Date: 7th October 2019
Fast Lane Consulting and Education Services Limited
Why we process your personal data
We process your personal data primarily on the basis of Legitimate Interest as a business but only if necessary for the purpose we collected it for. We will also process data on the basis of contractual and transactional obligation where necessary. We may process your data for;
- Sales and marketing activities such as calls, emails and other types of communications
- Understanding how you interact with the website and social media
- Account activity such as, email, written and verbal communications and agreements
- Financial activity, such as billing communications
- To perform obligations under a contract with you or a business you may work for
- We will only store your data, for as long as we need it to undertake any of the processes listed above.
By using our Websites or agreeing to do business with us, you consent to the collection and use of information as outlined in within this document.
1. Information We Collect
We collect personal information from you through the use of forms, which may be on paper or on our Websites, such as when you login to access our Services, signup to receive our newsletters, register for information, or make a purchase or commence a course of study.
The information you provide directly to us may include, but is not limited to: (1) name; (2) occupation; (3) email address; (4) mailing address; (5) home telephone number; (6) contact information for your place of work; (7) demographics (e.g. job title, purchasing responsibilities, company information, and professional certification); (8) in certain circumstances, payment information; and/or (9) any additional information that you choose to provide to us. You are not required to provide us with such information, but certain features of our Services may not be accessible or available without the provision of the requested information.
We also collect personal information from you when you communicate with us for any reason, including by email, postal mail or telephone, and when you use our Services.
In addition, we collect certain information automatically about visitors to our Websites as described below.
If you choose to provide us with information you explicitly grant your consent to us using that information as is necessary to provide Services to you.
We are obliged to provide feedback to your employer if they have funded the course & request it, but we do not do this as a matter of course.
2. Information from Affiliates, Social Networking Sites, and Other Non-Affiliated Third Parties
We may collect information about you through any of our affiliates or through non-affiliated third parties. For example, you may be able to access the Service through a social networking account, such as Facebook. If you access the Services through a social networking account, you may allow us to have access to certain information in your social networking account profile. This may include your name, profile picture, gender, location, email address, photos, videos, date of birth, and/or your posts. Social networking sites have their own policies for handling and sharing your information. Please consult the applicable social networking site’s policies for that site’s privacy practices. We have no control over how any third party site uses or discloses the personal information it collects about you.
We may also collect information about you through non-affiliated third parties, including without limitation (a) business partners or (b) customers who provide information regarding their employees or agents (e.g. to enroll employees or agents in our course offerings). We may combine information that we collect from you through the Services with information that we obtain from such third parties and information derived from any other products or services we provide.
3. Third Party Links
You might find links to third party websites on our Websites or within documentation we provide.
If you access other websites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their own privacy policies which you should review.
We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
4. Social Networking
The Website may offer you the opportunity to share or follow information about us (or the Website or our Services) using third party social networking functionality (such as through "share this", "like" or "follow" buttons).
We offer this functionality in order to generate interest in us, the Website and our Services among the members of your social networks, and to permit you to share and follow opinions, news and recommendations about us with your friends. However, you should be aware that sharing personal or non-personal information with a social network may result in that information being collected by the social network provider or result in that information being made publicly-available, including through internet search engines.
Please note that we do not exercise, endorse or control the policies or practices of any third party social network whose functionality you may access through the Website.
5. Ecommunications - registration, dispatch, statistical evaluation procedures, and your rights to opt out.
By opting in to receive our ecommunications you are declaring an agreement with the described procedures. Double opt-in and logging: The registration for our newsletter is done by a double opt-in procedure. This means that you will receive an e-mail after the registration, in which you will be asked to confirm your registration. This confirmation is necessary so that no one can register with other people's e-mail addresses. The subscriptions to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes saving the logon and confirmation time as well as the IP address. The changes to your data stored by the shipping company are also logged.
Login credentials: To subscribe to the newsletter, it is sufficient to enter your e-mail address. As an option, we ask you to enter a name to allow us to address you personally.
Types of communications: By submitting your email address you are consenting to receive the particular piece of information you requested, as well as allowing us to send you appropriate and useful communications. This includes, but is not limited to; invitations to our industry leading events and webinars, our latest assets (whitepapers, guides, reports, infographics, videos and case studies) and promotional offers and services. We would also like to keep you abreast of the charity events and initiatives we partake in.
If you are a customer of Fast Lane, you will also receive training and services updates. These updates will highlight the great new training releases and updates from our vendors and Fast Lane. At any time, you can update your preferences by clicking the link in any emails you receive from us. The link will always be in the footer of the email. You can also stop receiving emails from us using that same link. If you don’t have an email from us to hand and want to update your preferences simply email [email protected] and we will update your preferences as you wish.
Statistical survey and analysis – Our enewsletters contain a "web-beacon", i. e. a pixel-sized file, which is retrieved by the mail order service provider's server when the newsletter is opened. In the course of this retrieval technical information such as the browser, system, IP address and time of retrieval are collected. This information is used for the technical improvement of the services based on the data, target groups, and their reading behaviour based on the retrieval locations (which can be determined by means of the IP address) or access times. Statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons this information can be assigned to the individual newsletter recipients. However, it is neither our intention, nor that of the shipping company, to monitor individual users. The evaluations serve to recognize the reading habits of our users so we are able to better adapt our communication content, or to send different content according to the interests of our users.
