James Miller & Associates Ltd, trading as We Are Excel are committed to protecting and respecting your privacy.
This policy sets out how we will process any personal data we collect from you. Please read the following carefully. By visiting www.WeAreExcel.co.uk and/or by purchasing a training event from us you are accepting and consenting to the practices described in this policy.
We will always comply (and be able to demonstrate our compliance) with relevant data protection legislation, including the Data Protection Act 1998 (“DPA”) and General Data Protection Regulation (“GDPR”) as applicable, when processing your personal data. Further details on the DPA and GDPR can be found at the Information Commissioner’s Office website (www.ico.gov.uk). For the purpose of data protection legislation , we will act as data controller and we can be contacted at 1 Halton Close, Park Street, St Albans, AL2 2GZ.
We will process your personal data in accordance with the following principles:
(a) all personal data must be processed lawfully, fairly and in a transparent manner;
(b) all personal data must be collected for one or more specified, explicit and legitimate purposes and not processed in a manner incompatible with those purposes;
(c) all personal data shall be restricted to what is adequate, relevant and limited for those purposes;
(d) all personal data shall be kept accurate and up to date (and reasonable steps must be taken to erase or rectify inaccurate personal data);
(e) all personal data must be kept for no longer than is necessary for those purposes;
(f) all personal data must be protected by appropriate technical and organisational security measures to prevent unauthorised or unlawful processing and accidental loss, destruction or damage.
Information we may collect from you.
We may collect and process the following data about you:
Information you give us. You may give us information about you by filling in our Enquiry Form on our web site weareexcel.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you fill out our Enquiry form, book a training event, search our site, place an order on our site, participate in social media functions on our site, enter a competition, promotion or survey and when you complete a post course evaluation form.
The information you give us may include your name, organisation name, organisation address, e-mail address, phone number.
Information we collect about you: with regard to each of your visits to our site we may automatically collect the following information (this information identifies your computer rather than you directly and is thus anonymous, although it may be possible to infer your identity from it in which case the information will be pseudonymous):
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions.
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); services or products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including sub-contractors in technical, payment and delivery services; advertising networks; analytics providers; search information providers; and credit reference agencies) and may receive information about you from them.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. NB: Cookies only track which device is accessing a website, they do not identify – and we do not record – who is using that device (although in some situations it may be possible to infer this).
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Except for essential cookies, all cookies will expire after [1 year].
Uses made of the information
We will only process your personal data to the extent that it is necessary for the purposes specified in this Policy and we will keep the personal data we store about you accurate and up to date. Where it is inaccurate or out of date, it will be destroyed – please let us know if your personal details change or if you become aware of any inaccuracies in the personal data we hold about you.
We use information held about you in the following ways:
Information you give to us. We will use this information:
To provide you with the information, products and services that you request from us;
To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about (in this case, we will treat you as having given consent under the Privacy and Electronic Communications Regulations (PECR) to receiving this information from us unless we hear from you otherwise. We will always include appropriate “unsubscribe” options in any communication);
With your specific consent, to provide you with information about third party goods or services (you may withdraw, withhold or amend this consent at any time using the options available).
To notify you about changes to our service;
To ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you. This information identifies your computer rather than you directly, although it may be possible infer your identity from it. We will use this information:
To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
To allow you to participate in interactive features of our service, when you choose to do so;
As part of our efforts to keep our site safe and secure;
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We will not keep your personal data for longer than is necessary for the purposes specified in this Policy. Where it is no longer required, it will be pseudonymised, anonymised, destroyed or erased as appropriate.
Disclosure of your information
We will never sell your personal data or make it available to any third parties without your prior consent (which you are free to withhold) except where:
(a) we use third parties (such as credit reference agencies, suppliers and sub-contractors) for the performance of any contract we enter into with you, in which case we will ensure that they comply with this Policy and all relevant data protection legislation;
(b) we share your personal information with a member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006) in accordance with our legitimate interests;
(c) we share your personal information with third parties in accordance with our legitimate interests to protect the rights, property, or safety of James Miller & Associates Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
(d) we are required to do so by law;
(e) we sell any part of our business or assets (in which case we may disclose your personal data confidentially to the prospective buyer as appropriate in accordance with our legitimate interests).
We may also share anonymised or pseudonymised information with third party partners including:
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
Analytics and search engine providers that assist us in the improvement and optimisation of our site.
Where we store your personal data
All information you provide to us is stored on our secure servers. We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction. We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
Any payment transactions will be effected by one of our trusted third party payment suppliers and will be encrypted [using SSL technology].
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.
We will hold your personal information in accordance with our Data Retention Policy for as long as:
(a) is necessary to comply with our legitimate business interests; and/or
(d) is necessary to comply with our legal obligations; and/or
(e) you have indicated you are happy for us to do so.
You have the following rights in respect of your personal data held by us. Please send all requests in respect of these rights to our Data Protection Manager:
(a) to access your personal data;
(b) to be provided with information about how your personal data is processed (this information is set out in this Policy);
(c) to have your personal data corrected where necessary (please contact us promptly should you become aware of any incorrect or out-of-date information);
(d) to have your personal data erased in certain circumstances (please refer to the appropriate data protection legislation or consult the ICO for details);
(e) to object to or restrict how your personal data is processed;
(f) to have your personal data transferred to yourself or to another business.
If you consider that we have not complied with this Policy or the relevant data protection legislation in respect of your personal data or someone else’s, please let us know at firstname.lastname@example.org Any such breach will be taken seriously and will be dealt with in accordance with the relevant data protection legislation.
You have the right to take any complaints about how we process your personal data to the Information Commissioner:
Information Commissioner’s Office
Cheshire SK9 5AF
0303 123 1113.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.