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PRIVACY POLICY


INTRODUCTION

Welcome to Human Focus International Limited’s privacy and cookies policy (this
“Privacy Policy”).

We respect your privacy and are committed to protecting your personal data. This
Privacy Policy will inform you as to how we look after your personal data when
you visit Human Focus website through which we sell access to our training
products and the portal through which those training products are accessed
(regardless of where you visit them from) (together the “Website”) and tell you
about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in
this Privacy Policy.


 1. IMPORTANT INFORMATION AND WHO WE ARE
    
    
    Purpose of this Privacy Policy
    This Privacy Policy aims to give you information on how Human Focus
    International Limited collects and processes your personal data through your
    use of the Website, including any data you may provide when you purchase a
    product or access materials through the Website.
    
    The Website is not intended for children and we do not knowingly collect
    data relating to children.
    
    It is important that you read this Privacy Policy together with any other
    privacy policy or fair processing policy we may provide on specific
    occasions when we are collecting or processing personal data about you so
    that you are fully aware of how and why we are using your data. This Privacy
    Policy supplements other notices and privacy policies and is not intended to
    override them.
    
    Controller
    Human Focus International Limited is the controller and responsible for your
    personal data (collectively referred to as “Human Focus“, “we“, “us” or
    “our” in this Privacy Policy) where personal data is collected through the
    Website. We operate the Website to enable individuals to purchase and
    receive industry specific training that will help them perform their jobs
    more safely and effectively.
    
    Processor
    Sometimes, we contract with various employers (“Employer(s)”) to purchase
    this access on behalf of, and to provide access to this training to, their
    employees (“Employee(s)”).
    
    Employers provide Employee personal data to us to enable each Employee to
    access the Website. The Employers are the controllers under applicable laws
    and we act as a processor, processing such personal data only as instructed
    by the Employer. This Privacy Policy applies to Employees only to the extent
    they provide personal data directly to us through the Website and we act as
    controller; for any personal data relating to Employees provided to us
    directly by Employers, the relevant privacy notice for Employees is that
    provided by the relevant Employer from time to time, and we act as processor
    of that personal data only.
    
    Data Protection Office
    We have appointed a data privacy manager who is responsible for overseeing
    questions in relation to this Privacy Policy. If you have any questions
    about this Privacy Policy, including any requests to exercise your legal
    rights, please contact the data privacy manager using the details set out
    below.
    
    Contact details
    If you have any questions about this Privacy Policy or our privacy
    practices, please contact our data privacy manager in the following ways:
    
    Full name of legal entity: Human Focus International Limited
    
    Email address: enquiries@humanfocus.co.uk Postal address: Suite 2, Chapter
    House, 33 London Road, Reigate RH2 9HZ
    
    Telephone number: 01737 647 882
    
    You have the right to make a complaint at any time to the Information
    Commissioner’s Office (ICO), the UK supervisory authority for data
    protection issues (www.ico.org.uk). We would, however, appreciate the chance
    to deal with your concerns before you approach the ICO, so please contact us
    in the first instance.
    
    Changes to this Privacy Policy and your duty to inform us of changes
    We keep this Privacy Policy under regular review. This version was last
    updated on 4th August 2020.  Historic versions can be obtained by contacting
    us.
    
    It is important that the personal data we hold about you is accurate and
    current. Please keep us informed if your personal data changes during your
    relationship with us.
    
    Third-party links
    The Website may include links to third-party websites, plug-ins and
    applications. Clicking on those links or enabling those connections may
    allow third parties to collect or share data about you. We do not control
    these third-party websites and are not responsible for their privacy
    statements. When you leave the Website, we encourage you to read the privacy
    policy of every website you visit.


 2. THE DATA WE COLLECT ABOUT YOU
    
    
    Personal data, or personal information, means any information about an
    individual from which that person can be identified. It does not include
    data where the identity has been removed (anonymous data).
    
