This policy applies to information held about users of the website and prospective users, guests and prospective guests, partners, contacts and all other persons about whom This Is How holds information. By ‘information,’ we mean personal information about you that we collect, use, share and store.
THIS IS HOW is a joint venture between Nominet and Livity, therefore in this policy, “we,” “us,” and “our” means Livity Limited, both companies registered in England and Wales. Livity’s registered office is Unit 3.02, Piano House, Brighton Terrace, London SW9 8DJ and the company registration number is 04202600 and Nominet’s registered office is Minerva House, Edmund Halley Rd, Oxford OX4 4DQ and the company registration number is 03203859.
“You” means the individual to whom the information relates. For the purposes of the data protection legislation we are the data controller. If you need to contact us about anything in this policy you can reach us by email at [email protected] or by post at Livity’s registered office address.
We are committed to protecting and respecting the privacy of our customers, partners and others with whom we interact. In this policy you will find information about what types of information we hold about you, how and why we collect it, how we use it, and how we keep it secure. This policy also tells you about your rights and how you can exercise them and how the law protects you. Please read it carefully to understand our views and practices regarding your personal data and how we will treat it.
What information we collect about you
We only collect information that we need to carry out our business. What information we collect will depend on our relationship with you. Typically this may include the following:
|Our website users||We will collect information about you in order to provide our services, in particular this includes being able to save the content you’ve selected so you can revisit easily. This data will include your contact information such as email address, telephone number, and other identification information for site login purposes (and if required for our due diligence procedures). If you use our website we may collect information regarding how you interact with the content on our website, which pages you visit etc. We may do this using cookies and where we do so we do so in accordance with our cookies policy.|
|Our suppliers and partners||We will collect contact information in order to enable us to manage our relationship with you, and bank account details (to enable payment for services). In the course of providing services to us we may collect other information from you which is relevant the provision of those services. If we engage you to provide services on behalf of our clients (for example talent or influencers) we may collect and use additional information that we need in order to engage you and to comply with our obligations to our clients, for example your description or photograph, your interests and background or your age. If we have to arrange travel for you we may need to obtain your passport details and information related to your health (for insurance purposes).|
How we collect information about you and how we use it
We will collect this information in a variety of ways in the course of our interactions with you as explained above.
We use your information to:
- save the results of participation in the skills quiz
- provide information about your preferred courses and content most relevant for your interests;
- to communicate with you ongoing about this content;
- comply with legal and regulatory obligations;
- to prevent fraud; and
- for security and to check your identity.
Legal basis for processing
There are a number of different legal grounds for processing personal information. Which one is applicable will depend on precisely how we are processing your information and for what purpose. Most commonly we will be processing your personal information where it is necessary:
- for the performance of contracts to which you are a party or in order to take steps at your request prior to you entering into those contracts; or
- for the purposes of legitimate interests pursued by us provided that those interests are not overridden by your own rights and freedoms in relation to the processing of your personal data; or
- in order to comply with a legal obligation to which we are subject; or
- where it is necessary to rely on your consent, because you have consented to the processing.
In relation to any processing of special categories of personal data (including information regarding your health, religious or political beliefs, ethnic background, sexual life and sexual orientation) we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information.
Where our processing is based on the legitimate interest grounds described above, those legitimate interests include: (i) collecting personal information to provide services to clients; (ii) to make sure you receive updated information on our business activities and opportunities; (iii) to provide the services you have requested; (iv) for our own marketing and research; and (v) to prevent fraud. In most cases if you work for one of our clients or are a young person wanting to join our network we will process your personal data on this basis.
Sharing your information
Except as expressly set out in this policy we will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
The personal information you provide to us may be shared with third party companies, agents, contractors, service providers or affiliated companies if this is necessary to provide you with our services, respond to your inquiries or for any of the purposes described in this policy. This may include:
- our business partners, clients and suppliers;
- our auditors, insurers, lawyers and other professional advisers;
- credit reference agencies;
- law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; or
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
Transferring your information outside Europe
Your personal information may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“) and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers.
When we, or our permitted third parties, transfer your information outside the EEA we will take all reasonable steps to ensure that such transfer is subject to appropriate safeguards, including entering into agreements with the party to whom we transfer such information in accordance with model EC approved model data transfer agreements.
Under EU data protection laws you have a number of rights in relation to your personal data. We respect and honour these rights and will help you to exercise them insofar as we are able. These rights are not absolute – in some cases they will not apply to you, or to the particular use that we are making of your data, and there are exceptions (for example if we have to process the data to comply with our own legal obligations) but if that is the case we will let you know.
At any time, you have the right:
- to request access to or a copy of any personal data which we hold about you;
- to rectification of your personal data, if you consider that the information we are holding is inaccurate;
- to ask us to delete your personal data, if you consider that we do not have the right to hold it;
- to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- to ask us to stop or start sending you marketing messages as described below in the marketing section;
- to restrict processing of your personal data;
- to data portability (moving some of your personal data elsewhere) in certain circumstances;
- to object to your personal data being processed in certain circumstances; and
- to not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change at the following email address: [email protected]
Where you are one of our clients or have otherwise agreed to be contacted for marketing we may use your personal information to send you information about us and our services, including via our newsletter. You can unsubscribe from receiving them at any time, details of how to unsubscribe will be included at the bottom on each electronic mailing we send you. You also have the option of “unsubscribing” from our mailing list at any time thereby disabling any further such e-mail or other communication from being sent to you by emailing [email protected]
We will action any opt out request from you without delay.
How long will we keep your information?
We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.
Where we are permitted to send you direct marketing communications we may retain your contact information necessary for this purpose, for as long as you do not unsubscribe from receiving the same from us. If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our services you should not share that password with anyone else.
Links to other sites
Questions, comments and requests regarding this policy are welcomed and should be addressed to [email protected]
If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Changes to this policy
Any changes we make to our policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our policy.
Last updated: January 2020