keeping data up to date<\/h3>\n
8. Data retention<\/h3>\n
9. Secure processing<\/h3>\n
10. Accountability and record-keeping<\/h3>\n
11. Data Protection Impact Assessments<\/h3>\n
12. Keeping data subjects informed<\/h3>\n
13. Data subject access<\/h3>\n
14. Rectification of personal data<\/h3>\n
15. Erasure of personal data<\/h3>\n
16. Restriction of personal data processing<\/h3>\n
17. Data portability<\/h3>\n
18. Objections to personal data processing<\/h3>\n
19. Personal data collected, held, and Processed<\/h3>\n