PRIVACY AND COOKIES POLICY
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.investin.org or www.investineducation.co.uk (our Site) you acknowledge and are accepting and consenting to the practices described in this policy.
InvestIN, is the trading name for InvestIN Education Ltd, a company registered in England and Wales. Our company registration number is 08179629 and our registered office is at 85 Great Portland Street, First Floor, London, W1W 7LT.
InvestIN Education Ltd (“We, Us or Our”) is the controller and responsible for your personal data.
If you have any questions about this policy or our privacy practices, please contact our data privacy manager in the following ways:
By post to: InvestIN, 85 Great Portland Street, First Floor, London, W1W 7LT By email to: email@example.com By phone: +44 (0) 203 488 5089
You have the right to make a complaint at any time to 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.
Changes To this Policy and 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 during your relationship with us.
Third Party Links
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
If you register for an InvestIN programme we collect some Special Categories of Personal Data about you (this includes details about your race or ethnicity,) for the purposes of enabling us to provide you with information about targeted opportunities (such as work experience) and to assist us with meeting any requirements you may have when attending the programme (for example, if you have any dietary requirements).
We are mindful that some of our courses are attended by minors who, by law, cannot consent to the processing of their personal data if they are under the age of 13.
Any booking made for any child under the age of 18 must be submitted by either a parent who holds parental responsibility for the child, or by a school/institution which they attend who has the necessary authority to provide the information on the child's behalf.
By submitting a booking you are specifically providing consent to our processing of the child’s personal data.
Photography and Videoing at Events.
From time to time we will take photos and videos of students during their time at an event. The purpose of this is to assist us with training and refreshing the programme content, as well as for use in promotional material. In addition, some recorded programme content will be made available to other students who could not attend on the day for personal reasons.
Our lawful basis for processing this information will be either consent or legitimate interests, depending on the processing activity.
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, service or event you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We may also collect personal data from various third parties and public sources.
Information From Other Sources
This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this Site. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Purposes For Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process a registration request and bookings, manage payments, fees and charges and collect and recover money owed to us
Marketing and Communications
Necessary for our legitimate interests to take and make payments.
To manage our relationship with you which will include:
Asking you to leave a review or take a survey
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how users use our Site)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To make suggestions and recommendations to you about offers or services that may be of interest to you
Necessary for our legitimate interests (to define types of customers for our products and our services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To enrol you into our alumni platform, InvestIN Connect and provide you with information about targeted opportunities which may be of interest to you, for example in relation to relevant work experience
Date of birth
Consent (and explicit consent for special category data, marked with *)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
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.
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
Any third parties in the UK and the EU are subject to the provisions of the GDPR or similar regulations in relation to your personal data. 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.
The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom and European Economic Area ("EEA"). It may also be processed by staff operating outside the UK or EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
The law restricts data transfers to countries outside the UK or EEA in order to ensure that the level of data protection afforded to individuals is not undermined. We transfer personal data originating in one country across borders when we transmit, send, view or access that data in or to a different country.
We will only transfer Personal Data outside the UK or EEA if one of the following conditions applies:
In particular, we currently engage the Rocket Science Group LLC (trading as “MailChimp”), a US company, to maintain our online email databases and to allow us to keep in contract with you, primarily by sending emails. MailChimp is committed to protecting all personal information received from us and we have entered into appropriate contractual arrangements with MailChimp in order to ensure the security and proper use of your data but if you have any questions about this, please contact the data privacy manager directly. A link to MailChimp’s own privacy notice can be found here: https://mailchimp.com/legal/privacy/
Please contact our data privacy manager if you want further information about when we may transfer your information outside the UK or EEA and the specific mechanisms used by us to ensure the protection of your personal data.
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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: – “Your Legal Rights” below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include your right to:
Please refer to the Glossary below for more detailed information on your rights.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
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 could refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 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 to speed up our response.
Time to Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.
Your Legal Rights
You have the right to:
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It is used to determine if HubSpot should increment the session number and timestamps in the “__hstc” cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.
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This cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session.
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This cookie is passed to HubSpot on form submission and used when deduplicating contacts.
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If we chat with a visitor who later returns to our site in the same cookied browser, the chatflows tool will load their conversation history. The cookie is controlled by the settings in chatflow.
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This cookie is set to let Hotjar know whether that visitor is included in the data sampling defined by our site's page view or daily session limit.
This cookie is set by HotJar when a website user first lands on a page with the HotJar script. It is used to persist the HotJar User ID, unique to that site on the browser. This ensures that behaviour in subsequent visits to the same site will be attributed to the same user ID.
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These cookies are used by Shopify in connection with its analytics suite.
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Please note that the third parties listed above may also use these cookies for their own purposes over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.
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