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unleashr logo new colour

Privacy Policy

Last updated: 01 September 2020

This Privacy Policy describes the information we process to support the development, improvement and delivery of Products & Services offered by UnleashR.

UnleashR is comprised of various individual global, country, practice, product or service-specific websites, each of which is provided by UnleashR Limited. This Privacy Policy applies to all websites and web pages of unleashr.com and unleashr.co.uk and the additional product, practice or service specific websites; e.g. unleashr-mentoring.com, which is referred to below as “this Website”.

UnleashR Limited (also referred to below as “we”, “us” or “our”) is a privacy-conscious organisation and this Privacy Policy explains how we protect visitors’ and users’ information gathered via this Website.

By using this Website or any of UnleashR Products & Services, you agree to the use of your information as described in this Privacy Policy, in compliance with all relevant data management laws and regulations, including the GDPR.

Please note that other websites that may be linked to this Website, but are not provided by UnleashR Limited, are not governed by this Privacy Policy, and UnleashR takes no responsibility for those sites.   

We encourage visitors to review each of these other websites’ Privacy Policies before disclosing any personal information.

This Privacy Policy may be supplemented or amended from time to time by other policies that are specific to specific areas of this Website (e.g. products & services or recruitment).

Summarised the key reasons why we collect, use or share data:

  • To fulfil our UnleashR Terms of Service, General Terms and Conditions, or Product or Service specific Terms and Conditions, or Terms of Use
  • To be in alignment with the local or international regulatory requirements and comply with our legal obligations
  • In the public interest, to provide free-of-charge support and tools for the development of personal and interpersonal skills
  • To provide innovative, relevant, high-value and profitable support & services to our visitors, clients, users and partners, unless those interests are overridden by your interests or fundamental rights and freedom that require the protection of personal data.

We collect and store the information, including content and information you provide when

  • you use our Products & Services or the features of this Website, including when you sign up for any content (document, audio, video) or tool we give away for free or as a gift, or a coupon/voucher of any kind we provide;
  • or when you use an account;
  • or create or share content and messages on the provided platforms.

The information you provide on the Mentoring platform (Thinkific) and during your participation in any of our mentoring programmes is regulated by the Terms and Conditions of Thinkific and the specific Mentoring Programme you purchased. Your name, username and photo (if you include one) will be visible to other users on the Mentoring platform (Thinkific).

Data with special protections: Solely on your decision, you can choose to provide information in your profile on the Mentoring Platform (Thinkific) or in the groups, thread, comments about your religious views, political views, or your health; however we respectfully advise not to share such information. We do not collect, monitor, analyse, share or use in any way such information.

This and other information (such as racial or ethnic origin, philosophical beliefs or trade union membership) is subject to special protections under EU law. Such information, if you decided to include it or share it, may be stored as part of your communication or profile, however unleashr does not collect, monitor, analyse, share or use in any way such information.

We collect contact information if you choose to enter it, using it to contact you and conduct marketing analytical processes, basically to provide you with a fitting high-quality service, as well as to identify your payment in case you make a purchase.

We collect and analyse information about how you use our Products & Services, such as the types of content that you view or engage with, the features you use, the actions you take, and the frequency/duration of your activities. For example, we log when you’re using and have last used our Products & Services, as well as what posts, articles, videos and other content you view on our Websites or Platforms when using our Products & Services. Such platforms may be operated by our Suppliers.

If you make a purchase or other financial transaction (such as when you make a donation), we may collect information about the purchase or transaction. This includes payment information, such as your credit or debit card number and other card information, other account and authentication information, and billing, delivery and contact details. Such details are collected and stored by our Supplier Stripe and Spiffy (Spiffy.co). Please check the Privacy Policy of Stripe. Please check the Privacy Policy of Spiffy (Spiffy.co)

As part of our Products & Services, we provide our clients with the opportunity to interact with other like-minded people in groups. We don’t store but can view and analyse content, communications and information that you and other people provide in such groups when you and they use our Products & Services. This can include information about you, such as when others mention you or comment on a post or photo of you. The technological background for such groups may be provided by Facebook or Thinkific. Please check Facebook’s Privacy Policy for details. Please check Thinkific’s Privacy Policy for details.

