PRIVACY POLICY NOTICE
All online courses are provided by Mash Communications (UK) Ltd under the brand name “Mind The Gap”, registered business address 82 The Greenhouse, MediaCityUK, Salford, M50 2EQ; registered number: 08018568 (England and Wales)
Mind The Gap is the training academy of Mash Communications (UK) Ltd. The company name will be referred to as “Mind The Gap” herewith.
All intellectual property rights, including copyright in all content and communication belongs to Mind The Gap. By reading the Terms of Use you are agreeing that the content and property of Mind The Gap cannot be copied, reproduced, modified, stored, redistributed or exploited commercially in any way without permission from Mind The Gap.
This privacy policy notice is served by Mash Communications UK and Mind The Gap (MTG) under the website; https://www.mindthegap.academy and all subsequent related online courses powered and hosted on Thinkific.
As a trainer, coach and communications consultant my relationships are always be built on transparency and trust.
Your information remains confidential and NDAs (non-disclosure agreements can be signed if needs be). Confidentiality will always be paramount.
We have written this statement to inform you that we am committed to protecting the privacy and security of your personal information.
In most circumstances your data will be held by Mind The Gap (MTG) as a “Data Controller”.
Mash/Mind The Gap may update this notice at any time.
It is important that you read this notice, together with any other privacy notice I may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why Mash/Mind The Gap is using such information.
This notice applies to:
- All Clients
- All Third Parties and Suppliers with whom we have dealings in the ordinary course of our business including those individuals with whom we send marketing information.
The purpose of this policy is to explain to you how we control, process, handle and protect your personal information through the business and while you browse or use this website and all associated platforms for Mash Communications UK and Mind The Gap. Mind The Gap is the training brand that sits within Mash Communications UK Ltd.
If you do not agree to the following policy you may wish to cease viewing / using this website, and or refrain from submitting your personal data to us.
Policy key definitions:
- "I", "our", "us", or "we" refer to the business, Mash Communications and Mind The Gap
- "you", "the user" refer to the person(s) using this website.
- GDPR means General Data Protection Act.
- PECR means Privacy & Electronic Communications Regulation.
- ICO means Information Commissioner's Office.
- Cookies mean small files stored on a user’s computer or device.
Your individual rights
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
Mind The Gap respects your privacy. We do not collect personally identifiable information about you unless you voluntarily provide it, such as when you provide email contact information to subscribe to the Mind The Gap email list newsletter, send feedback to Mind The Gap, register for one of Mind The Gap’s courses or respond to a survey. If you voluntarily provide your email address or other contact information, we might also use it to inform you of changes to Mind The Gap, to survey you about your use or opinion of Mind The Gap, or to ask for your support. At your request, we will remove your contact information from our files.
We do not make your contact information or any other personally identifiable information available to anyone outside Mind The Gap or its service providers (who use the information only for authorized Mind The Gap purposes) unless we are legally required to do so.
In addition to the above, we collect certain anonymous (non-personally identifiable) information to help us improve the Mind The Gap web site and to evaluate the access and use of Mind The Gap materials and the impact of Mind The Gap on the worldwide educational community:
- We collect information you provide about your use of and satisfaction with Mind The Gap through email you send us, through the Mind The Gap feedback form, and through Mind The Gap surveys, whether or not you voluntarily include your contact information.
- We may use web analysis tools that are built into the Mind The Gap web site to measure and collect anonymous session information.
- We also use “cookies” to improve your Mind The Gap web experience and to collect anonymous information about how you use Mind The Gap. However, cookies are not required for Mind The Gap use. If your browser is configured not to accept cookies, you will still be able to access Mind The Gap and its content.
When we report information about Mind The Gap access, use, and impact, we report aggregate, non-personally identifiable data. Occasionally, we report quoted feedback from users. We do not attribute feedback to specific individuals unless we obtain permission to use that person’s name along with the feedback.
Internet cookies
We may use cookies on this website to provide you with a better user experience. We do this by placing a small text file on your device / computer hard drive to track how you use the website, to record or log whether you have seen particular messages that we display, to keep you logged into the website where applicable, to display relevant adverts or content, referred you to a third party website.
Some cookies are required to enjoy and use the full functionality of this website.
We use a cookie control system which allows you to accept the use of cookies, and control which cookies are saved to your device / computer. Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options.
Data security and protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Fair & Transparent Privacy Explained
We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.
