Current Version: EX2 - Cancellation / Postponement Policy V1 – 26.04.18
Current Version: PEX2G - Confidentiality, and General Data Protection - V3 18.08.18
Last Updated: July 9, 2018
Excellence Squared Group Ltd is committed to responsible handling and protection of your personal data.
The following statement applies to all of Excellence Squared Group Ltd and its subsidiaries, this includes Assessment Services Ltd.
We have created this statement to provide you with clear and understandable information regarding our privacy practices when you are accessing or using our websites (all websites hosted by either Excellence Squared Group Ltd, or its subsidiaries) so that you can make informed choices about the use of your personal data collected by Excellence Squared Group Ltd.
When accessing other services or applications through our websites, please read the specific privacy conditions which may apply to them.
Excellence Squared Group Ltd reserves the right to update this statement from time to time by publishing a new version online. This statement was last updated in May 2018.
WHAT PERSONAL DATA DO WE COLLECT and how?
Excellence Squared Group Ltd collects personal data that you provide to us directly when you request information about our services through our subsidiary organisations; subscribe to our website’s services, email notifications and/or newsletters; make an enquiry through our different enquiry forms and telephone; or carry out a transaction or place an order through our website by completing our booking forms or registering to an event. This may include:
- Identification and contact data such as name, surname, job title, phone number, email, address and country
- Financial and transactional data such as credit card details
- Any information that you voluntarily share with us such as feedback, opinions or information provided via any of our helplines
Excellence Squared Group Ltd also collects personal data automatically when you visit our websites. This may include:
- Device information such as IP address, referring website, pages your device visited and the time that your device visited our website
- Internet log information and details, collected through our third parties such as Google Analytics, that does not specifically identify you
- Information collected by cookies (for further information please see the Privacy and Cookies Policy).
Excellence Squared Group Ltd may also collect your personal data through our subsidiaries’ Stakeholders, Subcontractors and Delivery Partners such as Education Skills Funding Agency.
WHY DO WE HOLD PERSONAL DATA?
Excellence Squared Group Ltd (and subsidiaries) will use your personal data for the following different purposes:
- To improve our websites with the objective of ensuring that content is presented in the most effective manner for you and for your device
- To send email and communicate with you via email regarding our services and events which may be of interest to you if this is in accordance with your marketing preferences
- To analyse your use of our website for trend monitoring and promotional purposes
- To respond to enquiries and comments and provide you with support via communication channels, such as NetSuite, Online Self-Assessment App, websites
- To keep our website safe and secure and comply with our legal requirements and obligations
- To perform or finalize any transaction or order which you have placed with Excellence Squared Group Ltd (subsidiaries)
- To set up and manage your user account
- To share it with Excellence Squared Group Ltd subsidiaries so that they may offer you their products or services
- For any other new purpose for which we notify you before collecting any personal data
HOW LONG DO WE KEEP PERSONAL DATA?
Excellence Squared Group Ltd (and subsidiaries) will retain your personal data for the period of time that is necessary to fulfil the original purposes for which it has been collected. Please keep in mind that in certain cases a longer retention period may be required or permitted by law or to allow Excellence Squared Group Ltd (and subsidiaries) to pursue its business interests, conduct audits, comply with our legal obligations, enforce our agreements or resolve any dispute.
We will keep your personal data while your account is active or for as long as needed to provide you with our products or services to you to enable us to operate our business.
Subject to a legal, contractual, or similar obligation we will be required to retain your data as part of mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of contract or litigation.
If you contacted us requesting information about our products and/or services but did not proceed with any purchase or have any contractual obligation, we will hold your personal data for minimum of 12 months subject to any on-going communication or attendance to an event.
WHO OWNS AND CONTROLS THE PERSONAL DATA?
We are committed to ensuring that you can exercise your right of access and you can control your data.
Any personal data that is held by Excellence Squared Group Ltd on its ERP database, Netsuite is owned and controlled by Excellence Squared Group Ltd.
If you have registered for an account on either our online Self-Assessment App, ownCloud, iagonline.com, or www.visitheritage.co.uk and/or its local equivalents, you may directly and autonomously access your online profile and other personal details and update, amend, if legally possible, add or delete the data about yourself by logging into the applicable website or service with your account credentials.
Otherwise, and in accordance with our internal procedures, we will respond to the following requests as described below by contacting us in writing to firstname.lastname@example.org.
- Access to personal information: you have the right to request what personal data we hold about you subject to our right to identity verification. If you request a copy of your data, we may charge you a fee, except where this is not permissible under local law.
- Correction and deletion: in some jurisdictions, including the EU (according to data protection laws for data subjects in the EU), you have the right to correct or amend your personal data if it is inaccurate or needs to be updated. You may also have the right to request the deletion of your personal information, however this may not be always possible due to legal requirements and other obligations to keep such data. If we are asked to delete your data, we may keep some minimal information about you to be able to demonstrate that we have fulfilled our obligations.
- Filing a complaint: Any complaints about our adherence to the practices described in this Statement shall be addressed as described here. In some jurisdictions, including according to data protection laws in the EU for complaints issued from subjects in the EU, you have the right to lodge a formal complaint with a data protection authority.
- Communication preferences: Excellence Squared Group Ltd may send you regular communications about our services and products to enhance your customer experience with us, via different channels such as email update, phone, postal mailings and social networks.
You can exercise your right to prevent communications to you by unsubscribing of the Customer Communications and Updates we send to you. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again. The unsubscribing of our Customer Communications and Updates does however mean you will not be kept up to date with our service developments. Please note that even if you opt out from receiving Customer Communications and Updates, you might still receive administrative communications from us, such as progress updates for our products or services, order confirmations, notifications about your account activities, and other important notices.
SAFEGUARDING YOUR PERSONAL DATA
Excellence Squared Group Ltd follows strict security procedures in the storage and disclosure of information which you have given us in order to prevent unauthorized access, loss or destruction of your personal data. These may include:
- Physical safeguards, with locked doors and file cabinets, controlled access to our facilities and secure destruction of media containing your personal data
- Technology safeguards, like the use of anti-virus and endpoint protection software, and monitoring of our systems to ensure that they comply with our security policies
- Organisational safeguards, like training and awareness programs on security and privacy, to make sure employees understand the importance and means by which they must protect your personal data
Excellence Squared Group Ltd does not seek to collect sensitive personal data (also known as special categories of data). If we do so we will always collect the data in accordance with local data privacy requirements. If you choose to provide us with unsolicited sensitive personal data, you will be asked to consent to our processing of such data on a case-by-case basis.