Halthean Privacy Policy

Effective September 2019

Your privacy and trust are important to us. This Statement explains how Halthean Worldwide Limited (“Halthean,” “we”, “us” or “our”) collect, handle, store and protect personal information about you in the context of our services. It also provides information about your rights and about how you can contact us if you have questions about how we handle your information.

Who this statement applies to and what it covers

This Statement applies to individuals who use any of our services or who access our services through any website, application, including mobile application (“app”), product, software or service of ours that hyperlinks to this Statement (we call these our “Services”).

It does not generally apply to individuals whose personal information forms part of the content included within our products.

Halthean provides transformational leadership programs and coaching for businesses and our Services are generally not aimed at children.

Depending on the Service, we may provide additional or different privacy statements or notices for specific interactions you have with us or to highlight how we use your personal information for specific Services. Where we do this, it will be clear which statements apply to which interactions and Services. For example, if you use one of our mobile apps, we provide you a separate notice in relation to a particular data type collected through that app.

Within our Services, there may be links to third-party websites or applications. We are not responsible for the content or privacy compliance of third party websites or applications. You should check those websites or applications for their privacy statements and terms that apply to them.

Children’s Privacy. Our Services are not generally aimed at children. In the limited circumstances where we may collect and use personal information about children, for example to develop an educational resource, we will comply with industry guidelines and applicable laws.

Who we are

Halthean is a UK based company, registered in England and Wales with company number 05134202 and with registered office at 6b Planet Business Centre Planet Place, Killingworth, Newcastle Upon Tyne, Tyne And Wear, UK, NE12 6DY.

For some Services we make decisions on how personal information is used in the context of a Service (Halthean is a controller of personal information in this case), and for other Services we will only use personal information as instructed by our customers (Halthean is a processor of personal information in this case). Below you can find more information on the cases in which Halthean is a controller of personal information and information on how to contact us.

Sources of personal information

We collect personal information about you from your interactions with us and from certain third parties and other sources (such as your employer or the subscriber providing access to our Services or from publicly available sources where permissible).

We obtain personal information from you:

through your interactions with us and our Services, such as, when you purchase or use our Services, register for an event, request information or call us for support (please note that we may record or monitor our telephone calls for compliance and quality assurance purposes)
through your system/device and use of our Services. Our servers, logs and other technologies automatically collect system/device and usage information to help us administer, protect and improve our Services, analyze usage and improve users’ experience
through cookies and similar technologies included on our Services.

We also collect personal information about you from third parties such as:

the person / people arranging for you to access our Services (e.g., your employer or our subscriber) in order to set up a user account
an organisation to which you belong where that organisation provides you access to our Services (such as a library providing you access to certain of our Services)
partners and service providers who work with us in relation to your Service
publicly available sources such as public websites, open government databases or other data in the public domain, to help us maintain data accuracy and provide and enhance the Services.

What types of personal information we collect

The type of personal information we collect depends on how you are interacting with us and which Services you are purchasing or using.

In many cases, you can choose whether or not to provide us with personal information, but if you choose not to, you may not get full functionality from the Services.

The personal information we collect consists of the following:

Name and contact data, such as, first and last name, email address, postal address, phone number, and other similar contact data
Account Credentials, such as, passwords and other security information for authentication and access
User content, such as, communications and files provided by you in relation to your use of the Services
Payment information, such as payment card number (credit or debit card), and the security code associated with your payment instrument, if you make a payment
Device information, such as information about your device, such as IP address, location or provider
Usage information and browsing history, such as information about how you navigate within our Services, your browsing history and which elements of our Services you use the most
Location data, for Services with location-enhanced features. If we need your consent to collect geo-location data, we will collect this separately
Demographic information, such as, your country, and preferred language
CCTV, if you visit our premises.

How we use personal information

This section includes details of the purposes for which we use personal information and also the different legal grounds upon which we process that personal information. We use personal information to provide and improve Services and for other purposes that are in our legitimate interests, as well as for compliance purposes. Further information is set out below.

Some laws require us to explain our lawful reason for processing your personal information. We process personal information about you on the basis that it is:

necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfil that contract (i.e., to provide you with Services)
in our or a third parties’ legitimate interests: details of those legitimate interests are set out in more detail below (e.g., provision of Services that we are contractually obliged by a third party, such as your employer or our subscriber, to deliver to you)
where you give us your consent: we only ask for your consent in relation to specific uses of personal information where we need to and, if we need it, we will collect it separately and make it clear that we are asking for consent
for compliance with a legal obligation (e.g., to respond to a court order or a regulator)

You are welcome to contact us for further information on the legal grounds that we rely on in relation to any specific processing of your personal information.