Depending on how you connect to this Website or our Products & Services on our Mentoring Platform (Thinkific), information may be collected from you by Thinkific about the computers, tablets, phones, connected TVs or other web-connected devices you use. For example, we use information collected about your use of our Products & Services on your phone in order to better personalise the content or features that you see when you use our Products & Services on another device, such as your laptop or tablet. Information obtained from these devices may include cookie data (data from cookies stored on your device, including cookie IDs and settings). Learn more about how we use cookies in the UnleashR Cookie Notice. https://unleashr-mentoring.com/cookie-notice/

We also receive information about your online actions and purchases from third-party data providers who have the right to provide us with your information. Such providers are Facebook, Instagram, YouTube, ActiveCampaign, Thinkific, Spiffy (Spiffy.co) and Stripe. Please check the privacy policy of these organisations.

We require each of these partners to have lawful rights to collect, process, use and share your data before providing any data to us.

We use information that you provided us based on decisions and choices you made as described above and below, and to provide and improve the UnleashR Products and related services described in the Terms and Services or in the Product Specific Terms and Services.

How do we use information that you provided us with?

We use information that you provided us with to deliver and improve our Products & Services, including the personalisation of features and content and make suggestions for you (such as free/paid products, services, groups, or events you may be interested in).

We use the information you provided us with to create Products & Services that are unique and relevant to you.

We use feedback and data about visitor and user activity on this Website and concerning the use of our Products & Services. We use it to learn from you and others (excluding any data with special protections that you choose to provide); about how you use and interact with our Products & Services.

We analyse information about your activities on this Website, and on connected platforms, in order to provide a more relevant and consistent experience of the unleashr Products & Services, you decided to use, wherever you use them. For example, we may suggest that you join a particular group where you may receive more valuable information and support.

We use location-related information, when you sign up for our newsletter, to provide, personalise, and improve our Products & Services. Location-related information can be an IP address or geographical information. Our partners such as Thinkific, Spiffy (Spiffy.co) and Stripe may store your geographic information if you provide it during the purchase or use of your chosen Products and Services. Such data provision enables us to identify or verify your payment or to detect potential breaches to profiles or Terms and Conditions related to our products.

We use information that you provided us to develop, test and improve our Products & Services, including by conducting surveys and research, as well as testing and troubleshooting new Products & Services and features of this Website. When launching surveys or performing analysis, we make sure we provide you with information about the data we gather during the surveying period/research, and we ensure that have your consent.

We use information that you provided us (including your activity online and in relation to our websites or Products) in order to measure the effectiveness of our Products & Services.

We use information that you provided us to verify accounts in a sense that we make sure that you subscribed to our newsletters or Products & Services and to maintain the integrity and safety of our Products & Services. For example, we may use data that we have in order to investigate suspicious activity or breaches of our Terms or Policies and to ensure that we operate lawfully and in compliance with the laws and regulations.

We use information that you provided us you to send you marketing communications, communicate with you about our Products or Services or other options that we may have come across and believe may be relevant to you, and to let you know about our Policies and Terms & Conditions. We also use your information to respond to you when you contact us.

We use information that you provided us (including from research partners who we may collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health, and well-being. For example, we may analyse information that you provided to us about diversity or equality issues.

How do we share the information you provide us with?

When you share and communicate using our Products & Services, you choose to communicate with the public or a specific group, depending on where you communicate. On this Website, you communicate to the public, on our mentoring platform (Thinkific: where you have to log in) you communicate within a particular group (other people who also logged in their own profiles and are members of a mentoring group), and in Facebook Groups you communicate with the members of that particular group.

