TRLENGO CONSULTING LIMITED understands that the information you trust us with is important to you, and we are committed to protecting and respecting your privacy and maintaining your trust. This Policy explains how, when and why we collect your personal information in the course of providing services to you, under what situations we may disclose your personal information to others, and how we keep it secure. We adhere to the strictest possible code of confidentiality in all our dealings with clients and adopt a “What happens on Tour…stays on Tour” mindset.

SUMMARY

• We only collect personal information about you where it is completely necessary or where you have consented, and we ensure that we only collect information that we need.
• We will not send you marketing material unless you have given us permission to do so.
• We will not sell your personal information to third parties for marketing purposes.
• We use third-party suppliers to help us provide an excellent service to you. Where we share personal information with those suppliers, we have the appropriate contracts or controls in place, which will assess the security of their processing arrangements.
• We will protect your personal information with an appropriate combination of technical and organisational measures.
• You have rights to your information which are detailed in Section 8.
• We retain your data only for as long as is necessary.
• If you have a complaint, please see how to contact us in Section 10.
• If you have any questions on how we process your information, please see how to contact us in Section 12

1. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE USE IT?

We need to collect information about you to offer you our full range of services and to offer you the right products and/or services for your circumstances. This may include personal information about you, information that we collect automatically, and personal information we collect from other sources. We also use this information to:

• Communicate with you (and if you are a Minor looking at our Schools Package for GCSE and A-Level students or a Veteran with PTSD Minor looking at our ‘Beat Your PTSD’ programme, please also see our policy on Minors and Veterans with PTSD in Section 2 below);
• Invite you to our events and presentations;
• 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;
• We use the Device Information to generally improve and optimise our site and services (for example, by generating analytics about how our customers browse and interact with the site, and to assess the success of our marketing and advertising campaigns); this includes advertising and retargeting.

The kinds of personal data about you which we may collect, use, store and transfer are, broadly as follows:

• Personal Information – any information that can identify you as a person i.e. name, date of birth, gender
• Contact Information – including billing address, delivery address, email addresses and telephone numbers
• Financial – including bank account and payment card details
• Transactional – details about payments to/from you and details of services you have purchased from us
• Profile – including username, historical payments, preferences, feedback and survey responses
• Marketing & Communications – your preferences in receiving marketing and communication preferences
• Device Information – information on how users interact with a website i.e. analytics of site activity

If you bought/signed up to one of our products and/or services before 25 March 2018 we will consider you opted-in to marketing communications based on Legitimate Interest. After that date, you will have to opt-in to marketing communications in order for us to keep you informed and process your data to personalise our services to you. By opting-in to marketing communications you will receive

• Free Monthly Newsletter – if you subscribe to it
• Emails relating to our services and products 
• If you sign up with us for any of our products and/or services, you will receive emails relating to those products and/or services on items as varied as product/service information, details of coaches/trainers, invoices, logistics, special offers etc…

Please note that we do not alter our site’s data collection and use practices when we see a ‘Do Not Track’ signal from your browser. Please further note that we do not collect any Special Categories of Personal Data (unless you offer this information) about you (this includes details about your race, ethnicity, religious or political beliefs or sexual orientation), nor do we collect any information about criminal convictions and offences.

2. MINORS AND VETERANS WITH PTSD AND HOW WE HOLD YOUR INFORMATION

We understand the sensitivity involved in holding the details of Minors and Veterans with PTSD and as such, we make sure that all data stored is password protected by our management system. Only our Directors and full-time employees have access to your data on a day-to-day basis.

In the short-term, we store physical copies at our premises of data related to Minors undergoing our student-specific Mindset Package for Schools which is conducted at their place of education and of Veterans with PTSD undergoing our ‘Beat Your PTSD’ programme which is conducted at a place of their choice. This Personal/Contact Information includes Minor’s/Veteran’s names, address, contact details, emergency contact details and bespoke plan to enable us to properly deliver the product/service to the Minor/Veteran in question. Physical copies of this information is destroyed on completion of provision of the product/service.

At your request (as a Parent of a Minor or as a Veteran), we also hold your ‘Financial Data’, to facilitate automatic payments should you wish. This information, like Personal Information, is stored securely, in our password protected managed system and can only be accessed by our Directors and full-time employees.

3. WHY WE USE THE INFORMATION ABOUT YOU

We collect your personal information for several reasons: to provide you with services; administer those services; manage issues; improve the services we offer; and inform you of other services that may interest you. To process your information, we mainly rely on the following legal bases:

Performance of a contract: The use of your information is necessary to perform the contract that you have with us.

