PRIVACY POLICY
We currently collect and process the following information relating to prospects, clients and members:
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Personal contact details (for example, name, address, email and phone contact details which could include personal and work contact information and job title/role and social media accounts)
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Characteristics – for some purposes we ask you to provide gender, nationality, date of birth and ethnicity for monitoring purposes
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Details of products/services/memberships you have purchased from us
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Payment information including bank account details
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Personal information that might be shared in content from communications such as letters, emails, CVs, job applications, references, conversations, assignments, social media posts, chats within online conferencing and online forums
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Results of your assignments
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Data on how you use our services – e.g. web browsing, opening emails
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Marketing consent choices
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For our membership networks we will also ask you to provide the following in order for us to be able to understand your background and what you want from your membership:
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Other professional memberships
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Relevant qualifications, experience and skill
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What you want from the network
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THE TYPE OF PERSONAL INFORMATION WE COLLECT
HOW WE GET THE PERSONAL INFORMATION AND WHY WE HAVE IT
Most of the personal information we process is provided to us directly by you for one of the following reasons:
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Dealing with an enquiry
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Registering for a course or qualification
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Working with you as a client for our services
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Employment
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Joining a membership network run by us
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The personal information could be provided via:
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The contact form on our website
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A membership application form
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Registration on our learning portal
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Emails, letters, phone conversations, social media messages, and chat function in online conferencing
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Event booking forms
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Registration forms
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CVs, letters, certificates
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Cookies on our website
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We use the information that you have given us in order to:
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Assess the suitability for our programmes, providing quotations and delivering the services of coaching, mentoring, training, membership or any associated activity.
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Keeping records of the services provided.
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Invoicing for services and maintaining records of financial transactions for scrutiny by HMRC and other authorities.
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Sending you information about our business and topic areas you may be interested in – by email, post, social media
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Enabling you to connect with others through our membership networks
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We may share this information as follows:
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Within Xenonex with employees who need the data to provide the services
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With trusted partners such as associates, our accountant, event or hospitality suppliers – we would have a contract with such providers which covers personal data confidentiality
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If you are completing a qualification with us, relevant data will be shared with ILM for registration and External Quality Assurance purposes
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If required by statutory or legal obligation to HMRC, the Police or Courts
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We DO NOT sell or share our data to other organisations.
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Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
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(a) Your consent. You are able to remove your consent at any time. You can do this by contacting us at the address at the bottom of this notice.
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(b) We need the data in order to fulfil the contract we have with you for providing services.
HOW WE STORE YOUR PERSONAL INFORMATION
Dependent on the source of your personal information, it may be stored in a number of locations:
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Within emails on MS Outlook/Ionos email, iCloud and on portable devices
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On an Internet-based CRM or other third-party system*
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Within our bespoke ‘Academy’ Learning Portal
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In documents and spreadsheets on Dropbox
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Within an online accounting system
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Occasionally in paper files stored at the company premises
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* All ICN membership applications, renewals and associated events are processed through a third-party system, Wild Apricot. In order for members and visitors to access their profiles on the member site, all users agree automatically to the Wild Apricot terms of use and privacy policy. Online payment is taken by Stripe, via a secure connection, who operate as the Data Controller within this process and are PCI compliant. Xenonex do not take or record payment details via our website and your payment data will therefore be subject to Stripe’s Privacy Policy.
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COOKIES
Cookies are small pieces of text information sent to your browser when visiting a website. We use cookies to store information about your visit and enhance the functionality of your visit. No personal information or information that could be used to identify individuals is held in these cookies.
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You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled. To find out how to enable/disable cookies see www.allaboutcookies.org.
DATA SECURITY
SPECIAL CATEGORY DATA HANDLING
Certain data requires special handling because if disclosed accidently, it could have a harmful effect on you. This includes sensitive data such as race and ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data, health or sexual orientation. As such, we will only use this data with your consent unless it is in your vital interest (threat to your life), it is in our legitimate interests, where there is a legal obligation or a contractual commitment.
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SECURITY OF ALL DATA
We use Internet standard encryption technology (“SSL” or “Secure Socket Layer” technology) to encode personal data that you send to us when sending a membership request through the website or registering on our ‘Academy’ learning portal. To check that you are in a secure area of the Website before sending personal data to us, please check that your browser displays an image of a closed padlock or an unbroken key.
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However, please note that whilst we take appropriate technical and organisational measures to safeguard the personal data that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal data that you transfer over the Internet to us.
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We will take all steps reasonably necessary to ensure that all personal information is treated securely and in accordance. Access to your personal information will be restricted to such staff and other individuals as are necessary for the purposes for which the information was collected.
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Unless we explain otherwise to you, we’ll hold relevant data for as long as we have reasonable business needs – i.e. for managing our relationship with you and managing our operations.
We retain information about our ILM qualification candidates indefinitely for the purposes of external scrutiny.
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If you join one of our membership networks, we will retain your information while you are a member. At the point of non-renewal you can notify us whether you wish your data to be erased. You can opt-out of marketing mailings at any time.
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Note that if you have been a client, if you unsubscribe from our marketing mailings, we will retain information about our work with you as follows:
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Information relating to financial transactions, which includes some personal data is held for up to 10 years within our accounts system.
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Relevant paper-based and electronic documents recording client sessions
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If you have signed up for email mailings you remain on the list until you unsubscribe, which you can do at any time, or we decide to purge our systems.
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YOUR DATA PROTECTION RIGHTS
Under data protection law, you have rights including:
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Your right of access – You have the right to ask us for copies of your personal information.
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Your right to rectification – You have the right to ask us to rectify personal information you think is
inaccurate. You also have the right to ask us to complete information you think is incomplete.
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Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
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Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
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Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
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Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
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You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
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Please contact us at the address below if you wish to make a request.
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CONSENT
By providing your Personal Information and registering with us or logging on with us when you enter our website, you explicitly consent to the our processing and disclosing your Personal Information for the purposes, and otherwise in the manner, set out on this page, or as otherwise provided in accordance with the Terms and Conditions. If you wish to qualify, vary, modify or limit your consent in any way then please notify us. Our contact details are located in the Contact Us pages of our website.
EMAIL NOTICE AND DISCLAIMER
Any email and any files transmitted with it may contain confidential and/or privileged material and is intended solely for the use of the individual(s) to whom it is addressed. If you are not the intended recipient(s) indicated in this message, please notify us immediately by return and delete this email. Any retention, disclosure, distribution, copying, or other use of this information is strictly prohibited and without liability on our part. Please note that neither Xenonex Ltd nor the sender accepts any responsibility for any viruses that may be contained in this e-mail or its attachments.
HOW TO COMPLAIN
If you have any concerns about our use of your personal information, you can make a complaint to us at the address at the bottom of this page. You can also complain to the ICO if you are unhappy with how we have used your data.
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The ICO’s address:
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Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
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Helpline number: 0303 123 1113
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ICO website: https://www.ico.org.uk
OUR CONTACT DETAILS
Xenonex Ltd (registered in England and Wales with company number 06722946 VAT registration No: 942438810)
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Bishopdale Suite, Regional Agricultural Centre, Great Yorkshire Showground, Railway Rd, Harrogate HG2 8NZ
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01423 546162
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