You may share information on various social media channels, such as a comment or a photo or a video, on one of our posts or comments; in such cases, please check your privacy settings and the privacy policy of that particular social media account and provider.

Public information can be seen by anyone, even if they don’t have an account. This includes any information you share with a public audience. Such information may be content you share on this Website (i.e. your comments on a post). Public information can also be seen, accessed, reshared, or downloaded through third-party services such as search engines, APIs, and offline media such as TV, and by apps, websites, and other services that integrate with our Products & Services.

You should be highly considerate with whom you choose to share public information, because people who can see your activity may decide to share it with others in person, on any platform or website or in any app, including people and businesses outside the audience that you shared with.

For example, when you share a post or send a message to specific friends or accounts, they can download, screenshot, or reshare that content to others across or off this Website. Also, when you comment on someone else’s post or react to their content, your comment or reaction is visible to anyone who can see the other person’s content, and that person can change their audience at a later date.

People can also use this Website or one of the platforms related to our Products & Services to create and share content with you with the audience they choose. For example, people can share a photo of you in a story or mention, tag you at a location in a post, or share information about you in their content or messages. If you are uncomfortable with what others have shared about you on this Website or on our mentoring platform (Thinkific), please contact us by sending email to questions@unleashr.co.uk.

If you are uncomfortable with what others have shared about you in any of the groups related to our Products & Services but provided by a third-party supplier (e.g.: Facebook, Thinkific), please check Facebook Privacy Policy for more information; please check Thinkific Privacy Policy for more information.

If the ownership or control of all or part of our Products & Services or their assets changes, we may transfer your information to the new owner.

We may work with third-party partners who help us provide and improve our Products & Services, such as Gentech Consulting.

We don’t sell any of your information to anyone and we never will. We also impose strict restrictions on how our partners can use and disclose the data we may provide.

Below you can read about how we share information with third parties 
(partners, other organisations, or regulatory bodies)

 

Partners who benefit from our analytics and marketing services

We may provide anonymous, and aggregated statistical data and insights that help people and businesses understand how they may develop their own businesses, what engagement methodologies may work better and what processes and tools might work better.

Suppliers and service providers

We may provide anonymous, and aggregated information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analysing how our Products & Services are used, providing customer service, facilitating payments or conducting surveys. We use the platforms of such service providers. As a result, some information such as your name, email address, location or payment details may or will be stored by those service providers: Facebook, Google, Thinkific, Spiffy (Spiffy.co), Stripe, Zapier, TaxJar, Gentech Consulting otherwise we cannot provide you with the Products & Services we offer or with the features of this Website.

Legal and law enforcement requests

As part of our legal obligations, we share information with law enforcement or in response to legal requests in the circumstances outlined below.

We access and share information that you provided us (on this Website or on any of the platforms in relation with our Products & Services) directly or indirectly, by requesting access or requesting collaboration from the third-party supplier with regulators or law enforcement or others in response to a legal request, if we believe in good faith that the law requires us to do so and  the response is required by law in that jurisdiction, affects users in that jurisdiction and is consistent with internationally recognised standards.

We may access, analyse, or share information that you provided to us when we have a good reason to believe that it is necessary to detect, prevent and address

  • fraud;
  • unauthorised use of the Products & Services or the features of this Website;
  • or breach of our General Terms and Conditions or Policies;
  • or other harmful or illegal activity
  • to protect ourselves (including our rights, property or Products & Services), you or others, or when it is required of us as part of regulatory enquiries or investigations; or to prevent death or imminent bodily harm.

For example, if relevant, we provide information to and receive data from third-party partners about the reliability of your account in order to prevent fraud, abuse and other harmful activity in relation with the use of this Website or our Products & Services.

Information that we receive about you (including financial transaction data related to purchases made with UnleashR) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation or investigations of possible breaches of our Terms or Policies, or otherwise to prevent harm. We also retain information from accounts disabled for term breaches for at least a year to prevent repeat abuse or other term breaches.