Sponsored links, affiliate tracking & commissions
Our website may contain adverts, sponsored and affiliate links on some pages. These are typically served through our advertising partners; Google Adsense, eBay Partner Network, Amazon Affiliates, or are self-served through our own means. We only use trusted advertising partners who each have high standards of user privacy and security.
However we do not control the actual adverts seen / displayed by our advertising partners. Our ad partners may collect data and use cookies for ad personalisation and measurement. Where ad preferences are requested as 'non-personalised' cookies may still be used for frequency capping, aggregated ad reporting and to combat fraud and abuse.
Clicking on any adverts, sponsored or affiliate links may track your actions by using a cookie saved to your device. Your actions are usually recorded as a referral from our website by this cookie. In most cases we earn a very small commission from the advertiser or advertising partner, at no cost to you, whether you make a purchase on their website or not.
We may use advertising partners in these ways to help generate an income from the website, which allows us to continue our work and provide you with the best overall experience and valued information.
If you have any concerns about this we suggest you do not click on any adverts, sponsored or affiliate links found throughout the website.
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the "Processing of your personal data" above. Any email marketing messages we send are done so through an EMS; email marketing service provider. EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences.
Our EMS provider is MailChimp. We may hold the following information about you within our EMS system;
- Email address
- I.P address
- Subscription time & date
- Your birthdate
- Courses you have been on with Mind The Gap
Data Protection Principles
We will comply with data protection laws including GDPR. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only if necessary for the purposes we have told you about.
- Kept securely.
Why we hold information
It is necessary for MTG to retain data on clients in order for us to fulfil our contractual obligations and hold data for legitimate business needs.
We will only retain data which we reasonably require and for a period which is reasonably necessary.
We will not disclose your data to the third parties unless you have consented for me to do so or I am otherwise required to do either contractually or under another law or enactment.
Personal Information
We collect personal information about clients directly from themselves when they contact MTG via telephone, email, social media or through the website.
Client and business data is stored within a GDPR compliant MailChimp account.
Data on current clients that we are actively working with is also stored in my mobile telephone that is also password encrypted. If our coaching is carried out via Zoom, Skype or a similar communication application, contact data will be stored within the application for the duration that we are actively in a coaching relationship.
We reserve the right to change the systems in which data is stored without notification to another equivalent system but at all times I will ensure the appropriate security of your data and GDPR compliance.
Using Your Information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest (or for official purposes).
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which I will process your personal information are listed below.
- Administering the contract we have entered into with you.
- Dealing with legal disputes involving you.
- To prevent fraud.
- To market other products or services which we offer which may be of interest to you.
- To inform you about updates about my services.
- To administer my business which may include disclosure of client data to the accountant.
- Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
In certain circumstances listed above, we hold your data to market other services to you, send you inspirational blogs, or send you information that we think may interest you. We have a legitimate business interest in retaining your data for this purpose, but you may ‘opt out’ of receiving these types of communication from me.
Change of purpose
We will only use your personal information 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 compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How long will we use your information for?
We will only retain your personal information for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying 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 of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In respect of client data, you can expect us to hold data relating to your instructions for a period of seven years after completion of the last interaction. The reason for this is that the Limitation Act 1980 typically provides that legal proceedings for breach of contract or negligence can be brought up to six years after the events. We therefore have a legitimate business interest in retaining the data should any subsequent legal proceedings ensue.
Given the nature of my services clients often return to me with repeat instructions within weeks, months or years of contacting me in the first instance. The seven-year period referred to above will start from the last contact we have with the client, third party or supplier, to ensure we are able to assist as and when we need to. Should you not contact me for seven years, we will confidentially destroy all data held for you.
Data Privacy Manager
Sarah Knight, owner and founder of Mash and Mind The Gap is appointed as a Data Privacy Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how I handle your personal information, please contact Sarah at sarah@mindthegap.academy.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Resources & further information
- Overview of the GDPR - General Data Protection Regulation
- Data Protection Act 2018
- Privacy and Electronic Communications Regulations 2003
- The Guide to the PECR 2003
- Twitter Privacy Policy
- Facebook Privacy Policy
- Google Privacy Policy
- Linkedin Privacy Policy
- Mailchimp Privacy Policy
- Website Design Carmarthen
Privacy Policy v1 July 2021 - Edited and customised by the Mind The Gap above.