Wednesday 19 December 2018

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Privacy Notice

Introduction

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter is referred to as ‘you’ or ‘Data Subject’) that is not already in the public domain.

Personal Data and how we use it

Doulos uses the information collected from you to provide quotations, register you for online and face-to-face and other training events, make telephone contact and to email you marketing information which Doulos believes may be of interest to you and your business. In you making initial contact you consent to Doulos maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. Doulos also acts in the capacity of data processor when sharing personal information with (GDPR compliant) third parties working in partnership on live events (including face-to-face training and workshops and online training, including webinars). The details of the partners involved will always be clearly indicated at the point of data collection (registration) and the data will only be shared with partners who can demonstrate they are GDPR compliant.

Personal data about you may be stored from the forms and surveys you complete, course and events bookings or registrations, sales transactions, other records of our correspondence and phone calls and details of your visits to our website. This data may include, but is not limited to, personally identifying information like Internet Protocol (IP) addresses and third-party information obtained about you from public sources and our own suppliers such as credit referencing agencies. Doulos may from time to time use such information to identify you and collect statistics about your website activity.

Doulos will only collect the information needed so that it can provide you with marketing, consulting and training services, we do not sell or broker your data. You also have full control of the types of marketing information you receive (see Opt-Out Policy below).

Cookies

Doulos’ website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Cookies are used for your convenience when downloading content from the website. Your country and email address are stored in the cookie so that you do not need to enter this information more than once. You do not need to keep the cookie permanently, however it will need to be present, at least temporarily, to allow the download.

Cookies are also required to make a purchase from the webshop, however these only last for the duration of your visit.

Tracking

The Doulos website collects tracking information which allows us to see how people are using the site and make improvements. All tracking information is stored by Doulos and is not collected by, or released to, third parties.

If you do not wish to be tracked by our site, you may opt out here. Our software also respects the 'Do not Track' headers that most modern browsers provide, and will not track you if these are set. You can also stop tracking by disabling Javascript (although some areas of the site will be degraded in this case).

Web hosting providers

Cloudflare manage and secure the traffic to some of the Doulos websites. They will log access in accordance with their security policy, and share aggregated data with us.

YouTube

Selected pages on this site contain embedded YouTube videos, which will enable Google to collect information about your activity on those pages in accordance with their privacy policy. We use a privacy-enhanced link so that Google do not store cookies until you play the video.

Payment Processing

Paypal manage our payment processing in accordance with their privacy policy (UK | US). No data is shared with PayPal until you click on a payment link in the webshop or booking area of myDoulos.

Links

This site contains links to other websites. We are not responsible for the privacy practices of these and you should read their own privacy policies. The policy described here, applies only to personal data collected by Doulos.

Legal basis for processing any personal data

To meet Doulos’ contractual obligations to clients and to also respond to marketing enquiries.

Legitimate interests pursued by Doulos and/or its clients

To promote the marketing and consulting and training services offered by Doulos and/or to market the services and/or products offered by Doulos’ clients.

Consent

By agreeing to this privacy notice you are consenting to Doulos processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing DPO@doulos.com or writing to us, see last section for full contact details.

Disclosure

Doulos may on occasions pass your Personal Information to third parties exclusively to process work on its behalf or those working in a partnership arrangement on live events as detailed above. Doulos requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. Some data is passed to parties situated outside the EEA. In this case Doulos will ensure they are part of Privacy Shield (if a USA entity) or that they can demonstrate they adhere fully to the requirements of GDPR.

Doulos do not broker or pass on information gained from your engagement without your consent. However, Doulos may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. Doulos may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Doulos, its clients and/or the wider community.

Retention Policy

Doulos will process personal data during the duration of any contract and will continue to store only the personal data needed for five years after the contract has expired to meet any legal obligations. After five years any personal data not needed will be deleted.

Data storage

Data is held by Doulos in the UK, Germany and in the USA. The data held in the USA conforms to the full requirements of GDPR. Data stored in the cloud will be with GDPR compliant suppliers.

Your rights as a data subject

At any point whilst Doulos is in possession of or processing your personal data, all data subjects have the following rights:

  • Right of access - you have the right to request a copy of the information that we hold about you.
  • Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing - where certain conditions apply you have a right to restrict the processing. See The Doulos Opt-Out Policy
  • Right of portability - you have the right to have the data we hold about you transferred to another organisation.
  • Right to object - you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling - you also have the right not to be subject to the legal effects of automated processing or profiling.


In the event that Doulos refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
Doulos at your request can confirm what information it holds about you and how it is processed.

You can request the following information:

  • Identity and the contact details of the person or organisation (Doulos) that has determined how and why to process your data.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Doulos or a third party such as one of its clients, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority (Data Protection Regulator).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what personal data is held, identification will be required

Doulos will accept the following forms of ID when information on your personal data is requested: a photocopy or scanned image of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Doulos is dissatisfied with the quality of the ID copies, further information may be sought before personal data can be released.

All requests should be made to dpo@doulos.com or by writing to us at the address further below.

Opt-Out Policy

You have full control of the types of marketing emails you receive. These can be selected by using the Doulos email subscription form.

You may choose to unsubscribe from any, or all of our email notification services at any time. Before you opt-out, keep in mind that Doulos strives to minimize the number of notices emailed to approximately 5 per month (and these include course schedule announcements and webinar invitations). You may miss out on important invitations if you choose to opt-out from all Doulos mailings.

To change your preferences, and limit the emails you receive in some way rather than opt-out, please use the Update my preferences link on any marketing email from Doulos or contact your local team if you would prefer.

Changes to this policy

The Doulos privacy policy may change at any time, so you may wish to check it each time you visit our website. We will not reduce your rights under this Privacy Policy without your explicit consent.

Complaints

In the event that you wish to make a compliant about how your personal data is being processed by Doulos or its partners, you have the right to complain to Doulos’ CEO. If you do not get a response within 30 days you can complain to the Data Protection Regulator.
The details for each of these contacts are:
Doulos, attention of the CEO
22 Market Place, Ringwood, Hampshire, BH24 1AW
Telephone +44 1425 471223 or email dpo@doulos.com

Data Protection Regulator (ICO)
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: +44 303 123 1113 or online messaging: https://ico.org.uk/global/contact-us/email
Or email: registration@ico.org.uk



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