Legitimate interests for use

We use personal information for a number of legitimate interests, including to provide and improve Services, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below.

to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription and Service information
to administer our relationship with you, our business and our third-party providers (e.g. to send invoices)
to deliver and suggest tailored content such as news, research, reports and business information. We analyse the way you use our Services to make suggestions to you for features or Services that we believe you will also be interested in, and so that we can make our Services more user-friendly
to personalise your experience with our Services. We may retain your browsing and usage information to make your searches within our Services more relevant and use those insights to target advertising to you online on our websites and apps.
We may sometimes share your personal information across our Services so that we can make all of the Services we deliver to you more intuitive (e.g., rather than requiring you to enter the same data many times)
to contact you in relation to, and conduct, surveys or polls you choose to take part in and to analyse the data collected for market research purposes
to display information you choose to post, share, upload or make available in chat rooms, messaging services, and community and event forums (including in community and event profiles) and for related collaboration, peer connection, games and information exchange
to provide any third party, who has made our Services available to you (e.g. your employer or our subscriber), insights about use of the Services
for internal research and development purposes and to improve, test and enhance the features and functions of our Services
to provide you with marketing as permitted by law
to meet our internal and external audit requirements, including our information security obligations (and if your employer or our subscriber provides for your access to our Services, to meet their internal and external audit requirements)
to enforce our terms and conditions
to protect our rights, privacy, safety, networks, systems and property, or those of other persons
for the prevention, detection or investigation of a crime or other breach of law or requirement, loss prevention or fraud
to comply with requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, including where they are outside your country of residence
in order to exercise our rights, and to defend ourselves from claims and to comply with laws and regulations that apply to us or third parties with whom we work
in order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)

Where we rely on legitimate interests as a lawful ground for processing your personal information, we balance those interests against your interests, fundamental rights and freedoms. For more information on how this balancing exercise has been carried out, please contact us at our registered office.

Marketing

We deliver marketing and event communications to you across various platforms such as email, telephone, text messaging, direct mail and online. Where required by law, we will ask you to explicitly opt in to receive marketing from us. If we send you a marketing communication it will include instructions on how to opt out of receiving these communications in the future.

Honoring your marketing preferences is important to us. You have the right to opt out of receiving direct marketing and targeted online advertising.

How to Opt Out of Email Marketing

Where we send marketing emails, we provide unsubscribe options for your use within our emails. To update your email marketing preferences, please visit the applicable email preference center, a link to which will normally be included in emails you receive from us. In addition, you can also use the “Contact Us” feature of a particular Service, discuss with your Halthean contact or contact us at our registered office.

Even if you opt out of receiving marketing communications by email, we may still send you service communications or important transactional information related to your accounts and subscriptions (for purposes such as providing customer support).

Interest-based advertising (IBA)

Interest-based advertising (IBA) allows us to deliver targeted advertising to users of our Services. IBA works by showing you advertisements, or sending you marketing emails, that are based on the type of content you access or read. For example, as you browse our Services, one of the cookies placed on your device will be an advertising cookie so we can better understand what sort of pages or content you are interested in. The information collected about your device enables us to group you with other devices that have shown similar interests. We can then display advertising to categories of users that is based on common interests. For more information about IBA, please visit: http://www.iab.net/public_policy/behavioral-advertisingprinciples.

Opting out of IBA

If you want to opt out of receiving interest-based advertising, it does not mean that you will no longer receive advertising when you are using our Services. It just means that we will not use your personal information for IBA and that any advertising you see will not be customized to you. You can exercise your online advertising choices at http://optout.aboutads.info or by clicking the AdChoices icon in an ad and following the instructions. You may also opt out of receiving interest-based ads from many sites through the Network Advertising Initiative’s (NAI) Opt Out Tool (http://www.networkadvertising.org/choices) and in the EU at http://www.youronlinechoices.com/. If you delete cookies, use a different device, or change web browsers, you may need to opt out again.

Advertising on mobile devices

Mobile devices have an identifier that gives companies the ability to serve targeted ads to a specific mobile device. In many cases, you can turn off mobile device ad tracking or you can reset the advertising identifier at any time within your mobile device privacy settings. Another tool you can use to control advertising on your mobile device is the AppChoices App: http://youradchoices.com/appchoices. You may also choose to turn off location tracking on your mobile device. If you turn off ad tracking or location tracking, we will no longer use information collected from your device’s advertising identifier for the purposes of advertising. You may still see the same number of ads but they may be less relevant because they will not be based on your interests. Where we need your consent to gather information about your location we will obtain this from you.

How we share personal information

We share personal information within the Halthean group, with our business partners and third party service providers, the person providing for your access to our Services (if that is not you) and in accordance with law. Our third-party service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us.

