Privacy Notice

Visible Strengths Co. (collectively known as Visible Strengths Co., “we”, “us”, or “our”) is an Education & Coaching Academy for Career Professionals.

This Privacy Notice aims to:

• give you information on how Visible Strengths Co. collects, handles, processes, transports and stores your personal data through your use of this website, including any data you may provide when you sign up for our newsletter, take part in any of our events, contact us, fill in a form, or otherwise (regardless of where you visit it from);
• tell you about your privacy rights and how the law protects you;
• explain the way that access can be granted to personal information held by us; and
• explain the manner of dealing with any complaints concerning the correctness of or access to personal information.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 2018 (the “Act”) and the EU General Data Protection Regulation (“GDPR”), the data controller is Visible Strengths Co.

You have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do not hesitate to contact us in the first instance.

FG Funnels

FG Funnels hosts our site. Personal Information (as defined below) hosted by or through FG Funnels is subject to their privacy policy, which may or may not contain terms as protective as this Privacy Notice. By using our site, you agree to also be bound by FG Funnels’ Privacy Policy.

Who is this Privacy Notice for?

This Privacy Notice describes how we treat and use the personal data we collect about any person who uses our website or services.

Children’s privacy

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you know that your child has provided us with personal data, please contact us by email at mma@visiblestrengths.co. If we become aware that we have collected personal data from children without verification of parental consent, we will take steps to remove that information from our servers.

If you do not provide personal data

If we need to process the data you provide about yourself in order to fulfil our service and you fail to provide that data when requested, we may not be able to perform the service, in which case we may have to cancel a product or service you have with us. We will notify you if this is the case at the time.

What information do we use?

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 (i.e. anonymous data). We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

We also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Privacy Notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your philosophical beliefs, sex life, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Tracking & cookies data

We use cookies and similar tracking technologies to track activity on our service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies such as beacons, tags and scripts are also used to collect and track information and to improve and analyse our service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies you may be unable to use some portions of our service.

Examples of cookies we use:

• Session Cookies. Used to operate our service.
• Preference Cookies. Used to remember your preferences and various settings.
• Security Cookies. Used for security purposes.

Analytics information

FG Funnels uses analytics tools to help us measure traffic and usage trends for our site. These tools collect information your browser sends as part of a web page request, including the web pages you visit, browser add-ons, and other information that assists us in improving our site. We may collect and use this analytics information with your Personal Information and stitch together session data from user visits to build a broader profile of our individual users to serve you better.

Public forums

Our site has features that enable users to post content publicly (including, without limitation, user comments). The protections described in this Privacy Notice do not apply when you provide information (including Personal Information about you or any person) concerning your use of these public forums. Any information you share in a public forum is public information and may be seen or collected by other persons, including third parties, that do not adhere to the standards outlined in this Privacy Notice. We are not responsible for events arising from the distribution of any information you choose to post or share publicly through our site. You agree that we may use Personal Information and other information about you to identify you with a posting in a public forum. If you would not like to have these details disclosed, you should refrain from posting any comments on our site.

How do we use this information?

We will only use personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing to you directly at any time by contacting us at mma@visiblestrengths.co.

Information you give to us

We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
• to notify you about important changes to our service.

Information we collect about you

We will use this information:

• to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to allow you to participate in interactive features of our service when you choose to do so;
• to improve our website and to ensure that content is presented in the most effective way for you and your device;
• to monitor the usage of the service;
• as part of our efforts to keep our website safe and secure.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your contact details and technical data we collect about you, such as your IP address and the way you browse our website, to form a view of 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 (we call this marketing).

You will receive marketing communications if you have requested information from us, purchased goods or services through us, or provided us with your details when you entered a competition or registered for a promotion, and in each case have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages by following the opt-out links on any marketing message or by contacting us at any time at mma@visiblestrengths.co.

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, warranty registration, product/service experience or other transactions.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any external company for marketing purposes.

Third-party links

Our site may contain links to and content from third-party websites and online services. The fact that we link to a website or display an advertisement or other third-party content or product is not an endorsement, authorisation or representation of our affiliation with any of those third parties, nor is it an endorsement of their privacy or information security policies or practices.

This Privacy Notice applies only to our site, and the privacy policy of the third party governs your interactions with those third-party services. We do not exercise control over third-party websites, products or services. Other websites, products and services may place their cookies or other files on your computer and collect data or solicit Personal Information from you. We encourage you to read the privacy policies and other terms of such third parties before using their services.

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 consistent and compatible with the original purpose. If you would like an explanation about how processing for the new purpose is consistent and compatible with the original purpose, please email us at mma@visiblestrengths.co.

If we need to use your personal data for an unrelated purpose, we will notify you and 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.

How do we share your information?

Legal requirements

Visible Strengths Co. may disclose your personal data in the good faith belief that such action is necessary to:

• comply with any legal obligation;
• prevent or investigate possible wrongdoing in connection with the service;
• protect the personal safety of users of the service or the public;
• enforce or apply our Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of Visible Strengths Co., our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction (under various UK anti-money laundering regulations);
• protect against legal liability.

As a European citizen, under GDPR you have certain individual rights. You acknowledge and agree that from time to time we have the right to share your personal information with:

• any member of our group, which means our subsidiaries and affiliates, as defined in section 1159 of the UK Companies Act 2006;
• third parties, including select business partners, suppliers and sub-contractors, for the performance of any contract we enter into with you.

Service providers

We may employ third-party companies and individuals to facilitate our service (“Service Providers”), to provide the service on our behalf, to perform service-related services, or to assist us in analysing how our service is used. These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our service. Visible Strengths Co. uses Google Analytics and FG Funnels Analytics. Please refer to their respective privacy policies for more information.

How do we store or transfer your information?

Your information, including personal data, may be transferred to — and maintained on — computers outside your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United Kingdom and choose to provide information to us, please note that we transfer the data, including personal data, to the United Kingdom and process it there. Your consent to this Privacy Notice, and submission of such information, represents your agreement to that transfer.

Visible Strengths Co. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice, and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place, including the security of your data and other personal information.

Once we have received your information, we have a data protection regime in place to oversee the effective and secure processing of your personal data. We will use strict procedures and security features to try to prevent unauthorised access. Should any personal data breach occur, we will notify you and any applicable regulator where we are legally required to do so.

Security of data

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website at the transmission stage; any transmission is at your own risk.

Please contact us at mma@visiblestrengths.co if you would like further information about security or data transfer.

How long do we keep your information for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy 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 unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements.

Under UK tax law, we are required to keep basic personal data about our customers (name, address, contact details) for a minimum of 6 years, after which it will be destroyed.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We may use this information indefinitely without further notice to you.

What are your rights?

Under certain circumstances, you have rights under data protection laws to:

• request access to your personal data;
• request correction of your personal data;
• request the erasure of your personal data;
• object to processing of your personal data;
• request restriction of processing your personal data;
• request transfer of your personal data;
• withdraw consent.

Exercising your rights

If you wish to exercise any of your rights set out above, please email us at mma@visiblestrengths.co.

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 several requests. In this case, we will notify you and keep you updated.

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 unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Changes to our Privacy Notice

This Privacy Notice may be updated from time to time. We will notify you of any material changes by posting a new Privacy Notice on our site. Your use of the website and any services following any such notice will signify and constitute your agreement to and acceptance of such revised Privacy Notice.

Contact

If you have any questions about this Privacy Notice, please contact us by email at support@visiblestrengths.co.