    We may collect, use, store and transfer different kinds of personal data
    about you which we have grouped together as follows:

 * * Identity Data includes first name, last name, job 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, your login data,
     browser type and version, time zone setting and location, browser plug-in
     types and versions, operating system and platform, and other technology on
     the devices you use to access the Website.
   * Content Data includes videos you upload to the Website.
   * Profile Data includes username and password, purchases or orders made by
     you, your interests, preferences, feedback and survey responses.
   * Usage Data includes information about how you use the Website, products and
     services and training records generated through the Website.
   * Marketing and Communications Data includes your preferences in receiving
     marketing from us and our third parties and your communication
     preferences.The extent of data collected is dependent on how you or your
     Employer (where relevant) contracts with us.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 this data will not directly or
     indirectly reveal your identity. For example, we may aggregate your Usage
     Data to calculate the percentage of users accessing a Website feature.
     However, 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
     Policy.We do not collect any Special Categories of Personal Data about you
     (this includes details about your race or ethnicity, religious or
     philosophical beliefs, sex life, sexual orientation, 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.If you fail to provide personal dataWhere we need
     to collect personal data by law, or under the terms of a contract we have
     with you or an Employer, and you fail to provide that data when requested,
     we may not be able to perform the contract we have or are trying to enter
     into with you or the Employer (for example, to provide you with access to
     digital content). In this case, we may have to cancel our services with you
     or the Employer but we will notify you or the Employer if this is the case
     at the time.


 3. HOW IS YOUR PERSONAL DATA COLLECTED?
    
    
    We use different methods to collect data from and about you including
    through:

 * * Direct interactions. You may give us your Identity, Contact, Content and
     Financial Data by filling in forms on or uploading videos to the Website or
     by corresponding with us by post, phone, email or otherwise. This includes
     personal data provided when you:
     * purchase our products or services;
     * complete and submit online test materials;
     * create or access an account to access products or services;
     * request marketing to be sent to you; or
     * give us feedback or contact us.
   * Automated technologies or interactions. As you interact with the Website,
     we will automatically collect Technical Data about your equipment, browsing
     actions and patterns. We collect this personal data by using cookies, and
     other similar technologies. We may also receive Technical Data about you if
     you visit other websites employing our cookies. Please see paragraph 4
     below for further details.
   * Third parties or publicly available sources. We often receive personal data
     about you from various third parties and public sources as set out below:
     * Technical Data from the following parties analytics providers such as
       Google based outside the EU
     * Contact, Financial and Transaction Data from providers of technical,
       payment and delivery services such as Stripe based outside the EU.
     * Identity and Contact Data from publicly available sources such as
       Companies House based inside the EU.

How we use your personal data

 We will only use your 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 into or have
     entered into with you or your Employer.
   * Where it is necessary for our legitimate interests (or those of a third
     party) and your interests and fundamental rights do not override those
     interests.
   * Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your
personal data although we will get your consent before sending third party
direct marketing communications to you via email.   You have the right to
withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan
to use your personal data, and which of the legal bases we rely on to do so. We
have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please
contact us if you need details about the specific legal ground we are relying on
to process your personal data where more than one ground has been set out in the
table below.

Purpose/Activity Type of data Lawful basis for processing including basis of
legitimate interest To register you as a new customer or user of Website (a)
Identity
(b) Contact
(c) Profile Performance of a contract with you or your Employer To process and
deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(f) Content (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) To
manage our relationship with you which will include:



(a) Notifying you about changes to our terms or this Privacy Policy
(b) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications (a) Performance of a contract with you or your
Employer
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to
study how customers use our products/services) To administer and protect our
business and the Website (including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical (a) Necessary for our legitimate interests (for running our
business, provision of administration and IT services, network security, to
prevent fraud and in the context of a business reorganisation or group
restructuring exercise)
(b) Necessary to comply with a legal obligation To deliver relevant Website
content and advertisements to you and measure or understand the effectiveness of
the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical Necessary for our legitimate interests (to study how customers use
our products/services, to develop them, to grow our business and to inform our
marketing strategy) To use data analytics to improve the Website,
products/services, marketing, customer relationships and experiences (a)
Technical
(b) Usage Necessary for our legitimate interests (to define types of customers
for our products and services, to keep the Website updated and relevant, to
develop our business and to inform our marketing strategy) To make suggestions
and recommendations to you about goods or services that may be of interest to
you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications Necessary for our legitimate interests (to
develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.

