Privacy Notice

This privacy notice provides information on how Empresa Psychology collects and processes your personal data when you submit a contact request or engage our services. By continuing to interact with our services, you are consenting to the practices described in this privacy notice. If you disagree with these changes, you may withdraw your consent for Empresa Psychology to hold and process your data at any time.

Effective Date: 20th January 2025

Important information and who we are

Empresa Psychology Ltd is a company registered in England and Wales, who is the controller and responsible for your personal data.

Contact details

Full name of legal entity: Empresa Psychology Ltd

Company registration number: 15876341

Company website: www.empresapsychology.co.uk

Data Protection Officer: Dr Natalie Isaia, Director

Email address: natalieisaia@empresapsychology.co.uk

Postal address: C/O Elliot Woolfe & Rose Limited, Devonshire House, 582 Honeypot Lane, Stanmore, Middlesex, United Kingdom, HA7 1JS

1. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data (e.g. names, usernames, titles, or other unique identifiers) may be collected:
  • During the registration process for training events or newsletters.
  • When completing a contact request form.
  • When setting up user accounts for participants to access training materials or resources online.
• Contact Data (e.g. email addresses, phone numbers, and postal addresses) may be collected:
  • During the registration process for training events or newsletters.
  • When completing a contact request form.
• Profile Data (e.g. usernames, activity on services, or interests in certain types of training) may be collected:
  • From user accounts created for accessing training materials.
  • Through feedback forms, surveys, or preferences shared directly regarding future services or content.
• Social Data (e.g. links to your social media profile) may be collected:
  • We use LinkedIn to engage with a wider audience and to support marketing and sales activities. When you interact with us via LinkedIn, we may store any data that is openly available on your profile.
• Usage Data (e.g. duration of online sessions, pages visited, or features utilized) may be collected:
  • Through tracking software on websites or learning platforms that log interactions.
  • Analytics tools that record what content is most accessed or how long participants spend on particular modules.
• Marketing and Communications Data (e.g. opt-in for newsletters, marketing materials, or promotional offers) may be collected:
  • When consent is provided to receive marketing communications (e.g., through a newsletter signup form).
  • Tracking engagement with marketing emails (e.g., open rates or click-through rates).
• Consent Data (your preferences for marketing and data processing) may be collected:
  • When you update your consent preferences on our website or LinkedIn page.
• Technical Data (e.g. IP addresses, location data, browser types, login data, and system configurations) may be collected:
  • When accessing online training materials or using our website.
  • Through web analytics tools to monitor how users engage with online platforms.
• Behavioural Data and Campaign Data (e.g. how you interact with our website, emails, and other online content) may be collected:
  • When accessing our website
  • When downloading resources
  • When accessing our LinkedIn company page
  • When interacting with our emails and newsletters
• Engagement Data may be collected when:
  • We keep a record of calls, emails and meetings that we have with you to enable us to provide you with the best sales experience and personalised service.
  • We keep a record of where you are in the marketing lifecycle to ensure that marketing materials are personalised appropriately.
• Survey and Feedback Data may be collected:
  • When you have purchased a product and provide feedback or testimonials
  • When you interact with a quiz
  • When you provide customer feedback via email or LinkedIn contact forms
• Financial Data (e.g. payment details, bank account numbers, or invoicing data) may be collected:
  • Through invoicing for services.
• Transaction Data (e.g. details of purchases and records of services provided) may be collected:
  • When booking a service.
  • Through billing and invoicing for services.

2. How we store and handle your data

• Email communication is conducted through Microsoft 365. Microsoft 365 stores its data in the UK and the EU.
• Survey and feedback data will be collected via Microsoft 365 Forms. Providing feedback is optional. When you provide feedback you will be able to opt out of having your feedback used for marketing and promotional purposes.
• Identity, contact, social and profile data will be stored in HubSpot customer relationship management (CRM) system. HubSpot host your data in an EU data centre located in Germany. While your data is stored in the EU, your data may be processed by HubSpot in the USA, and various data Sub-processors and Affiliates. Any integrations used in conjunction with HubSpot (LinkedIn) will be checked to ensure they comply with GDPR requirements. Access will be restricted to authorized personnel, with encryption and password protection applied. Data can be deleted upon request.
• Consultation calls are booked via Zoho Bookings, so contact data will also be stored by Zoho Bookings. Zoho host your data in European data centres located in Amsterdam and Dublin. Marketing, communications and consent data will be stored for marketing purposes only within HubSpot CRM. You will have the option to opt out easily, at which time your marketing data will be deleted.
• Usage data, behavioural data, campaign data, technical data and engagement data will be collected within HubSpot CRM, with secure access control and encryption measures. Anonymization will be applied when possible. Data will only be kept for analysis or improvement purposes.
• Financial data and transaction data will be stored in secure accounting software: Zoho Invoicing. Zoho Invoicing host your data in European data centres located in Amsterdam and Dublin. Sensitive financial data will be encrypted and PCI DSS-compliant if credit card payments are involved. Financial data will only be stored for the necessary period required by law for accounting and tax purposes.

3. How we use your personal data

We will only use your personal data for the purpose for which we collected it which include the following:

• To register you as a new customer.
• To process and deliver your order.
• To manage your relationship with us.
• To enable you to participate in a prize draw, competition or complete a survey.
• To improve our website, products/services, marketing or customer relationships.
• To recommend products or services which may be of interest to you.
• To provide you with updates and information of interest via our newsletter.

The legal bases on which we are relying for data processing are those set out in Article 6.1: (b) (contractual performance); (c) compliance with the Controller's legal obligations; and (f) processing necessary for the Controller's legitimate interest.

4. How we share your personal data

We share your data with the above-named companies (Microsoft 365, HubSpot, Zoho) for the purposes described above, in order to use their services.

We may share relevant data with employees and independent contractors who are engaging in service delivery activities with Empresa Psychology, for example administrative assistants who are supporting with back-office processes and associates who are delivering training. These third parties will be bound by contract and NDA to ensure that they cannot use or share your data for purposes that are not relating to the services that you have engaged Empresa Psychology to provide.

We will not share your personal data with any other third parties, except under the following circumstances:

• In cases of serious harm, we may share your information. If we have reason to believe that there is an immediate risk of serious harm being caused to you or another person. We will always endeavour to first seek your consent before contacting other healthcare providers.
• Compliance with law: we may share information when the law requires us to, i.e. safeguarding, terrorism, drug trafficking and serious crime.

5. International transfers

Empresa Psychology is based solely within the UK; however, data may be transferred outside the UK due to the use of global data centres by companies providing software services (Microsoft 365, Zoho Invoicing and HubSpot). Any software services used by Empresa Psychology will comply with international data transfer regulations and will provide transparency about where data may be transferred and stored in their privacy policies or terms of service. Empresa Psychology ensures wherever possible that your data is stored in UK or EU data processing centres; see Section 2 above for further information relating to specific software services data processing locations.

6. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint at any time to the Information Commissioner's Office, the UK regulator for data protection issues (www.ico.org.uk).

If you are in the European Economic Area (EEA), you have the following rights with respect to information that Empresa Psychology holds about you.

• Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared.
• Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
• Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
• Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
• Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
• Right to complain: You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.