PRIVACY POLICY
1. Introduction
1.1 Lena Batra (‘we’, ‘us’ or ‘our’) are committed to safeguarding the privacy of those viewing and/or attending our training course and associated materials, our service users, our individual customers and our customer personnel.
1.2 In this policy, ‘we’, ‘us’ or ‘our’ refer to Lena Batra. For more information about us, see Section 11.
1.3 Our Hosting Service provider for our training course and associated materials is Thinkific Labs Inc. For further information on their Legal Notices, including Privacy Policy, Cookie Policy and Data Processing Addendum, please refer to: https://thinkific.com/legal/
2. Credit
2.1 This document was created using a template from Docular: https://seqlegal.com/free-legal-documents/privacy-policy
3. The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
3.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number and/or postal address and country.
3.3 We may process your user account data ("account data"). The account data may include your account identifier, name, email address, business name, professional group, account creation and modification dates.
3.4 We will not have access to and will not process information relating to payment transactions for the purchase of goods and services. The source of the transaction data is the payment services provider.
3.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication.
3.6 We may process data about your use of the training course and associated materials ("usage data"). The usage data may include your IP address, length of visit, enrolment and engagement with the training, page views, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
3.7 Our Hosting Service provider for our training course and associated materials is Thinkific Labs Inc. For further information on their data collection, usage and transaction data, please refer to: https://www.thinkific.com/dpa/
4. Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Relationships and communications - We may process contact data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with those viewing and/or attending our training course and associated materials, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our services and business.
4.3 Direct marketing - We may process contact data for the purposes of creating, targeting and sending direct marketing communications by email, SMS post and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent OR our legitimate interests, namely promoting our business and communicating marketing messages and offers to those viewing and/or attending our training course and associated materials, and service users.
At any stage you can opt out of receiving further direct market communication by contacting us, using the contact information provided in Section 11.
4.4 Research and analysis - We may process usage data and/or account data, and/or contact data for the purposes of researching and analysing the use of our training course and associated materials, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent OR our legitimate interests, namely monitoring, supporting, improving and securing our training course and associated materials and business generally.
4.5 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
5. Providing your personal data to others
5.1 This course is accredited with the British Society of Hearing Aid Audiologists (BSHHA). As a requirement of this accreditation we are obliged to disclose a list of successful attendees of this course for their records.
Any data provided to BSHAA will be subject to their own policies.
5.2 Other than as indicated in 5.1 your personal contact data will be held in accordance with this Policy and will not be shared with others unless you provide your consent and permission to receiving further information or request to be contacted. You will have the opportunity to provide your consent as you progress through this training course and associated material.
Any data provided to a third party with your consent, will be subject to policies operated by the third party.
5.3 Your personal data will also be stored on the servers of our hosting services providers Thinkific Labs Inc. in accordance with their policies.
https://www.thinkific.com/resources/terms-of-service/
5.4 Financial transactions relating to our training course and associated materials are handled by Thinkific Inc.’s own payment platform (TCommerce) which are powered by the payment services providers, Stripe and Paypal. Details of which can be found below:
https://www.paypal.com/us/legalhub/privacy-full
6. International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK data protection law OR EU data protection law OR UK and/or EU data protection law.
6.2 Our Hosting Service provider for our training course and associated materials is Thinkific Labs Inc., who are situated in the USA. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of the UK and USA. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which you can obtain from https://www.thinkific.com/resources/terms-of-service/
7. Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 Our Hosting Service provider for our training course and associated materials is Thinkific Labs Inc., who will retain your personal data in line with their policies:
https://www.thinkific.com/privacy-policy/
and
We will retain your personal data for a period of 10 years, in line with standard retention periods.
7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting:
European Data Protection Board and
Information Commissioners Office.
8.4 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].
9. Cookies used by our service providers
9.1 Our service providers use cookies, and those cookies may be stored on your computer when you visit our website.
9.2 We use Thinkific Labs Inc. to host and deliver our on-line training platform. This service uses cookies as specified at: https://www.thinkific.com/cookies-policy/
10. Amendments
10.1 We may update this policy from time to time by publishing a new version within our training course and associated materials.
10.2 We may notify you of any significant changes to this policy.
11. Our details
11.1 This training course and associated materials are owned and operated by Lena Batra, unless otherwise stated within the training course and associated materials.
11.2 You can contact us using the Lena Batra website contact form at: www.lenabatra.com
12. Representatives
12.1 Our representative with respect to our obligations under data protection law is Lena Batra and you can contact our representative using the Lena Batra website contact form at: www.lenabatra.com, as provided in Section 11.2
13. Data protection officer
13.1 Our data protection officer's contact details are as in Section 12.1