Legitimate Interests: We may use your information for our legitimate interests, such as to provide you with the most suitable product/service, website experience, emails or newsletters, or to improve and promote our products and/or services, along with administrative and legal purposes.

Comply with a legal regulatory obligation: We may process your personal data in this way where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent: We may rely on your consent to use your personal information for certain services, to assist, and also for direct marketing purposes. You may withdraw your consent at any time, please contact us using the details in Section 12.

4. INFORMATION THAT WE SHARE

We may have to share your personal information with third-party service providers in certain circumstances but when we do so, the third-party service providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

We do, however, use Google Analytics and you can read more about how Google uses your Personal Information by going to:  https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics by going to: https://tools.google.com/dlpage/gaoptout.

We also share your Personal/Contact Information with our coaches/trainers/mentors working with you, so that they can provide the best service, whether in a 1-2-1 or group/course capacity. Finally, we may share your personal information to comply with applicable laws and regulations, search warrants or other lawful requests for information we receive, or to otherwise protect our rights.

5. MARKETING

We may use your Contact Information to send you information about our products and services which we believe may be of interest to you. We will collect your information for marketing purposes, if you agree, when you browse our website or provide your personal information through our website, by phone, e-mail or our other social media platforms. To stop us contacting you for marketing, email ‘STOP’ to us using the details in Section 12.  

We also have a monthly Newsletter with relevant updates and useful information which you can subscribe to. To unsubscribe from it, simply clicking the link at the bottom of the Newsletter.

6. INFORMATION SECURITY

We work hard to keep your data safe using an appropriate combination of technical and organisational measures to ensure the confidentiality, integrity and availability of your information at all times. If you have a security-related concern, please contact us using the details in Section 12.

7. INFORMATION WE COLLECT THROUGH YOUR USE OF OUR WEBSITE.

When you visit our website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the ‘cookies’ that are installed on your device. We do this to track and improve your user experience of our website, view our services and respond to our advertising, so we can tailor direct marketing and enhance our overall service offering to you. To find out more about our use of ‘cookies’ and related technologies, please read our Cookie Policy on our website.

As you browse the site, we also auto-collect information about the individual web pages/products you view, what websites/search terms referred you to the site, and information about how you interact with the site by using:

• ‘Cookies’ – data files that are placed on your device and often include an anonymous unique identifier.
• ‘Log files’ – track actions occurring on the website, and collect data including your IP address, browser type,

               internet service provider, referring/exit pages, and date/time stamps.

• ‘Web beacons’, ‘Tags’, ‘Pixels’ – electronic files used to record information about how you browse the site.
• ‘Google Analytics’ – tracks user experience.
• Sign up to our Newsletter or Submit an Enquiry – we collect ‘Personal & Contact Information’ which is your name, contact information and your message to us, so that we are able to contact you.

8. ACCESS TO YOUR INFORMATION AND CORRECTION

You have the right to review any data we have on you. We will provide this within 30 days having verified your identity for a small fee of £10-00. Please email us from the website for this if required. You also have a right to contact us if you believe your personal information is incorrect and, if so, we will make the necessary changes. You can also have your data erased (‘the right to be forgotten’) – if so, please email us from the website and we will let you know once data erasure is complete (again for a small fee of £10-00).

9. RETAINING YOUR DATA.

We comply with the various regulatory and legislative requirements as to the information we collect about you. We will also endeavour not to keep your personal data for longer than necessary for us to fulfil our obligations to you, or until you ask us to delete this information. We believe that it is in your own Legitimate Interests that we retain this Personal Information, on the basis that should you wish to continue or re-commence using our products and/or services, we will have historical records and be better prepared to provide you with the expected service. Where it is not possible for us to delete your data, we will ensure the appropriate security and organisational measures are put in place to protect the use of your data.

10. COMPLAINTS

We work hard to ensure that your personal information is treated safely and securely. However, if you have a complaint, please e-mail us from the website. You can also complain to the Information Commissioner’s Office.

11. CHANGES TO OUR PRIVACY POLICY

We review our Privacy Policy from time to time and place any updates on our Website in order to reflect changes to our practices or for other operational, legal or regulatory reasons.

12. CONTACTING US IN RELATION TO PROCESSING OF PERSONAL INFORMATION.

We control the processing of personal data on our systems. If you wish to discuss anything in relation to this Policy or how we handle your personal information, you can reach our Data Protection Officer by contacting us by e-mail from the website. 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. The GDPR includes the following rights to you as individuals: the right to be informed of changes to your data, the right to erase your data, the right to restrict processing of your data, the right to object and the right not to be subjected to automatic decision-making including profiling.