We are Elphinston Performance Limited (EP Ltd). Company number 05368848. Registered office address Askrigg, Leckwith Road, Llandough, Penarth, Vale of Glamorgan, CF64 2LY. We are the data controller of your personal data.
We recognise the importance of protecting your privacy in line with our legal responsibilities. This policy sets out how we collect, process and hold any personal data we collect from you, or which you provide to us, for example, when you contact us, or by using our website or those of our third party service providers. By using these sites, you consent to us collecting and processing this data, on the terms and for the reasons which are explained below.
This policy affects your legal rights and obligations so please read it carefully. If you have any questions, please contact us at firstname.lastname@example.org.
Personal data you provide to us
We collect personal data or information when you enter your details on forms on our website, or those of our third party service providers and when you contact us in writing (by post, email, or posts and messages via the social media platforms that we support).
We collect, process, store and use personal data when you
- subscribe to the JEMS® newsletter via our website or other sign up form. This data (your name and email address) is stored by MailChimp and is used only to send you the JEMS® newsletter, in accordance with the Marketing Communications section of this policy.
- opt in to receive emails about JEMS® via our website or other sign up form. This data (your name and email address) is stored by MailChimp and is used only to send you emails about JEMS®, in accordance with the Marketing Communications section of this policy.
- opt in to display on our website your JEMS® Certified Practitioner status via a sign up form at the time of Certification. This data (your name, date of certification, practice details, specialty interests, and the method by which you wish to be contacted by patients) is stored by EP Ltd and displayed on the JEMS® website and can be amended or removed at the request of the practitioner at any time by email to email@example.com
- opt in to maintain your Certified JEMS® Practitioner status by providing details of relevant CPD via our website or other online form. This data (your name, email address and the details you provide about your CPD activities) is stored by SurveyMonkey and EP Ltd and is used to confirm you have fulfilled the necessary requirements.
- agree to become a voluntary Assistant Tutor (AT) by signing a contract to that effect. This data (your name, mobile number and dates of attendance as an AT) is stored by EP Ltd and is used to contact you to invite you to attend future courses as an AT.
Online booking platform
- We collect, process, store and use personal data when you book to attend a course or event (including your name, mobile phone number, email address and payment information but NOT bank or payment card details).
- We may also collect personal data that you give to us about other people if you register them to attend an event. You agree that you have notified any other person whose personal data that you provide to us of this privacy notice and, where necessary, obtained their consent so that we can lawfully process their personal data in accordance with this policy.
- This data is stored by our online booking platform provider, Ticket Tailor. Ticket Tailor provides a secure ticket sales system and holds its own GDPR compliance policy as a Third Party Data Controller.
- This data is also stored by EP Ltd. We use this data in order to comply with our contractual obligations, including to contact you with any information relating to the event, to deliver the event to you in accordance with any requests you make and that we agree to, and to deal with any questions, comments or complaints you have in relation to the event. We will also maintain a record of your attendance.
- We do not hold any bank or payment card details, these are held securely by our nominated payment partners, Stripe. Stripe provides a secure payment system and holds it’s own GDPR compliance policy as a Third Party Data Controller.
- All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this.
- You do not need to provide us with any personal data to view our online booking platform. However, we may still collect the information set under the Data we automatically collect section of this policy, and marketing communications in accordance with the Marketing Communications section of this policy.
- We may also use your personal data for our legitimate interests, including dealing with any customer services you require, enforcing the terms of any other agreement between us, for regulatory and legal purposes (for example anti-money laundering), for audit purposes and to contact you about changes to this policy.
- When you contact us in writing (by email, posts and messages via the social media platforms that we support, or via the contact form on our website), we may keep a record of the correspondence in order to assist you with future enquiries.
Data we automatically collect
- When you visit our website or those of our third party service providers, we, or third parties on our behalf, automatically collect and store information about your device and your activities. This information could include (a) your computer or other device’s unique ID number; (b) technical information about your device such as type of device, web browser or operating system; (c) your preferences and settings such as time zone and language; and (d) statistical data about your browsing actions and patterns.
- This may include using cookies (in accordance with the Cookie section of this policy) and similar tracking technologies on websites, such as pixels and web beacons, to analyse trends, administer the website, track users’ movements around the website, serve targeted advertisements, and gather demographic information about our user base as a whole.
- We use the information we collect on an anonymous basis to improve our website and your online experience, our events and the services we provide, and for analytical and research purposes.