How can you exercise your rights provided under the GDPR (General Data Protection Regulation)?

Under the terms of the GDPR, you have the right to access, amend/correct, export and delete your data.

If you subscribed to any of our newsletters, you have the opportunity to change your name and email address or unsubscribe at any time by clicking on the relevant link at the bottom of any email we send you. Once you unsubscribed we no longer have access to or manage your data and no longer get in contact with you, unless your data were stored because of a business transaction and there is a regulatory or contractual obligation we are required to meet.

If you use our mentoring services, you have the access necessary to change your name and password as well as other details you provide on your profile. For changing your email address, please contact client-services@unleashr.co.uk. Your email address is an essential piece of information to prove your eligibility for using a product you purchased and have access to, changing this information requires verification of your identity.

If you are our customer and wish to export any of your data, please contact client-services@unleashr.co.uk.

If you are a subscriber and wish to export any of your data, please contact questions@unleashr.co.uk

You also have the right to object to and restrict certain processing of your data. This includes:

The right to object to our processing of your data for direct marketing, which you can exercise by using the “unsubscribe” link in such marketing communications and

The right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can exercise this right by informing us about your objection in an email sent to questions@unleashr.co.uk.

Data retention, account deletion

We store data until it is no longer necessary to provide our Products & Services to you or until your account is deleted taking into consideration our legal and statutory obligations. Please always see General Terms and Conditions and Terms of Use. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.

There is data that we do not store but view, process and analyse. Such data may be stored by a partner of unleashr. For example, data regarding the way you use this Website may be collected by Google Analytics, Facebook and ActiveCampaign, Thinkific, Spiffy (Spiffy.co), Stripe, TaxJar. Please see the Privacy Policy of each website for more information. Your payment information is collected, processed and stored by Spiffy (spiffy.co) and Stripe; UnleashR doesn’t store your payment details. Please see Stripe’s Privacy Policy for further information. Please see Spiffy (Spiffy.co)’s Privacy Policy for further information.

We manage all sales through Thinkific, Spiffy (Spiffy.co) and Stripe, please check the Privacy Policy of Thinkific, Spiffy (Spiffy.co) and Stripe.

When you delete your account on the mentoring platform (Thinkific) please check Privacy and Data Management Rules on the Thinkific site. Information that others have shared about you isn’t part of your account and won’t be deleted. This website operates on a wordpress.com platform; please see wordpress.com Privacy Policy for further information.

How do we operate and transfer data as part of our global activities and services?

We share information globally, both internally within the UnleashR businesses and externally with our partners and suppliers for the purposes which are described in this Policy and in accordance with this Policy.

Internal information flow is managed under the Internal Communication and Information Flow Policy which has also been developed in alignment with the requirements of GDPR.  Information collected by UnleashR in the United Kingdom or in the United States may be transferred or transmitted to, or stored and processed in, the United States or other countries for the purposes which are described in this Policy.

These data transfers are necessary to provide the Products & Services outlined in the UnleashR Terms & Conditions and to globally operate. We utilise standard contractual clauses which are approved by the European Commission and rely on the European Commission’s adequacy decisions about certain countries, as applicable, for data transfers from the EEA to the United States and other countries.

All our suppliers and collaborators we share information with operate on a global scale and are required to comply with the GDPR.

Notification of changes to this Policy.

We’ll notify you before we make changes to this Policy and give you the opportunity to review the revised Policy.

What is our role in data management?

unleashr is a data controller.

Legal background to this Privacy Policy

Guidance of Information Commissioner’s Office: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/

Guide to Data Protection: https://ico.org.uk/for-organisations/guide-to-data-protection/

GDPR: https://www.eugdpr.org/

Data Protection Bill: https://services.parliament.uk/bills/2017-19/dataprotection.html