Customer Privacy Policy 

CALM Training Ltd.  is a company registered in Scotland operating under the brands CALM Training and myCALM.
 

Overview 

At CALM Training we take the security of your data seriously. As a priority at CALM, we are committed to respecting your privacy rights.  We pledge to handle your data safely, securely, fairly and legally at all times. CALM is committed to giving clarity to the way we use your data and promote transparency about what data we collect about you and how we use it. 

This policy, which applies whether you enquire about CALM services through our website or social media platforms; attend one of our training events; contact us directly by phone or word of mouth; or, use our virtual learning environment , provides you with information about: 

– how we use your data;
– what personal data we collect;
– how we ensure your privacy is maintained; and
– your legal rights relating to your personal data. 

 

How we use your data 

General 

CALM Training uses your personal data: 

  • to provide training, consultancy and support services to you and your organisation; 
  • to deliver a tailored and relevant website; 
  • to facilitate a network of practitioners through our Social Media platforms; 
  • to create and manage a database of all CALM trained personnel across our customer base; 
  • with your agreement, to contact you electronically about promotional offers, products and services which we think may interest you; 
  • for market research purposes – to better understand your needs; 
  • to enable CALM to engage in meaningful customer relationship management activities with you; and 
  • where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority, regulatory body or in a legal dispute).  

Marketing 

Promotional Communications 

CALM Training uses your personal data for electronic marketing purposes (with your consent) and may send you postal and electronic mail to update you on the latest CALM products, services and opportunities.   

CALM Training aims to update you about products & services which are of interest and relevance to you as an individual and to the organisation you work for.  

You have the right to opt out of receiving promotional communications at any time, by contacting CALM Training through the contact channels set out in this Policy or by using the unsubscribe button at the bottom of our marketing communications. 

 

Sharing data with third parties 

Our service providers and suppliers 

In order to make to tell you about what CALM can offer you, we may need to share your personal data with some of our service partners such as Mail Chimp, which is the service we use for our email marketing campaigns.   

CALM Training only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls.  We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to CALM training and to you, and for no other purposes. 

Other third parties 

Aside from our service providers, CALM Training will not disclose your personal data to any third party, except as set out below.  We will never sell or rent your data to other organisations for marketing purposes. 

We may be required to share your data with: 

  • governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so: – 
  • to comply with our legal obligations; 
  • to exercise our legal rights (for example in court cases); 
  • for the prevention, detection, investigation of crime or prosecution of offenders; and 
  • for the protection of our employees and customers. 

 

International transfers 

CALM Training will not share any of your personal data with overseas service providers. 

 

How long do we keep your data? 

We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data. 

 

What personal data do we collect? 

CALM Training may collect the following information about you in the following way:

From accessing our training programs:

  • your name, age/date of birth and gender; 
  • your professional qualifications; 
  • your contact details: postal address including organisation address, telephone numbers (including mobile numbers) and e-mail address; 
  • previous CALM Training and other relevant training secured by you;

From visiting our website and social media platforms:

  • your on-line browsing activities on CALM websites and CALM social media platforms; 
  • your password for use on CALM Trainings virtual learning environment myCALM; 
  • your communication and marketing preferences; 
  • your interests, preferences, feedback and survey responses; 
  • your location; 
  • your correspondence and communications with CALM 

Our websites are not intended for children and we do not knowingly collect data relating to children. 

This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you use our contact page on our website or send an email to our Administration Team, or when you telephone CALM Training. We may also collect personal data from third parties who have your consent to pass your details to us, such as your employer, or from publicly available sources. 

How we protect your data 

Our controls 

CALM Training is committed to keeping your personal data safe and secure.  In order to prevent unauthorised access or disclosure, we have created physical, electronic and managerial procedures to safeguard the information we collect online. 

Our security measures include: – 

– security controls which protect the entire CALM IT infrastructure from external attack and unauthorised access; and 

– internal policies setting out our data security approach and training for employees. 

 

Your rights 

You have the following rights: 

  • the right to ask for a copy of personal data that we hold about you; 
  • the right (in certain circumstances) to request that we delete personal data held on you; where we no longer have any legal reason to retain it; 
  • the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you; 
  • the right to opt out of any marketing communications that we may send you and to object to us using / holding your personal data if we have no legitimate reasons to do so; 
  • the right (in certain circumstances) to ask us to ‘restrict processing of data’; which means that we would need to secure and retain the data for your benefit but not otherwise use it; and 
  • the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation. 

 

Legal basis for CALM Training to process customer personal data 

General 

CALM Training collects and uses customers’ personal data because is it necessary for: 

  • the pursuit of our legitimate interests (as set out below); 
  • the purposes of complying with our duties and exercising our rights under a contract of provision to our customer; or 
  • complying with our legal obligations. 

In general, we only rely on consent as a legal basis for processing personal data in relation to sending direct marketing communications to customers via email or text message. 

Customers have the right to withdraw consent at any time.  Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn. 

 

Our Legitimate Interests 

The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of CALM Training, including: – 

  • selling and supplying training, support and consultancy services to our customers; 
  • protecting customers, employees and other individuals and maintaining their safety, health and welfare; 
  • promoting, marketing and advertising our products and services; 
  • sending promotional communications which are relevant and tailored to individual customers; 
  • understanding our customers’ behaviour, activities, preferences, and needs; 
  • improving existing products and services and developing new products and services; 
  • complying with our legal and regulatory obligations; 
  • preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; 
  • handling customer contacts, queries, complaints or disputes; 

 

Cookies 

New cookie legislation 

Most websites you visit will use cookies in order to improve your user experience by enabling that website to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’). New legislations mean your website must make users aware if you use cookies and prompt them not to use cookies when viewing your site. 

Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. Cookies make the interaction between you and the website faster and easier. If a website doesn’t use cookies, it will think you are a new visitor every time you move to a new page on the site. This can have an impact on sites that have log in areas where the user would need to create a new log in every time they moved from page to page. 

Some websites will also use cookies to enable them to target their advertising or marketing messages based for example, on your location and/or browsing habits. Cookies may be set by the website you are visiting (‘first party cookies’) or they may be set by other websites who run content on the page you are viewing (‘third party cookies’). Websites which use Google Analytics to track visitor numbers are using cookies to monitor this information. 

What is in a cookie?  

A cookie is a simple text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or what’s in your shopping basket. 

What to do if you don’t want cookies to be set?  

Some people find the idea of a website storing information on their computer or mobile device a bit intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set; but you need to be aware that you might lose some functions of that website. How can I control cookies? 

Web browser cookies  

If you don’t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set. If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers. 

Links to other sites 

CALM Trainings website contains links to external websites. Privacy policies on these sites may vary and, as such, we are not responsible for the content or privacy policies of these sites. 

 

Data Protection Officer 

CALM Training has appointed a Data Protection Officer to ensure we protect the personal data of our customers and comply with data protection legislation. 

If you have any questions about how CALM Training uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact our Data Protection Officer on the contact details below; 

– phone: 01259 763681; 

– e-mail: info@calmtrianing.co.uk or 

– write to: Data Protection Officer, CALM Training, Elmbank Mill, The Charrier, Menstrie. FK11 7BU 

You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk. 

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