We share your information for the purposes set out in this Statement, with the following categories of recipients:

Halthean group companies
the person providing your access to our Services (e.g. your employer or our subscriber)
business partners with whom we deliver co-branded Services, provide content, or to host events, conferences and seminars
third parties that help us deliver Services or act on our behalf
third parties where we have a duty to or are permitted to disclose your personal information by law (e.g. government agencies, law enforcement, courts and other public authorities)
third parties in order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), in which case we may disclose your personal data to prospective buyers, sellers, advisers or partners and your data may be a transferred asset in a business sale
third parties where reasonably required to protect our rights, users, systems and Services (e.g. legal counsel and information security professionals)
any person you have asked us to share information with (e.g. if you upload information into a public forum it is shared publicly)

International transfers

Halthean uses cloud based software services and your personal information may be stored and processed outside of your home country, including in countries that may not offer the same level of protection for your personal information as your home country. We have measures in place to ensure that when your personal information is transferred internationally, it is subject to appropriate safeguards in accordance with data protection laws. Often, these include contractual safeguards. More information about these safeguards (including copies, where relevant) can be obtained by contacting us at our registered office.

Halthean uses networks, databases, servers and systems around the world. We collaborate with third parties like cloud hosting services, suppliers and technology support located around the world to serve the needs of our business, workforce and customers. We take appropriate steps to ensure that personal information is processed, secured and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within Halthean or to third parties in areas outside of your home country, including to countries that have not been declared adequate for the purposes of data protection by the European Commission.

The areas in which these recipients are located will vary from time to time, but include the United States, Europe, Canada, Asia (including Australia and India), and other countries where Halthean has a presence or uses contractors.

When we transfer personal information internationally, we put in place safeguards in accordance with applicable law (including Articles 44 to 50 of the EU General Data Protection Regulation). If you would like to know more about our data transfer practices and obtain copies of any relevant safeguarding measures, please contact us at our registered office.

How we secure personal information

Halthean takes the security of personal information seriously and we use appropriate technologies and procedures to protect personal information (including administrative, technical and physical safeguards) according to the risk level and the service provided.

Our Chief Executive is responsible for implementing secure data handling practices at Halthean.

Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet the sensitivity of the personal information we handle, our business needs, changes in technology and regulatory requirements. We have implemented appropriate information security controls.

How long we keep personal information

We retain your information in accordance with our enterprise records retention schedule. You can find more information on the criteria used to calculate the retention periods set out below.

Our Chief Executive is responsible for the implementation of policies and rules relating to the retention of personal information. We follow a standard records retention schedule that is based upon a classification scheme consisting of business functions, record classes, and record types.

We calculate retention periods for your personal information in accordance with the following criteria:

the length of time necessary to fulfill the purposes we collected it for
when you or your employer (or other subscriber providing for your access to our Services) cease to use our Services
the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations
any limitation periods within which claims might be made
any retention periods prescribed by law or recommended by regulators, professional bodies or associations
the existence of any relevant proceedings

Your rights

You may have rights under European and other laws to have access to your personal information and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.

We will honor your rights under applicable data protection laws. You have the following rights under European laws, and may have similar rights under the laws of other countries.

Right of subject access: The right to make a written request for details of your personal information and a copy of that personal information
Right to rectification: The right to have inaccurate information about you corrected or removed
Right to erasure (‘right to be forgotten’): The right to have certain personal information about you erased
Right to restriction of processing: The right to request that your personal information is only used for restricted purposes
Right to opt out of marketing: You can manage your marketing preferences by unsubscribe links found in the communications you receive from us or by visiting the applicable preference center
Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests
Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format
Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent

These rights are not absolute and they do not always apply in all cases.

In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.

In order to exercise your rights please contact us.

Cookies and similar technologies

Halthean and our third-party providers set and use cookies and similar technologies to store and manage user preferences, deliver targeted advertising, enable content, and gather analytic and usage data, for example. The use of cookies and other tracking technologies is standard across websites and apps through which information is collected about your online activities across applications, websites, or other services. More information about how we use cookies and similar technologies and how you can control and manage them is below.

What is a cookie?

A cookie is a small text file that is placed on a computer or other device and is used to identify the user or device and to collect information. Cookies are typically assigned to one of four categories, depending on their function and intended purpose: absolutely necessary cookies, performance cookies, functional cookies, and cookies for marketing purposes.

Types of cookies and why we use them

Absolutely necessary cookies: These cookies are essential to enable you to move around a website and use its features. Without these cookies, Services you have asked for, like adding items to an online shopping cart, cannot be provided.

Performance cookies: These cookies collect information about how you use our websites. Information collected includes, for example, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These cookies only collect information in an aggregated format. Performance cookies are used to improve the user-friendliness of a website and enhance your experience.

Functionality cookies: These cookies allow the website to remember choices you make (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of web pages. They may also be used to provide Services you have asked for, such as watching a video or commenting on a blog. These cookies cannot track your browsing activity on other websites.

