Last Updated: 22nd May 2018
We are committed to safeguarding the privacy of our website visitors; this policy sets out how we will treat your personal information.
Introduction1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about youThe law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process with your consentThrough certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us firstname.lastname@example.org. However, if you do so, you may not be able to use our website or our services further.
2. Information we process because we have a legal obligationWe are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
3. Complaints regarding content on our websiteWe attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
4. Sending a message to our support teamWhen you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of Prelude Team Ltd.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
5. ComplainingWhen we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
6. Affiliate and business partner informationThis is information given to us by you in your capacity as an affiliate of us or as a business partner.
It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
7. CookiesCookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
7.1. to track how you use our website
7.2. to record whether you have seen specific messages we display on our website
7.3. to keep you signed in our site
7.4. to record your answers to surveys and questionnaires on our site while you complete them
7.5. to record the conversation thread during a live chat with our support team
8. Personal identifiers from your browsing activityRequests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
9. Data may be processed outside the European UnionOur websites are hosted in the UK.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside the European Union:
9.1. the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
9.2. the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union
9.3. we comply with a code of conduct approved by a supervisory authority in the European Union
9.4. we are certified under an approved certification mechanism as provided for in the GDPR
10. Access to your personal information10.1. At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
10.2. To obtain a copy of any information that is not provided on our website you may send us a request at email@example.com.
10.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
11. Removal of your informationIf you wish us to remove personally identifiable information from our website, you may contact us at firstname.lastname@example.org
This may limit the service we can provide to you.
12. Verification of your informationWhen we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
13. Use of site by children13.1. We do not sell products or provide services for purchase by children, nor do we market to children.
13.2. If you are under 18, you may use our website only with consent from a parent or guardian
14. Encryption of data sent between usWe use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
15.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
15.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
16. Retention period for personal dataExcept as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
16.1. to provide you with the services you have requested;
16.2. to comply with other law, including for the period demanded by our tax authorities;
16.3. to support a claim or defence in court.
However, ultimately it is your choice as to whether you wish to use our website.
A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We use both “session” cookies and “persistent” cookies on the website. We will use the session cookies to: keep track of you whilst you navigate the website. We will use the persistent cookies to: enable our website to recognise you when you visit. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer (version 9) you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one. For more information on how to disable cookies, please visit: http://www.aboutcookies.org/Default.aspx?page=1
There are two types of cookie you may encounter when using this website:
First party cookies: these are our own cookies, controlled by us and used to provide information about usage of our site.
Third party cookies: these are cookies found in other companies’ internet tools which we are using to enhance our site, for example Facebook or Twitter have their own cookies, which are controlled by them.
First party cookies
|SESS...||This is used by the content management system, Drupal, to identify who you are. This isn’t usually set unless you are a registered user.|
|Drupal.tableDrag.showWeight||This is used by Drupal to remember your display preferences.|
|Drupal.toolbar.collapsed||This is used by Drupal to remember your display preferences.|
Third party cookies
|__utmb||Less than one day|
|__utmc||End of browsing session|
More information: http://www.google.com/intl/en_uk/policies/privacy/
|disqus_unique, testCookie||Used by the Disqus service to enable commenting on blog posts.|
More information: http://help.disqus.com/customer/portal/articles/466259-privacy-policy
|pid, k, guest_id, _twitter_sess, original_referer, external_referer, js,||Twitter cookies which allow content from Twitter to be shown on website pages and pages to be shared on Twitter.|
More information: https://twitter.com/privacy
|datr, lu, s, locale, c_user, xs||Facebook cookies used to allow sharing of a page on Facebook.|
More information: https://www.facebook.com/about/privacy/
|su_bc||Badge for sharing content on StumbleUpon.|
More information: http://www.stumbleupon.com/privacy
More information: http://pinterest.com/about/privacy/
More information: http://www.google.com/intl/en_uk/policies/privacy/
More information: http://bufferapp.com/privacy
The LinkedIn plugin detects whether you are logged in to LinkedIn, and to do this it may use any of the following cookies:
More information: https://www.linkedin.com/legal/privacy-policy
Google Adsense / The DoubleClick cookie
- Google's use of the DoubleClick cookie enables it and its partners to serve ads to users that are based on their visit to our sites and/or other sites across the Internet.