- If you opt in to receive marketing communications from us you, consent to the processing of your data to send you such communications, which may include newsletters, and information about new courses, events or products. We retain a record of your consent.
- You can choose to no longer receive marketing communications by clicking unsubscribe from any marketing email or by contacting us at firstname.lastname@example.org. If you do unsubscribe to marketing communications, it may take up to 5 business days for your new preferences to take effect. We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer wish to receive marketing emails from us.
Who do we share your data with?
- Your personal data is only used by EP Ltd for the purposes detailed above.
- We do not sell your personal information to any other third party, for any reason whatsoever.
- We share your personal information with selected reputable third party service providers where it is necessary to do so, for the purpose of providing the product or service you have enquired about, or purchased through EP Ltd. These may include payment providers, event ticketing providers, email communication providers, IT service providers, accountants, auditors and lawyers.
- In cases where your personal information has been passed to a third party as part of provision of a product or service purchased, you may need to contact the third party directly in relation to their continued use of your personal information.
- We will share your personal information with authorities, (including the police, law enforcement agencies, credit reference and fraud prevention agencies and select other bodies), for:
- prevention and detection of crime
- the prevention of fraud against EP Ltd
- to prevent money laundering
- for identity verification
- for the purpose of legal proceedings
- Under certain circumstances we may have to disclose your personal data under applicable laws and/or regulations, for example, as part of anti-money laundering processes or protect a third party’s rights, property, or safety.
- We may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
Where we hold and process your personal data
- EP Ltd is committed to keeping your personal information secure. All personal information held by or on behalf of EP Ltd is stored on a secure server to protect it from being accessed or used inappropriately.
- Some of your personal information may be stored by our third party service providers which currently include:
- Stripe (online payments)
- Ticket Tailor (online bookings)
- MailChimp (newsletter subscription and email service provider)
- SurveyMonkey (online survey platform)
- Toolkit (email service provider)
- Burning Red (website provider)
- Facebook (social media platform)
- Some or all of your personal data may be stored or transferred outside of the European Union (the EU) for any reason, including for example, if our email server is located in a country outside the EU or if any of our service providers or their servers are based outside of the EU. We shall only transfer your personal data to organisations that have provided adequate safeguards in respect of your personal data.
- A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any personal data about you, such as your name and/or address. These files are then used by websites to identify when users revisit that website.
- We also use Google Analytics to monitor how the website and online booking platform is used. Google Analytics collects information anonymously and generates reports detailing information such as the number of visits to the website, where visitors generally came from, how long they stayed on the website, and which pages they visited. Google Analytics places several persistent cookies on your computer’s hard drive. These do not collect any personal data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent Google Analytics from logging your visits.
- If you wish to opt out of interest-based advertising click http://preferences-mgr.truste.com/(or if located in the European Union click http://www.youronlinechoices.eu/). Please note you might continue to receive generic ads.
- If you have attended a JEMS® course or event, we shall retain your personal data and a record of your attendance until you request that we delete them.
- If you have consented to receive our newsletter or other marketing communications from us, we shall retain your personal data until you opt out of receiving such communications.
- If you are a JEMS® Certified Practitioner and have consented for us to display certain details about you on our website, we will continue to do this until you request that it be removed or amended by emailing email@example.com, or until such time as you let your JEMS® Certified Practitioner status lapse by not fulfilling the relevant CPD requirements.
- If you are a JEMS® Certified Practitioner we shall retain your personal data and details of your CPD submissions until you request that we delete them or you let your status lapse by not fulfilling the relevant CPD requirements.
- If you are a voluntary Assistant Tutor we will retain your personal data and details of your attendance until you request that we delete them.
- If you have otherwise contacted us with a question or comment, we may keep a record of the correspondence in order to assist you with future enquiries.
- You have the right to obtain from us a copy of the personal data that we hold for you, and to require us to correct errors in the personal data if it is inaccurate or incomplete. You also have the right at any time to require that we delete your personal data. To exercise these rights, or any other rights you may have under applicable laws, please contact us at firstname.lastname@example.org.
- Please note, we reserve the right to charge an administrative fee to meet our costs in responding.
- If you have any complaints in relation to this policy or otherwise in relation to our processing of your personal data, you should contact the UK supervisory authority: the Information Commissioner, see www.ico.org.uk.
Version date: 6 July 2018