Targeting and advertising cookies: These cookies track browsing habits and are used to deliver targeted (interest-based) advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They remember that you have visited a website and this information is shared with other organizations, such as advertisers.

Managing cookies

You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Services. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.

We understand that you may want to know more about cookies. Here are some useful resources that provide detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org or www.allaboutcookies.org. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:

We use certain other tracking technologies in addition to cookies:

Local shared objects/Flash cookies: Flash cookies, also known as local shared objects, are designed to support browser content supported by Adobe® Flash. They are usually used to enable ads and video content on websites. Like other cookies, they will store information on your device, some of which will be specific to the Flash-enabled content. Flash cookies can only be deleted within Adobe Flash rather than via your browser. Please refer to the following help page for information on how to manage your privacy settings and deletion of Flash cookies: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.
Web beacons: Our web pages may contain electronic images known as web beacons (also called single-pixel gifs and transparent graphic images) that we use to help deliver cookies on our sites, count users who have visited those sites, deliver Services, and analyze the effectiveness of our promotional campaigns, for example. We may also include web beacons in our marketing email messages or newsletters to determine whether an email is opened or if links are clicked. Web beacons are also used to deliver you interest-based advertising.
Web server & application logs: Our servers automatically collect certain information to help us administer and protect the Services, analyze usage, and improve users’ experience. The information collected includes:
- IP address and browser type
- Device information including Unique Device Identifier (UDID), MAC address, Identifier For Advertisers (IFA), and similar identifiers we or others may assign
- Device operating system and other technical facts
- The city, state, and country from which you access our website
- Pages visited and content viewed, stored, and purchased
- Information or text entered
- Links and buttons clicked
- URLs visited before and after you use our Services

“Do Not Track” Signals

Some browsers transmit Do Not Track (DNT) signals to websites. Due to the lack of a common interpretation of DNT signals throughout the industry, we do not currently alter, change, or respond to DNT requests or signals from these browsers. We continue to monitor industry activity in this area and reassess our DNT practices as necessary.

Connecting via social networks

Some of our Services may include social networking features, such as the Facebook® “Like” button and widgets, “Share” buttons, and interactive mini-programs. Additionally, you may choose to use your own social networking logins from, for example, Facebook or LinkedIn®, to log into some of our Services. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these Services. These Services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the Services and do not participate in social sharing on the Services.

Where to find further privacy information on our products and services

This Statement generally relates to the personal information we collect about users in connection with the Services, where we make decisions about how that personal information is handled (Halthean as a controller). However, you can click on “Learn More” below for more information about how we process personal information that our customers input into our Services and for which Halthean does not make decisions about (Halthean as a processor).

Where we need to give you additional information about how your personal information is used in relation to specific Services we will provide separate or additional privacy notices.

Third parties (such as training providers, venues, employers and accreditation bodies) may enter your personal information into Services we make available to, and host for them on their behalf. They may provide their own privacy notices to you. You should contact them for these notices, and you may also be able to find their privacy notices on their websites.

Use of Publicly Available Data within Our Services

Many organisations rely on the use of publicly available information in order to carry out research or to satisfy their compliance obligations.

To assist them, we make available information obtained from publicly available sources like public websites, open government databases or other data in the public domain (some of which is behind a paywall and some not).

We take privacy seriously and put in place measures designed to ensure that we process personal information in a proportionate way and in compliance with data protection laws.

Where we process non-sensitive personal information within those Services, it is normally processed because it is in our or a third parties’ legitimate interests to do so. In the limited circumstances where we process sensitive personal information, we normally do so where:

necessary in relation to obligations under employment, social security and social protection law
personal information has been manifestly made public by the person to whom it relates
necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity
processing is necessary for reasons of substantial public interest, on the basis of applicable law

We put in place appropriate measures to protect your information where it is transferred internationally, to secure it and to ensure it is retained only for a reasonable period.

If you would like to make further enquiries about how personal information is used within a specific Service, please contact us at our registered office.

How to contact us

If you have any questions, comments, complaints or suggestions in relation to data protection or this Statement, or any other concerns about the way in which we process information about you, please contact us at our registered office.

If you are not satisfied with the response, we encourage you to escalate your query to our Chief Executive by contacting us at our registered office.

Filing a Complaint. If you are not content with how Halthean manages your personal information, you can lodge a complaint with a privacy supervisory authority. In the European Economic Area, the relevant supervisory authority is the one in the country or territory where:

you are resident
you work, or
the alleged infringement took place

A list of National Data Protection Authorities in the European Economic Area can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Updates to this statement

This Statement may be subject to updates. Any material future changes or additions to the processing of personal information as described in this Statement affecting you will be communicated to you through an appropriate channel. For example, we may place a prominent notice on a product site or email you to let you know of an updated Statement.