- Users may opt out of using the DoubleClick cookie for interest-based advertising by visiting Ads Settings.
If you would like more information about how cookies are used for web advertisements, visit http://www.aboutads.info.
(3) Using your personal data
We may use your personal information to:
(a) administer the website;
(b) enable your use of the services available on the website, e.g. the Character Analysis
(c) send you general (non-marketing) commercial communications;
(d) send you email notifications which you have specifically requested;
(e) send to you updates and other marketing communications relating to our business which we think may be of interest to you, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications by contacting email@example.com );
(f) deal with enquiries and complaints made by or about you relating to the website; and
(g) monitor the Character Analysis usage and for improvement of the test. From time to time the data will be used to produce statistics regarding the reliability and validity of the tests. All data will be anonymous in the resulting reports and data will not be used to identify any user.
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.
In addition, we may disclose information about you:
(a) to the extent that we are required to do so by law;
(b) in connection with any legal proceedings or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling:
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information
(f) where you have taken the Character Analysis as part of a consultancy or Management Due Diligence project, the results may be disclosed as part of reporting and feedback to the organisation and/or as part of a group discussion;
(g) from time to time the data will sent to an independent verifier in order for statistics to be produced regarding the reliability and validity of the test and to improve its accuracy. All statistics will be anonymous in the resulting reports and data will not be used to identify any user;
(5) International data transfers
Information which you provide may be transferred to countries which do not have data protection laws equivalent to those in force in the European Economic Areas (EEA). Data submitted via the website is securely stored within the EEA and processed in line with UK data protection legislation. However where data is accessed outside of the EEA this may be considered an International Transfer.
MailChimp, our newsletter distributor, is a US (non-EEA) company and holds Safe Harbor Certification to demonstrate it follows the principles of EEA data protection policy. More information can be found at: http://safeharbor.export.gov/companyinfo.aspx?id=19301
SendGrid, our email distributor for the Character Analysis assessment results, is a US (non-EEA) company and holds Safe Harbor Certification to demonstrate it follows the principles of EEA data protection policy. More information can be found at: http://sendgrid.com/privacy
Disqus, our comment and discussion management system, is a US (non-EEA) company and holds Safe Harbor Certification to demonstrate it follows the principles of EEA data protection policy. More information can be found at: http://help.disqus.com/customer/portal/articles/466259-privacy-policy
In addition, personal information that you submit for publication on the website, (e.g. by posting comments) will be published on the internet and may be available, via the internet, around the world.
You expressly agree to such transfers of personal information.
(6) Security of your personal data
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store the personal information you provide on secure (password- and firewall- protected) servers in a purpose built data centre within the EEA.
We only keep your data as long as reasonably required, under the terms of this agreement, to allow you to use the Prelude Character Analysis, receive any information or notifications you specified and for us to make sure the assessment remains reliable, valid and current.
Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
(7) Policy amendments
(8) Your rights
You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to:
(a) the payment of a fee (currently fixed at £10.00); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address. We may also require verification of your email address).
We may withhold such personal information to the extent permitted by law.
You may instruct us not to process your personal information for marketing purposes, by sending an email to us (firstname.lastname@example.org).In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.
(9) Third party websites
The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.
(10) Updating information
Please let us know if the personal information which we hold about you needs to be corrected or updated.
Prelude Consulting Limited, 7 Park Farm, Black Notley, Essex, CM77 8LQ.
Or by email at: email@example.com
(12) Data controller
The data controller responsible for our website is Prelude Consulting Limited.