The use of the shipping service provider, carrying out statistical surveys and analysis as well as logging of the registration procedure is carried out on the basis of our legitimate interests. We are interested in using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of our users.
Cancellation/Revocation - You can cancel the receipt of our ecommunications at any time, i.e. revoke your consent. At the same time, your consent to the shipping service provider and your statistical analysis expire. A separate revocation of the shipment by the shipping company or the statistical evaluation is unfortunately not possible. A link to unsubscribe from the enewsletter can be found at the end of each communication. If users have only registered for the enewsletter and cancelled this registration, their personal data will be deleted.
6. Storing Your Personal Data
The personal information you provided to us is stored within secure servers. It will be deleted as soon as it is no longer required for its intended purpose and there are no legal obligations to keep it in safekeeping.
Please note that the transmission of information via the internet (including email) is not completely secure and therefore, although we endeavour to protect the personal information you provide to us, we cannot guarantee the security of data sent to us electronically and the transmission of such data is therefore entirely at your own risk.
All Fast Lane email addresses support TLS email encryption, so it is advised that if you are concerned about the contents of any email to use this encryption.
Where we have given you (or where you have chosen) a password so that you can access certain parts of our sites and portals, you are responsible for keeping these passwords confidential.
7. Disclosing Your Information
We may disclose your personal information to any company within our corporate group. This includes, where applicable, our subsidiaries, our holding company and its subsidiaries. We are obliged to provide feedback to your employer if they have funded the course & request it, but we do not do this as a matter of course. We may also disclose your personal information to:
- Any third party we contract to act on our behalf;
- Partners with whom we work to provide Services;
- Any third party that purchases all or substantially all of our assets and business; and to
- Any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
8. Device/Usage Information.
We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For instance, we may collect and analyze information such as (a) IP addresses, geolocation information, unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may also use third-party analytics providers and technologies, including cookies and similar tools and technologies, to assist in collecting this information.
9. Cookies and Other Electronic Technologies.
We may also use local shared objects (also known as “Flash cookies”) to assist in delivering special content, such as video clips or animation. Flash cookies are stored on your device, but they are not managed through your web browser. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services, because they may not function properly. Flash cookies operate differently to browser cookies, and cookie management tools available in a web browser may not affect flash cookies. As we adopt additional technologies, we may also gather additional information through other methods.
We use Google analytics within our websites to monitor how visitors move around the website and how they reached it. This is done so that we can see total (not individual) statistics on which types of content user’s access most frequently. The Google cookies also tell us if you have visited the site before and allow us to track how many individual users the websites have. The Google cookies cannot be used to identify individuals - they are only used for statistical purposes only. You can opt out of Google cookies here https://tools.google.com/dlpage/gaoptout Most internet browsers accept cookies automatically, but you can change the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. These settings will typically be found in the 'options' or 'preferences' menu of your browser. The links below explain how you can control cookies via your browser - remember that if you turn off cookies in your browser then these settings apply to all websites not just this one.
- Internet Explorer: http://support.microsoft.com/kb/278835 (this page links to further information for different versions of IE - the mobile version is at: https://support.microsoft.com/en-gb/help/10635/windows-phone-change-privacy-and-other-browser-settings).
- Chrome: http://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647
- Safari: http://docs.info.apple.com/article.html?path=Safari/5.0/en/9277.html (or http://support.apple.com/kb/HT1677 for mobile versions)
- Firefox: http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies
- Blackberries: http://help.blackberry.com/en/blackberry-q10/10.3.1/help/mwa1334238823957.html
- Android: https://policies.google.com/privacy/key-terms?hl=en#toc-terms-cookie
- Opera: http://www.opera.com/browser/tutorials/security/privacy/
10. Direct Marketing
You may at any time request us to stop using your personal data for direct marketing purposes. If you wish to do this please contact us.
11. IP address lookup
Our Company uses third parties to provide information about visitors to our websites. When you visit our websites we will record your IP address. This address will be matched against public and proprietary IP address databases to provide us with information about your visit. This information may identify the organisation to whom the IP address is registered but not individuals. In some limited cases i.e. single person companies, it may be possible to identify personal data from publicly available ICANN data. 12. Inaccuracies and Corrections We would like to keep your personal data accurate and up-to-date. If you become aware of any errors or inaccuracies please let us know.
We have implemented reasonable administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that information that we collect will never be disclosed in a manner that is inconsistent with this Policy.
13. Internet-based Transfers
Given that the Internet is a global environment, using the Internet to collect and process personal information may involve the transmission of personal information on an international basis. Therefore, by browsing our Websites and communicating electronically with us, you acknowledge our processing of personal information in this way. However, we will endeavour to protect all personal information collected through the Websites in accordance with strict data protection standards.
14. Your Rights
You have the right to:
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
15. Access to information
You also have the right to your personal data (known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
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), although we have the right to charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 may 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.
17. Contacting Us