Privacy Policy

We, Emerald Works Limited ("Emerald") (also trading as "Mind Tools"), are committed to protecting your personal data. This notice explains how we use the personal data we hold including the personal data we collect when you use our websites.

This notice also explains your privacy rights and how the law protects you including how we comply with the General Data Protection Regulation and other legislation that relates to the use of personal data.

It is important that you read this privacy notice together with any other statements or fair processing notices we may provide on specific occasions when we collect or process personal data so that you are fully aware of how and why we are using your data. We also operate cookies on our websites and information about that is provided separately in our Cookies Policy.
 

Data controller

Emerald Works Limited is the data controller and is responsible for the use of your personal data. Our full details are set out below.

Your obligations

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.

If you provide us with personal data about any other person, for example any other individuals within your organisation, then you must ensure that you have their consent to pass those details to us and for us to use those details in accordance with this privacy notice. You should also make sure that you bring this privacy notice to their attention.

Third party links

Our websites may include links to third-party websites, such as our Twitter, Facebook and LinkedIn social media pages. Clicking on those links 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 use of your data. You should read any privacy notices on their websites carefully.

Data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data which has been anonymised such that a person’s identity is removed.

The following information explains the types of personal data which we collect, use, store and transfer. We will only use your personal data as the law allows us to. The categories of personal data that we use are listed below with examples of the data included:

  • Identity and contact data such as names, titles and other identifiers together with address, email address and telephone numbers.
  • Technical data including internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, access times, operating system and platform and other technology on the devices you use to access our websites. This may also include information about how you use and interact with our websites.
  • Profile data such as username, password details, role information and your interests or preferences.
  • Marketing and communications data which includes preferences in receiving marketing from us and your communication preferences.
  • Career data including your CV, career history information and information about you, including references.
  • Financial data such as bank account or card payment details if you make a purchase from us.

How is your personal data collected?

Most of the personal data we hold is provided directly by you, for example by email, over the phone, or by using our websites (some of the technical data which we collect may be collected automatically as you interact with our websites for example via the use of cookies and similar technologies). Sometimes your data is provided by your organisation, for example when they ask us to give you access to our Toolkit.
We may also obtain your data from third parties or publicly available sources, such as marketing database providers.

Reasons for processing

We may process your personal data for our legitimate business purposes (or those of our group companies), such as to:

  • Deliver our products and services;
  • Administer our websites including troubleshooting, data analysis, testing, system maintenance and support so that we can provide, enhance, personalise or otherwise improve our websites and the products and services we offer, and for network security;
  • Better understand how people interact with our websites or products;
  • Improve the effectiveness of promotional campaigns and advertising;
  • Provide you with marketing communications such as our newsletter or other emails about our products and services;
  • Assess and where appropriate, deal with your application, if you express an interest in working for us;
  • Ensure our third-party providers can perform their obligations to us; and
  • Gather your feedback on our products and services.

We always carefully consider your interests and your personal information rights before doing this. If you have any concerns about us processing your personal information for these reasons, you have the right to object.
In other circumstances, such as for certain marketing activities, we will only use your personal data where you have provided your consent for us to do so. You can withdraw your consent at any time.

If you are a consumer, we may process your financial data to administer your payment so that we can provide our services to you. This is necessary for the performance of the contract that will be in place between us.
In addition, we may disclose information about you to the extent that we are required to do so by law or for the purpose of legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention) and where we may otherwise do so in accordance with applicable data protection legislation.

Change or 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. Please also 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.

If you would like further information about how we use personal data and the purpose which we might use it for, please contact us using the contact details set out below.

Research and Development

If you volunteer to participate in market research projects being undertaken by us or our group companies, this will involve us processing your personal data.

Typically, this will be personal data such as your name, email address, age, job role and details regarding your education. Any personal data you share for the purpose of your participation will only be accessible to members of the team who are involved in market research activities. We may also use third parties to support our market research activities, such as hosting online surveys or for technical support. Personal data will only be shared with third parties to the extent necessary to fulfil these contracted services. We do not allow third parties to use your personal data for their own purposes.

Children

We do not knowingly collect personal information relating to children under the age of 16. If you are a parent or guardian of a child under the age of 16 and think that we may have information relating to that child, please contact us. We will ask you to prove your relationship to the child, but if you do so you may (subject to applicable law) request access to and deletion of that child’s personal information.

Disclosures of your personal data

We may disclose and exchange your personal data to affiliated companies within the Emerald group. More information about our group companies can be found on the Emerald group website here: www.emeraldgroup.com.

We may also disclose personal data to:

  • Third parties we use to help deliver our products and services to you, such as payment service providers;
  • Other third parties we use to help us run our business, such as marketing agencies, website hosts, customer relationship and sales platform providers, survey tool providers and website analytics providers;
  • Our professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations; and
  • Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.

In these circumstances your personal data may be transferred outside the UK and the European Economic Union (UK & EEA). Whenever we transfer your personal data outside the UK & EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the safeguards permitted by law is in place.

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.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, disclosed or used or accessed in an unauthorised way. 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 it.

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.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

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 requirements.

In some circumstances, we may anonymise 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please contact us if you would like to exercise any of them. You have the right to:

  • Request access to your personal data (a “subject access request”). This means you can receive a copy of the personal data we hold about you.
  • Request correction of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. You can ask us to remove personal data where there is no good reason for us continuing to process it. You also have this right where you have successfully exercised your right to object to processing, where we may have processed your data unlawfully or where we are required to erase your personal data to comply with law. We may not always be able to comply with your request where there are particular legal reasons.
  • Object to processing of your personal data where we rely on a legitimate interest basis and if the processing impacts on your fundamental rights and freedoms. You can also object to direct marketing. In some cases, we may demonstrate that we have grounds to process your data which override your rights and freedoms.
  • Request restriction of processing. You can ask us to suspend the processing of your personal data: if you want us to establish the data’s accuracy; where our data use is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer need it, to establish, exercise or defend legal claims; or you have objected to use of data but we need to verify whether we have overriding legitimate grounds to use it.
  • Withdraw consent at any time where we rely on consent to process your personal data. This will not affect the lawfulness of processing carried out before you withdraw your consent.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

Contact Us

If you have any questions about this privacy notice, including any requests to exercise your data privacy rights, please contact our customer support team.

Email: support@emerald.com
Telephone: +44 (0) 1274 777700
Address: Emerald Works Limited, Level 1, 50 Frederick Street, Edinburgh, Scotland EH2 1EX.

Representation for Data Subjects in the EU

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/11054432.

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