1 Privacy Notice
This is the privacy notice of MyProfessionalPassport Ltd. In this document, "we", "our", or "us" refer to MyProfessionalPassport ltd.
We are company number 12291431 registered in England and Wales.
Our registered office is at 123, Bayfield; West Allotment; NE27 0FE; Newcastle upon Tyne.
2 Introduction
This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
2.1 Data Protection
We are registered with the ICO and have appropriate data protection policies in place.
2.2 Data we process
We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:
Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.
Your contact information includes information such as billing address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
Your professional information includes information such as your job description and the name of your employer. Completion of this information is optional but if you do choose to provide it you are consenting to the use of this data in accordance with this privacy notice.
Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from us.
Technical data includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Your profile includes information such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.
We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.
For example, we may aggregate profile data to assess interest in a product or service.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.
2.3 Special personal information
Special personal information is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
It also includes information about criminal convictions and offences.
We do not collect any special personal information about you.
2.4 If you do not provide personal information we need
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
3 The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
3.1 Information we process because we have a contractual obligation with you
When you create an account on our website, buy a service or product from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
• verify your identity for security purposes
• sell products or services to you
• provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
3.2 Information we process with your consent
Through certain actions, when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at contact@mypropass.co.uk. However, if you do so, you may not be able to use our website or our services further.
3.3 Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our business
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage business risk
• protecting your interests where we believe we have a duty to do so
3.4 Information we process that we recive from third parties
In order to carry out some of our services, MPP customers might:
• upload personal information, such as names and email addresses. We use and process this information to provide the Service in accordance with our contract with you or your organisation and this privacy policy.
• Create a Distribution in a number of ways such as, importing Contacts through a CSV or manually.
We do not, under any circumstances, sell your Distribution Lists or use it for any other purpose apart from issuing certificates and creating accounts. If someone on your Distribution List complains or contacts us, we might then contact that person. If we detect abusive or illegal behavior related to your Distribution List, we may share your Distribution List or portions of it with affected ISPs or anti-spam organisations to the extent permitted or required by applicable law.
Our Service is intended for use by our Members. Sometimes we may be requested to upload personal information on behalf of the organisation to asssit with the issue of certificates. As a result, for much of the Personal Information we collect and process through the Service, we act as a processor on behalf of our Members. MyPropass is not responsible for the privacy or security practices of our Members, which may differ from those set forth in this privacy policy. Please check with individual Members about the policies they have in place.
3.5 Information we process because we have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
4 Specific uses of information you provide to us
4.1 Information provided on the understanding that it will be shared with a third party
There are different ways in which you provide information that we may share with a third party:
4.1.1 Posting of information on our website
Our website allows you to post information that could be read, copied, downloaded, or used by other people.
In posting personal information, it is up to you to satisfy yourself about the confidentility of this data and what impact this would have if it was available in the public domain. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future to deliver services or information of new products and services.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at contact@mypropass.co.uk.
4.1.2 Receive notifications from third-parties
Once you have registered on the platform, we will need to share your personal information with relevant third parties in order to provide the service to you. This is to enable third parties to issue notifications for events and experience and to issue you with a certificate.
As described in 3.4, for much of the Personal Information we collect and process through the Service, we act as a processor on behalf of our Members. In such cases, if want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by MyProPass as a processor on behalf of our individual Members, you should contact the relevant Member that is using the Mypropass Service, and refer to their individual separate privacy policies and any associated GDPR compliance requirments.
4.2 Complaints regarding content on our website
Our website is a publishing medium. Anyone may register and then publish information about himself, herself, their business, planned trainings or events.
We do not moderate or control what is posted.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
4.3 Information relating to your method of payment
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of Stripe. That page may be branded to look like a page on our website, but it is not controlled by us.
4.4 Communicating with us
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
4.5 Complaining
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
4.6 Cookies
Please refer to our Cookie Policy for more information about our use of cookies and other similar tracking technologies.
4.7 Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
4.8 Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. Any such information is used in line with 3.4 and 4.1.2.
4.9 Credit reference
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
4.10 Data may be processed outside the European Union
Our websites are hosted in the United Kingdon.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
5 Control over your own information
5.1 Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
5.2 Access to your personal information
At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
To obtain a copy of any information that is not provided on our website you should contact us to make that request.
After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
5.3 Removal of your information
If you wish us to remove personally identifiable information from our website, you should contact us to make your request.
This may limit the service we can provide to you.
5.4 Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
6 Other matters
6.1 Use of site by children
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our website only with consent from a parent or guardian
We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.
6.2 Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
6.3 How you can complain
If you are not happy with our privacy policy or if you have any complaint then you should tell us.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
6.4 Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities;
• to support a claim or defence in court.
6.5 Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our website.
6.6 Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us.
