Hemispheres Think Write Limited Privacy Policy

This policy was last updated on 30/01/2019

Hemispheres Think Write Limited is committed to protecting your privacy and ensuring that your personal information is handled in a safe and responsible way. This policy outlines what to expect from Hemispheres Think Write Limited in how we collect and process any data about you. .

Who are we?

Hemispheres Think Write Limited is an educational company that specialises in products and training for school on the teaching of handwriting to children. All products and services are developed by a team of highly qualified Occupational Therapists who collectively have over 91 years of experience to share and bring to teaching of handwriting.
All Hemispheres therapists are registered with the Health and Care Professions Council (HCPC) and actively maintain their registration though a committed to their growth and development.

Our registered address is:

The Granary, Rectory Farm, Broadway Road, Lightwater, Surrey, GU18 5SH

Hemispheres Think Write Limited is the ‘controller’ of any personal data collected about you i.e. we are responsible for deciding how we collect and manage your personal data.
We are registered with the Information Commissioner’s Office under reference A8367138.


If you have any queries about how we gather and use your personal data then you can get in touch with our Data Protection Officer by post at:

Data Protection Officer
Hemispheres Think Write Limited
The Granary,
Rectory Farm,
Broadway Road,
Lightwater,
Surrey, GU18 5SH


Or via email: enquiries@thinkwrite-learning.co.uk
Please put ‘For the attention of the Data Protection Officer’ in the subject line of your email.

Your rights over your data

You have a number of rights over how we gather and use your personal data. You have the rights to:

• be informed about the collection and use of your personal data (e.g. in this privacy notice);
• object to the processing of your data where we rely on our legitimate interests as the legal basis for processing;
• withdraw your consent for us to use your data at any time, where you have opted in to our data processing in the past;
• ask us to change incorrect or incomplete data we hold about you;
• ask us to delete your personal data where it is no longer necessary for us to use it, when you have withdrawn consent, or where we have no lawful basis for keeping it;
• ask us to restrict the personal data we use about you where you have asked for it to be deleted or where you have objected to our use of it;
• ask us to provide you or a third party with some of the personal data we hold about you in a structured, commonly used, electronic form, so it can be easily transferred;
• request access to a copy of your personal data, along with information on what personal data we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request free of charge by contacting our Data Protection Officer in writing at the address above. Please provide us with evidence of your identity;
• not be subject to a decision based solely on automated processing, including profiling;
• make a complaint to us about how we have used your personal data.

To learn more about these rights please see the Information Commissioner’s Office website

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights .

If you would like to exercise any of these rights, please contact our Data Protection Officer by post or email at the address above. We will need to ask you to confirm your identity before we can deliver on a number of these rights.

If you believe that we have not complied with your data protection rights, you can complain to the:

Information Commissioner’s Office (the regulator for privacy / data protection legislation). The Information Commissioner’s Office (ICO) can be contacted at:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Tel: 0303 123 111

How do we collect information from you?

We collect information from you:

• when you visit our website
• when you visit our venue in person
• when you make an enquiry
• when you attend one of our training events
• when you visit us at a conference
• when we visit your establishment or premises
• when you sign up to receive marketing emails
• when you email us

What type of information is collected from you?

You may be asked to submit certain personal information about yourself when you make a request to attend a training day or request a visit. We will collect this information so we can fulfil your appointment request so that we can visit your school or post products to you.

When you place an order or make a booking:

Hemispheres Think Write Limited collects information such as:

• title
• name
• job title
• company name (if relevant)
• telephone number
• e-mail address (used for booking confirmation and post-event feedback emails)
• home or work address
• billing information taken for deposits or holding credit card information
• marketing preferences (whether you have opted-in)


 When you attend an event at or hosted by Hemispheres Think Write Limited:

• marketing responses (where applicable)
• survey responses
• dietary preferences
• current and past booking details

When you access our sites:

There is “Device Information” about your computer hardware and software that is automatically collected by Hemispheres Think Write Limited. This information can include:

• device type (e.g. mobile, computer, laptop, tablet)
• cookies
• operating system
• IP address
• browser type
• browser information (e.g., type, language, and history)
• domain names
• access times
• settings
• referring website addresses
• other data about your device to provide the services as otherwise described in this policy.

Location information:

If you use our website, we may receive your generic location (such as city or neighbourhood).

How is your information used?

We require the information outlined in the previous section to understand your needs and provide you with a better service. Our use of your personal data will always have a lawful basis.

We need to process your data to enter into a contract with you, in order to fulfill your booking requirements, send you service emails (order confirmation, event confirmation, post-event feedback) and to provide you with the service you expect.

We process your data for marketing purposes when we have your consent to receive our promotional emails.