We engage with third party mail platforms such as Mailchimp and similar
businesses to send marketing and advertising materials on our behalf details of
which are set out below.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on 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 from us if you have requested
information from us or purchased training modules from us and you have not opted
out of receiving that marketing.

Third-party marketing

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

Opting out

You can ask us or third parties to stop sending you marketing messages at any
time by following the opt-out links on any marketing message sent to you or by
contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of purchasing training modules or other
transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it
or as instructed by your Employer, unless we reasonably consider that we need to
use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us.

If we need to use your personal data 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 data without your knowledge or
consent, in compliance with the above rules, where this is required or permitted
by law.


 4. COOKIES

The Website uses cookies. Cookies are tiny text files which identify your
computer to our server as a unique user when you visit certain pages on the
Website and they are stored by your Internet browser on your computer’s hard
drive. Cookies can be used to recognise your Internet Protocol address, saving
you time while you are on the Website.

We only use cookies for your convenience in using the Website and not for
obtaining or using any other information about you (for example targeted
advertising). You can set your browser to refuse all or some browser cookies, or
to alert you when websites set or access cookies. If you disable or refuse
cookies, please note that some parts of the Website may become inaccessible or
not function properly.

If you want to find out more information about cookies, Click Here or to find
out about removing them from your browser Click Here

Please note that we collect data from the Website about use of the Website using
a web analysis tool which uses cookies that are (able to be) used to generate
pseudonyms for a user’s profile. This means that cookies (which may be stored on
your computer after you leave the Website) can store information about your
visit.

Name Expiration date Purpose _ga 2 Years Google Analytics Unique User ID _gat 1
minute Used for google analytics throttle request rate. This cookie will be
named as _gat_gtag_ _gid 24 hours Used for google analytics to distinguish users
mailchimp_landing_site 28 Days MailChimp tracking for marketing mailers

The website at https://humanfocus.co.uk/ uses the following cookies:

The e-Learning System (being the portal through which you access our training
modules) uses the following cookies:

Name Expiration date Purpose BadgeLogoPage 60 Days Organisation Branding Logo
WorksIdent 60 Days Person Identifier CustIdent 60 Days Organisation Identifier
SponsorLogoPage 60 Days Sponsor Branding Logo Mfacookie 1 Year Multi Factor
Authentication, this cookie will be named as Mfacookie<userid> _ga 2 Years
Google Analytics Unique User ID _zlcmid 1 Year Zendesk Live Chat ID _gat 1
minute Used for google analytics throttle request rate. This cookie will be
named as _gat_gtag_<property-id> _gid 24 hours Used for google analytics to
distinguish users ASP.NET_SessionId 60 minutes Used for Miscrosoft.NET to
maintain an anonymised user session by the server.


 5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes
set out in the table above:

External Third Parties

 * * Service providers acting as processors based in United Kingdom who provide
     external assessment and moderation services.
   * Payment providers such as Stripe who provide payment services to allow
     users to pay for products through the Website. Your payment will be
     processed by Stripe, who collect, use and process your information,
     including payment information, in accordance with their privacy policies
     (which can be found at https://stripe.com/gb/privacy). Stripe’s services in
     Europe are provided by a Stripe affiliate (Stripe Payments Europe Limited,
     an entity located in Ireland). In providing Stripe Services, Stripe
     Payments Europe Limited may transfer personal data to Stripe, Inc. in the
     United States, in accordance with its own privacy policies.
   * Email platform providers such as Mailchimp who provide services to allow us
     to circulate marketing and advertising correspondence to our customers.
     Correspondence will be sent by Mailchimp or other similar service providers
     on our behalf and they will use and process your information, including
     your email address, in accordance with their privacy policies (which, for
     Mailchimp, can be found at https://mailchimp.com/legal/privacy/). When we
     work with such providers, your personal data may be transferred from the UK
     to the United States, in accordance with the privacy policies of those
     providers.
   * Professional advisers acting as processors or joint controllers including
     lawyers, bankers, auditors and insurers based in the United Kingdom who
     provide consultancy, banking, legal, insurance and accounting services.
   * HM Revenue & Customs, regulators and other authorities acting as processors
     or joint controllers based in the United Kingdom who require reporting of
     processing activities in certain circumstances.
   * Third parties to whom we may choose to sell, transfer or merge parts of our
     business or our assets. Alternatively, we may seek to acquire other
     businesses or merge with them. If a change happens to our business, then
     the new owners may use your personal data in the same way as set out in
     this Privacy Policy.

We require all third parties to respect the security of your personal data and
to treat it in accordance with the law. We do not allow our third-party service
providers to use your personal data for their own purposes and only permit them
to process your personal data for specified purposes and in accordance with our
instructions.


 6. INTERNATIONAL TRANSFERS

We share your personal data with our office in Pakistan for purposes of
providing IT and administration services. This will involve transferring your
data outside the European Economic Area (EEA).

We also share your personal data with Stripe as detailed in section 5 above.
This will involve transferring your data outside of the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring at least one of the following
safeguards is implemented:

 * * We will only transfer your personal data to countries that have been deemed
     to provide an adequate level of protection for personal data by the
     European Commission.
   * Where we use certain service providers, we may use specific contracts
     approved by the European Commission which give personal data the same
     protection it has in Europe.
   * Where we use providers based in the US, we will use appropriate safeguards
     and ensure that the provider is compliant with these safeguards.

Please contact us if you want further information on the specific mechanism used
by us when transferring your personal data out of the EEA.


 7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered
or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions and they
are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.


 8. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, regulatory, tax, accounting or reporting requirements. We
may retain your personal data for a longer period in the event of a complaint or
if we reasonably believe there is a prospect of litigation in respect to our
relationship with you.

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, regulatory, tax, accounting or
other requirements.

By law we have to keep basic information about our customers (including Contact,
Identity, Financial and Transaction Data) for six years after they cease being
customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 9 below
for further information.

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


 9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in
relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold about
you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you
to have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal data
where you have successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however,
that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the time
of your request.

Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your
particular situation which makes you want to object to processing on this ground
as you feel it impacts on your fundamental rights and freedoms. You also have
the right to object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and
freedoms.

Request restriction of processing of your personal data. This enables you to ask
us to suspend the processing of your personal data in the following scenarios:

 * * If you want us to establish the data’s accuracy.
   * Where our use of the data is unlawful but you do not want us to erase it.
   * Where you need us to hold the data even if we no longer require it as you
     need it to establish, exercise or defend legal claims.
   * You have objected to our use of your data but we need to verify whether we
     have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will
provide to you, or a third party you have chosen, your personal data in a
structured, commonly used, machine-readable format. Note that this right only
applies to automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing
carried out before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We will advise
you if this is the case at the time you withdraw your consent.

No fee usually required

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

What we may need from you

We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any
of your other rights). This is a security measure to ensure that personal data
is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to
speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it
could take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you
updated.


 10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and
managing our business to enable us to give you the best service/product and the
best and most secure experience. We make sure we consider and balance any
potential impact on you (both positive and negative) and your rights before we
process your personal data for our legitimate interests. We do not use your
personal data for activities where our interests are overridden by the impact on
you (unless we have your consent or are otherwise required or permitted to by
law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities
by contacting us.

Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is
necessary for compliance with a legal obligation that we are subject to.



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