WHITE FROG PUBLISHING LIMITED
The General Data Protection Regulations (GDPR) and the Data Protection Act 2018 sets out the rules which White Frog Publishing Ltd must follow when processing personal data.
As a Tier 1, the company must provide notification to the Information Commissioner’s Office (ICO) bi- annually. The notification includes a list of the purposes for which all personal data is processed, the types of data being processed and who the data relates to.
White Frog Publishing Limited’s ICO Registration number is ZB021184.
1. Important information and About WHITE FROG PUBLISHING LTD
White Frog Publishing Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when and tell you about your privacy rights and how the law protects you.
We have also included a Glossary at the end of this document to help you to understand the meaning of some of the terms used in this privacy notice.
2. Purpose of this privacy notice
This privacy notice aims to give you information on how we collect, store and process and share your personal data, including any data you may provide when you sign up to our service.
We reserve the right to amend or update our privacy notice and terms at any time. We may make changes to this privacy notice from time to time and will publish any new version on our website and may notify you by email if we feel it is appropriate to do so.
WHITE FROG PUBLISHING LTD is the controller and responsible for your personal data (collectively referred to as "we", "us" or"our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: WHITE FROG PUBLISHING LTD
Name or title of data privacy manager: Lindsay Routledge
Email address: email@example.com
Postal address: 6 Highfield Drive, Gildersome, Leeds, LS27 7DW, UK
Telephone number: 0113 2532171
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
The data protection law in the UK changed on 25 May 2018 and this privacy notice sets out your rights under these new laws. This privacy notice is therefore only effective from this date.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links online
Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3. The data we collect
Personal data, or personal information, means any information about you from which you can be identified. It does not include data where your identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows, please note that these lists provide an indication of the types of data we may collect but are not exhaustive:
• Identity Data: first name, maiden name, last name, gender, marital status, title, date of birth, nationality, N.I. number and other personal ID references.
• Contact Data: Tax residency, home address (and those of other properties you own), email addresses and telephone numbers.
• Financial Data: Details of your assets, liabilities, income and expenditure. The level of detail collected is likely to be high - including values, reference numbers, history, features and benefits.
• Profile Data: includes your circumstances, ambitions, objectives, interests, preferences, feedback and questionnaire/survey responses.
• Transaction Data: Details of products and services you have purchased from us and those we have recommended to you.
• Technical Data (online): Internet protocol (IP) address, any login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, screen resolution, and other technology on the devices you use to access our website.
• Usage Data: information about how you use our website, products and services.
• Marketing and Communications Data: Communication preferences and your preferences in receiving marketing from us and our third parties.
• Aggregated Data: 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.
• Special Category Data: We reserve the right to collect and store special categories of Personal Data. However, we only anticipate doing so in very specific and rare circumstances. For example, we may need to collect health information to process a life insurance application form. These may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union memberships, drug use history, genetic/biometric data and information about criminal convictions and offences.
• Data of Others (incl. Minor Children): If you provide any personal information on behalf of someone else, you must have their consent to use their personal information, including spouses. We will only ever collect the minimum information required to deliver our service. In respect of minors, this may include names, dates of birth and school attended. You must have parental consent to provide any information on minor children to which you are not parent or guardian. Finally, a third party can provide personal information where they have the legal right to do so (e.g. under a Power of Attorney). We reserve the right to retain details of the individual and attorney in these cases.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
4. How is your personal data collected?
We use different methods to collect data from and about you, including through:
5. How we use 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:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one groundhas been set out in the table below.
|Purpose/Activity||Type of Data||Lawful basis for processing|
To prospect and onboard you as a client
1. Performance of a contract with you
To process and deliver our holistic training and planning service to you effectively
(g) Special Category
1. Performance of a contract with you.
2. Necessary to comply with a legal obligation.
3. Necessary for a legitimate interest. (continue to uphold a high quality, bespoke and personal service to you)
To manage and maintain our relationship with you. i.e. provide you with continued updates and relevant insights into training and planning matters and updating you on any changes to our terms/service.
1. Performance of a contract with you.
2. Necessary to comply with a legal obligation.
3. Necessary for a legitimate interest. (continue to uphold a high quality, bespoke and personal service to you)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. For more information on your options please contact us.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive communications from us in respect of various resource updates and new products. For example, a reminder about updating your materials to the latest versions. We provide this information in the delivery of our ongoing service; however, this is still technically marketing material. You will also receive this information if you have requested information from us.
We will get your express opt-in consent before we share your personal data with any third-party company for their own marketing purposes. We may however use a third-party marketing agency for our own marketing purposes. This may include sharing your data with this agency.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time by following the opt-out links on any marketing messages sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions. We will still use your data and contact you where it is appropriate to do so in the fulfilment of our contractual 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
6. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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.
7. International transfers
Many 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 by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. We will endeavour to ensure that the third parties we use have similar safeguards in place to those detailed above.
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.
9. Data retention
In respect of any client that we have undertaken a regulated activity for, i.e. the provision of training resources or sale of a product. We will keep your records indefinitely, unless otherwise stated. This is to ensure we are able to assist you at any time should you have any requestsabout our service to you in future.
For anyone else, 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 unauthorized 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.
Details of retention periods are available on request from us.
In some circumstances you can ask us to delete your data: see Request erasure section below for further information.
In some circumstances we may anonymize 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.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:
Further details about each of these rights are set out below.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 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 ensureyour 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract 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.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided with your consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.