Millbank Land Academy Limited (“Millbank”) respects your privacy and is committed to ensuring that your Personal Data is used correctly and in accordance with the highest standards of Data Protection Law.
This Policy covers the Millbank Land Academy website, www.millbanklandacademy.co.uk, and is applicable worldwide. By using the Millbank website, products and services on or after May 25th 2018 you consent and agree to this Policy.
PURPOSE OF THIS PRIVACY NOTICE
The purpose of this privacy notice is to give you information on how Millbank collects and processes your Personal Data through your use of this website, including any data you may provide through this website when you register to attend our events and/or purchase our products.
As used in this Policy, ”Personal Data“ means any information that can be used to individually identify a person, and may include, but is not limited to, name, phone number, email address, postal or other physical address, credit or debit card number, title, and other personally identifiable information. It does not include data where the identity has been removed (anonymous data).
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
If you have any questions, please contact us using the information set forth in the “Contact Us” section below.
Millbank Land Academy Limited and its associated Millbank Group companies (collectively referred to as “Millbank”, “we”, “us” or “our” in this privacy notice) will be the controller of your Personal Data that is provided, collected and/or processed pursuant to this Policy (except where otherwise expressly stated below) and therefore responsible for your Personal Data.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the Personal Data we hold about you is accurate and current. We will update the information we hold on you as and when you provide it to us during our communications with you. However, whenever possible, you should advise us if information we hold about you needs updating or is no longer accurate.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
TYPES OF PERSONAL DATA COLLECTED
We may collect, use, store and transfer different kinds of Personal Data about you when you visit our websites, contact us and use or otherwise interact with our Products. We have grouped these together follows:
- Identity Data includes first name, last name, title, date of birth and gender.
- Contact Data includes home address, billing address (which may be a business address), delivery address, email address and telephone numbers.
- Transaction Data includes details about bookings, payments to and from you, special requests and other details of products and services you have purchased or requested from us.
- Financial Data includes bank account and payment card details.
- Health Data includes information about health requirements and allergies pertinent to events
- Technical Data includes internet protocol (IP) address, browser type and version, device type, 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 our website.
- Profile Data includes your purchases or orders made by you, your interests, preferences, feedback and survey responses, Facebook profile information (when you connect with our Facebook pages) and information shared in discussion groups or forums.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details 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). Nor do we collect any information about criminal convictions and offences.
HOW PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including through:
- Direct interactions. As you engage with our business, you may give us your Identity, Contact, Health and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
- Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources
- Analytics. Data from third party providers, such as Google.
Millbank and our third party service providers automatically collect some information about you when you use our Products, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyse trends in the aggregate and administer the website and/or Products.
Cookies and Tracking Technologies
If you fail to provide Personal Data
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 the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW WE USE YOUR PERSONAL DATA
We collect and use your Personal Data as a customer for the purpose of dealing with your bookings, purchases and requests, tailoring our services to your requirements, providing you with information about the products and services we offer and improving our service to you.
We will use your Personal Data only in accordance with our Policy and we will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of am agreement with you) and our “legitimate interests” or the legitimate interest of others such as:
- To process your orders and deliver our products and services
- To provide you with support and assistance for our Products
- To generate reports based on information collected
- To develop new and improved products and services
- To respond to your queries, problems and complaints
- To comply with our legal and regulatory obligations
- To keep you informed about relevant products, special offers and market news
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can choose whether to provide Personal Data to Millbank, but note that you may be unable to access certain options, offers, and services if they require Personal Data that you have not provided.
You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this Policy.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase or other transactions.
CHANGE OF PURPOSE
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please view the Contact details at the top of this document.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
SHARING PERSONAL DATA
- Millbank companies
We share Personal Data within Millbank Land Academy Ltd, Millbank Group and its affiliated companies,
- Third party service providers
We share Personal Data with third party service providers for purposes of data processing or storage.
We also share Personal Data with business partners, service vendors and/or authorized third-party agents or contractors in order to provide requested Products or transactions, including processing orders, processing credit card transactions, hosting websites, hosting event and course registration and providing customer support. We provide these third parties with Personal Data to complete/utilize the requested Product or transaction.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
- Public authorities
We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Millbank’s terms of service, or as otherwise required by law.
As required by law, we may respond to court orders or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.
- Other third parties
We will not sell your Personal Data to third parties for marketing purposes unless you have granted us permission to do so.
We may engage with third parties whom we choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy notice.
Moreover, if we were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this Policy.
SHARING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
The Personal Data that we collect from you may be transferred to, and stored at, destinations both in and outside the European Economic Area (“EEA”).
Where processed outside the EEA, we take appropriate steps to ensure your Personal Data still receives a level of protection that is consistent with European data protection standards. For example, we only share your Personal Data outside the EEA if the third party receiving your Personal Data has signed up to an EU approved data sharing mechanism such as the EU-US Privacy Shield scheme.
PROTECTING YOUR PERSONAL DATA
We treat the information that you provide to us as confidential information and we are committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. When we transfer credit card information over the Internet, we protect it using Secure Sockets Layer (SSL) encryption technology.
Whilst we take all reasonable steps to protect your personal information, data transmission over the Internet cannot be entirely secure. We therefore cannot guarantee the security of the information you disclose online and the use of our services is at your own risk. We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
KEEPING YOUR PERSONAL DATA
Whenever we collect or process your Personal Data, we will only keep it for the purpose for which it was collected and in accordance with our legal and regulatory obligations. In most cases, our retention period for your Personal Data will come to an end six years after the end of your relationship with us.
At the end of the retention period, your Personal Data will either be anonymised (so that it can only be used in a non-identifiable way for statistical analysis, business planning) or deleted completely.
YOUR DATA PROTECTION RIGHTS
You have a number of rights under Data Protection Law which, in certain circumstances, you may be able to exercise in relation to the Personal Data we process about you. This includes:
Right to Access: You have a right to receive a copy of the Personal Data we hold about you. This is commonly known as a Data Subject Access Request.
Right to Data Portability: You have a right to receive certain information you have provided to us in a ‘machine-readable’ format and/or request that we transmit it to a third party.
Right to Erasure: You have a right to request that we erase your Personal Data. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to Object: In cases where we are processing your Personal Data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your Personal Data.
Right to Lodge a Complaint: You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Please see the “Contact Us” section of this Policy.
Right to Rectification: Where your Personal Data is inaccurate, out-of-date or incomplete, you have the right to request an amendment to it.
Right to Withdraw Consent: Where you have given us your consent to process your Personal Data, you have the right to change your mind at any time and withdraw that consent.
If you wish to exercise any of these rights, please get in touch by using the details in the “Contact” section below. Please note that, in some circumstances, we may not be able to fully comply with your requests.
We will ask you to verify your identity before proceeding with any request you make. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.
We aim to respond to all legitimate requests within one month, although it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
You can also contact us by writing to this address:
Millbank land Academy Ltd
18-24 Turnham Green Terrace
London W4 1QP
Effective Date: 25th May 2018
Last Modified: 25th May 2018