We process your data to meet certain legal obligations which are binding on us. We only do this when strictly necessary e.g. to comply with health and safety laws, to respond to and defend against legal claims.

We have a legitimate interest in processing your personal data in terms of:

• customizing the website based on your interests,
• when evaluating and improving our products and services,
• when taking photos of groups of people in Hemispheres Think Write Limited to use during and after the event,
• retaining details about a previous attendance at your establishment (e.g. training delivered and progress monitoring etc) so that we can refer back to the details if required to assist with subsequent services or products.
• understanding opinions voiced about Hemispheres Think Write Limited online and on social media, and answering questions about Hemispheres Think Write Limited.
• Where we rely on our legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of our customers and have concluded that they are not.

How long do we keep your data?

We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

The following retention periods apply at Hemispheres Think Write Limited:

Type of data and retention period

Notes of conversations (phone or face to face) about potential events and bookings and products required

Discarded as soon as clear the booking is not going to proceed

Emails about potential attendance

If doesn’t proceed, deleted after 6 months

Firm appointments, orders and events

Hemispheres Think Write Limited will retain your information for 3 years – if there has been no activity then your contact details will automatically be deleted

Marketing preferences

Individuals can opt out of marketing at any time by using the ‘unsubscribe’ option or by contacting us by email at enquiries@thinkwrite-learning.co.uk

Who has access to your information?

We will not sell, distribute, or lease your personal information to third parties. Any personal information we request from you will be safeguarded under current legislation.

We will only share your information with companies if necessary to deliver services on our behalf. (For example, to third party service providers such as IT technicians and other relevant event suppliers) and other third parties to provide our sites and fulfil your requests, and as otherwise consented to by you or as permitted by applicable law.

We may need to disclose your information to regulatory bodies, government bodies, or law enforcement agencies. This will be upon request only, and only when required to do so in order to satisfy legal obligations which are binding on us.

Third parties whose content appears on our site may use third-party Cookies, as detailed below. Please refer to ‘Use of Cookies’ for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

You may choose to restrict the collection or use of your personal information at any point. Please refer to the Your Rights you’re your data section of this Privacy Policy for details.

Storing your data and security

Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure your personal data.

The information you provide to us via the website will be stored and processed on servers based in the UK. However, in the course of our operations (including, without limitation, providing you with other services, we may transfer your personal data to our service providers who are based outside of the European Economic Area (EEA).
By submitting your personal data you agree that we may transfer, store and process your information outside of the European Economic Area.
We will require our service providers who process your personal data to keep it safe and secure in accordance with the General Data Protection Regulations 2018.

We make use of the following data processor services not otherwise mentioned in this policy to deliver functionality as part of our services:

Campaign Monitor - https://www.campaignmonitor.com

Facebook - https://www.facebook.com/hemispheresltd/

Google Analytics - https://marketingplatform.google.com/about/analytics

SurveyMonkey - https://www.surveymonkey.co.uk

Web Intelligent - https://www.webintelligent.co.uk

Profiling

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively.

Use of Cookies and Pixels

Like many other websites, we use cookies and server logs to collect information about how our site is used and to help us to personalise your online experience.

A cookie is a very small text file that is placed on your hard disk by a web page server which allows the website to recognise you when you visit. Cookies only collect data about browsing actions and patterns, and do not identify you as an individual.

Pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. Hemispheres Think Write Limited reserves the right to use these pixels in compliance with the policies of the various social media sites.

We use cookies for the following purposes:

Authentication, personalisation and security: cookies help us verify your account and device and determine when you log in, so we can make it easier for you to access the services and provide the appropriate experiences and features. We also use cookies to help prevent fraudulent use of login credentials.

• Performance and Analytics: Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.



• This helps us provide you with information that you find interesting and provides us with insights regarding our web site performance enabling us to tailor it to better meet your requirements.



• Third Parties: Third Party services may use cookies to help you sign into their services from our services. We also may use third-party cookies, such as Google Analytics, to assist with analysing performance. Any third-party cookie usage is governed by the privacy policy of the third party placing the cookie.



• Opting Out: You can set your browser to not accept cookies, but this may limit your ability to use the services.

Our site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Changes to this statement

Hemispheres Think Write Limited will occasionally update this Privacy Policy to reflect company and customer feedback. Hemispheres Think Write Limited encourages you to periodically review this statement to be informed of how Hemispheres Think Write Limited is protecting your information. This policy was last updated in January 2019.

Contact Information

Hemispheres Think Write Limited welcomes your comments regarding this Privacy Policy. If you believe that Hemispheres Think Write Limited has not adhered to this Privacy Policy, please contact Hemispheres Think Write Limited at enquiries@thinkwrite-learning.co.uk We aim to use commercially reasonable efforts to promptly determine and remedy the problem.