Pink Rooster Privacy Policy

PRIVACY STATEMENT

Pink Rooster is committed to protecting and respecting your privacy. This Privacy Notice, sets out the basis on which any personal data we collect from you, (or that you provide to us), will be processed by Pink Rooster and the purpose for our collection of it. Please read the following carefully to understand how we will treat your personal data.

Data protection (Data Protection Act 2018 / GDPR)

For the purpose the Data Protection Act 2018 ( https://www.gov.uk/data-protection) and the General Data Protection Regulation or GDPR ( https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/ )

For the purpose the General Data Protection Regulation or GDPR, Pink Rooster is the data controller of your personal information and is entered in the Information Commissioner’s Office (ICO) Register of Data Controllers.

This policy explains how we may collect and process personal data about:

• clients and prospective clients;
• suppliers;
• visitors to our website and subscribers to our online services;
• job and work experience applicants and contractors; and
• any other individual whose personal data we may

Depending on our relationship with you this policy may be supplemented with additional information, policies or guidelines relating to our use of your personal data, for example in our application forms, Terms and Conditions, and other documentation.

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1. What information do we collect and what do we do with it?

When you enrol as a student or subscriber (“learner”) on our site or related courses, as part of the enrolling process, we collect the personal information you give us such as your name and email address.

Email marketing: we may send you emails about our site and related course(s), registration, course content, your course progress or other updates. We may also use your email to inform you about changes to the course, survey you about your usage, or collect your opinion.

We may also collect information about you in other ways, for example:

• if you are a customer of one of our partner organisations, and we are undertaking our services on our partner’s behalf;
• indirectly, through one of our staff or volunteers, a client or a third party;
• if you are a supplier of ours, from that supplier relationship; and
• from publicly available sources, for example the electoral roll or Companies House.

We may (if it is relevant to the services we provide to you) collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes your name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes addresses, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about our services that you have used with us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, 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.
• Usage Data includes information about how you use our website and how you use our services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Special Categories of Personal Data 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.

How we use your personal data

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:

• 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.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where you have given Pink Rooster your express consent to process your personal data.
• Where we need to comply with a legal or regulatory obligation.

The way we process your personal data we collect as set out above varies depending on our relationship with you. In each case the purposes for which we request the information will be clear from the context in which it is acquired. These include:

• providing our services to you or an entity for which you work;
• verifying your identity;
• keeping a record of the services you have subscribed to and deliver services you may have requested;
• administration, billing and record-keeping purposes;
• communicating with you by telephone, email, fax or post;
• meeting our legal, regulatory and contractual obligations arising from our relationship with you;
• administering our website, enhancing operational capabilities and for internal operations;
• verifying or enforcing compliance with this policy and applicable laws; and
• to inform you of developments that may affect you or to inform you of products, services or events.

In some circumstances we may ask for sensitive data

Sometimes we will ask you to provide additional personal information, and sometimes sensitive personal information related to your health (e.g. if you our therapy or Social Prescribing Services).   When we do this we will provide further information about why we are collecting your information and how we will use it.  In these cases we will always obtain your express consent.

We may also ask for and anonymously record ethnicity, religious belief and sexual orientation information to help us with equal opportunities monitoring.

2. How do you get my consent?

When you provide us with personal information to become a learner on our site, make a purchase, or participate in the course, you imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

How do I withdraw my consent?

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at [email protected]

3. Disclosure

Disclosure of your personal data

We will only disclose your personal information to another person or organisation where we:

• need to share the information to provide a product or service you have requested;
• need to send the information to persons or organisations who engage our services on their behalf, including where you are that third party’s client;
• need to send the information to persons or organisations that work on our behalf to provide a product or service to you. Where such a person or organisation does work on our behalf we will ensure that they are contractually required to take appropriate technical and organisational measures to protect your personal information against unauthorised or unlawful processing and against accidental loss or destruction of, or damage to, personal information and only use the information in order to provide a product or service on our behalf; and
• are required to disclose the information in order to comply with the law or the requirements of a regulatory authority.

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.

4. Thingify

Our course and site (where applicable) is hosted by Thingify Labs Inc. (“Thinkific”). They provide us with the online course creation platform that allow us to sell our product/services to you.

Your data is stored through Thinkific’s data storage, databases and the general Thinkific application. They store your data on a secure server behind a firewall.

Payment:

If you make a purchase on our site, we use a third-party payment processor such as Stripe or PayPal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.

For more insight, you may also want to read Thinkific’s Terms of Service here https://www.thinkific.com/resources/privacy-policy/ or Privacy Statement here https://www.thinkific.com/resources/terms-of-service/ .

5. Third Party Services

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our course website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.

Links

When you click on links on our course site, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

This policy only extends to our website and websites, which are owned and operated by Pink Rooster and does not, therefore, extend to your use of, provision of information to and collection of information on any website not connected to Pink Rooster to which you may link by using the hypertext links within our website.

6. Security

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

Cookies

We collect cookies or similar tracking technologies. This means information that our website’s server transfers to your computer. This information can be used to track your session on our website. Cookies may also be used to customize our website content for you as an individual. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer.

We use cookies to recognize your device and provide you with a personalized experience.

We also use cookies to attribute visits to our websites to third-party sources and to serve targeted ads from Google, Facebook, Instagram and other third-party vendors.

Our third-party advertisers use cookies to track your prior visits to our websites and elsewhere on the Internet in order to serve you targeted ads. For more information about targeted or behavioural advertising, please visit https://www.networkadvertising.org/understanding-online-advertising.

Opting out: You can opt out of targeted ads served via specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page.

We may also use automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Web Analysis Tools

We may use web analysis tools that are built into Pink Rooster’s website to measure and collect anonymous session information.

7. Age of Consent

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence.

8. Changes to this Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If our site or course is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.

You are expected to check this page from time to time to take notice of any changes we have made, as they are binding on you.

QUESTIONS AND CONTACT INFORMATION

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Data Protection Officer at [email protected]

Last updated: 05 May 2021