Who we are
DEFINITIONS AND INTERPRETATION
Cookies: a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in clause 29 below (Cookies);
Personal Data: any information about you from which you can be identified. This does not include data where your identity has been removed (anonymous data);
User, you or your: any third party that accesses the Website and is not either (i) employed by WA Management and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to WA Management and accessing the Website in connection with the provision of such services;
WA Management, we, our or us: Whittaker Associates (Worcestershire) Limited a company incorporated in England and Wales with registered number 04456236 whose registered office is at 13 Dormer Place, Royal Leamington Spa, CV32 5AA ; and
Website: the website that you are currently using, https://www.wamanagement.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
3. WA Management is the “data controller”, the owner of this Website and responsible for your Personal Data. This means that WA Management determines the purposes for which, and the manner in which, your Personal Data is processed.
IF YOU FAIL TO PROVIDE PERSONAL DATA
4. 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 Personal 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 products 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.
5. We may collect, store, transfer and otherwise process the following Data, which includes Personal Data, from you:
5.3. contact Information such as email addresses and telephone numbers;
5.4. payment data;
5.5. web browser type and version (automatically collected);
5.6. operating system (automatically collected); and
5.7. Website activity data such as pages visited (automatically collected).
HOW WE COLLECT DATA
6. We collect Personal Data in the following ways:
6.1. data is given to us by you; and
6.2. data is collected automatically.
DATA THAT IS GIVEN TO US BY YOU
7. WA Management will collect your Personal Data in a number of ways:
7.1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
7.2. when you register with us and set up an account to receive our products/services;
7.3. when you use our products/services;
7.4. when you make payments to us, through this Website or otherwise; and
7.5. when you elect to receive marketing communications from us.
DATA THAT IS COLLECTED AUTOMATICALLY
8. To the extent that you access the Website, we will collect your Personal Data automatically, for example:
8.1. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
8.2. we will collect your Personal Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see clause 29 below.
OUR USE OF DATA
9. 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:
9.1. where we need to perform the contract we are about to enter into or have entered into with you;
9.2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
9.3. where we need to comply with a legal obligation.
10. Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.
11. Any or all of the above Personal Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Personal Data may be used by us for the following reasons:
11.1 to register you as a new client of ours and set up an account in your name, on the lawful basis for performing a contract with you;
11.2. to process and deliver your order for online training courses (including managing and processing payments), on the lawful bases of performance of a contract with you and it being necessary for our legitimate interests (to recover debts due to us);
11.3. to manage our relationship with you (including sending you communications (via email) specific to your course, such as to remind you of a course renewal, on the lawful bases of performance of a contract with you, it being necessary to comply with a legal obligation and it being necessary for our legitimate interests (to provide our customers with a high quality tailored service);
11.4. to administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), on the lawful bases of it being necessary to comply with a legal obligation and it being 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);
11.5. to use data analytics to improve our Website, products/services, marketing, customer relationships and experiences, on the lawful basis of it being necessary for our legitimate interests (to define types of customers for our products/services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy); or
11.6. to deliver relevant Website content and advertisements for marketing purposes and measure or understand the effectiveness of the marketing we deliver to you, on the lawful bases of your consent and it being necessary for our legitimate interests (to develop our products/services and grow our business).
WHO WE SHARE DATA WITH
12. We may share your Personal Data with the following groups of people for the following reasons:
12.1. third party service providers who provide services to us which require the processing of Personal Data – for example, our Website developer who may process your Personal Data in managing and hosting the Website on our behalf and, if you purchase a training course via the Website, your Personal Data will be shared with startmycourse.com to enable them to email you access to the course;
12.2. third party payment providers who process payments made over the Website – for example, if you purchase a training course via the Website, your Personal Data will be shared with PayPal in order for the payment transaction to proceed;
13. Below is a list of the companies that we share your Personal Data with in some capacity.
13.1. Oxeye Daisy stores User login and purchased securely. Personal Data collected here may be used to contact you regarding your courses or with marketing material where permission was given.
13.2. Trace On Paper Marketing are our marketing subcontractors. Personal Data may be shared to improve marketing and they may access details from Google Analytics
13.3. Google Analytics Non-Specific browsing data will be shared to google for marketing purposes
13.4. Microsoft OneDrive non-specific information about your visit to and activity on our Website may be stored on our secure One Drive servers for the purpose of reports to improve site usage.
13.5. Riskwize are the developers of the online courses and need access to your details to send you the access to the courses purchased. They receive no further data than this.
13.6. Facebook Data is shared via cookies for remarketing purposes. No personal details are shared outside of this.
13.7. Hotjar produces heatmaps and behaviour analytics information which tells us where visitors to our Website have moved their cursor.
14. Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. However, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data (namely, Ireland).
KEEPING DATA SECURE
15. We will use appropriate technical and organisational measures to safeguard your Personal Data, for example:
15.1. access to your account is controlled by a password and a user name that is unique to you.
15.2. we store your Personal Data on secure servers.
16. We hold Cyber Essentials Certification. This family of standards helps us manage your Personal Data and keep it secure.
17. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this email address: E-Training@wamanagement.co.uk.
18. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
20. 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.
21. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. For the avoidance of doubt, we delete any Personal Data in online training accounts if they remain inactive for 2 years.
22.Under certain circumstances, you have the following rights in relation to your Personal Data:
22.1. Right to access – the right to obtain confirmation from us that we process your Personal Data and to request access to your Personal Data. . If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded, repetitive or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
22.2. Right to correct – the right to have your Personal Data rectified if it is inaccurate or incomplete.
22.3. Right to erase – the right to request that we delete or remove your Personal Data from our systems.
22.4. Right to restrict our use of your Data – the right to restrict us from further using your Personal Data, so that we may only process it for certain purposes.
22.5. Right to data portability – the right to receive a copy of your Personal Data in a commonly-used and machine-readable format, and request that we move, copy or transfer your Personal Data to a third party.
22.6. Right to object – the right to object to our use of your Personal Data including where we use it for our legitimate interests.
22.7. Right to withdraw consent – the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
23. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Personal Data (where consent is our legal basis for processing your Personal Data), please contact our data privacy manager via this e-mail address: E-Training@wamanagement.co.uk.
24. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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. 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 the period for which we hold it.
LINKS TO OTHER WEBSITES
CHANGES OF BUSINESS OWNERSHIP AND CONTROL
27. We may also disclose Personal Data to a prospective purchaser of our business or any part of it.
28. In the above instances, we will take steps with the aim of ensuring your privacy is protected. 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.
You may contact WA Management by email at firstname.lastname@example.org.