Type of website: Training Academy and Membership community space
Effective date: 17th day of September, 2021

https://elitemind.academy (the “Site”) is owned and operated by Elite Mind Business Academy Ltd. Elite Mind Business Academy Ltd is the data controller and can be contacted at:

hello@elitemind.co.uk
01753 597703
________________________________________

Purpose
The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:

  1. The personal data we will collect;
  2. Use of collected data;
  3. Who has access to the data collected;
  4. The rights of Site users; and
  5. The Site’s cookie policy.

This Privacy Policy applies in addition to the terms and conditions of our Site.

 

GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

 

Consent
By using our Site users agree that they consent to:

  1. The conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by: Contacting the Data Protection Officer.

 

Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal bases to collect and process the personal data of users in the EU:

  1. Users have provided their consent to the processing of their data for one or more specific purposes;
  2. Processing of user personal data is necessary for us or a third party to pursue a legitimate interest. Our legitimate interest is not overridden by the interests or fundamental rights and freedoms of users. Our legitimate interest(s) are: Data collection is used to make legal recommendations and influence public policy and practice;
  3. Processing of user personal data is necessary for us to take, at the request of a user, steps before entering a contract or for the performance of a contract to which a user is a party. If a user does not provide the personal data necessary to perform a contract the consequences are as follows: It will be detrimental to the quality of service and personalisation level provided, or service will not be provided at all.;
  4. Processing of user personal data is necessary for us to comply with a legal obligation. If a user does not provide the personal data necessary for us to perform a legal obligation the consequences are as follows: The client information will be processed confidentially to the detriment of personalisation and the quality of service.;
  5. Processing of user personal data is necessary to protect the life of the user or another natural person; and
  6. Processing of user personal data is necessary to a task carried out in the public interest or in the exercise of our official authority.

Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically
When you visit and use our Site, we may automatically collect and store the following information:

  1. IP address;
  2. Location;
  3. Hardware and software details;
  4. Clicked links;
  5. Content viewed; and
  6. Time spent on the website.

Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Site:

  1. First and last name;
  2. Age;
  3. Email address;
  4. Phone number;
  5. Payment information; and
  6. Auto fill data.

This data may be collected using the following methods:

  1. Creating an account;
  2. Subscribing to community membership; and
  3. Purchasing a product or service.

How We Use Personal Data
The Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect automatically is used for the following purposes:

  1. Statistics;
  2. Personalisation; and
  3. Service improvement and delivery.

The data we collect when the user performs certain functions may be used for the following purposes:

  1. Communication;
  2. Personalisation;
  3. Service delivery; and
  4. Reward and recognition.

Who We Share Personal Data With
Employees
We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Other Disclosures
We will not sell or share your data with other third parties, except in the following cases:

  1. If the law requires it;
  2. If it is required for any legal proceeding;
  3. To prove or protect our legal rights; and
  4. To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

 

How Long We Store Personal Data
User data will be stored for up to 5 years. Different information is collected for different objectives, and the data is kept until the purpose of collection has been achieved, unless requested by the user or legal entity to do otherwise.

You will be notified if your data is kept for longer than this period.

 

How We Protect Your Personal Data
In order to protect your security, we use the strongest available browser encryption and store all of our data on servers in secure facilities. All data is only accessible to our employees and never shared with any third parties. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee’s termination.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

 

International Data Transfers
We transfer user personal data to the following countries:

  1. United States;
  2. Canada;
  3. South Africa; and
  4. Australia.

When we transfer user personal data we will protect that data as described in this Privacy Policy and comply with applicable legal requirements for transferring personal data internationally.

If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:

  1. The country your personal data is being transferred to has been deemed to have adequate data protection by the European Commission or, if you are in the United Kingdom, by the United Kingdom adequacy regulations; or
  2. We have implemented appropriate safeguards in respect of the transfer. For example, the recipient is a party to binding corporate rules, or we have entered into standard EU or United Kingdom data protection contractual clauses with the recipient..

Automated Decision-Making and Profiling
You have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. You can object to your personal data being used in this way or require a manual review of an automated decision by contacting our data protection officer.

We only use automated decision-making and profiling if the decision:

  1. Is necessary to enter into or perform a contract between you and us;
  2. Is authorised by EU or member state law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  3. Is based on your explicit consent.

The decision(s) we make using automated decision-making, the criteria or reasons those decisions are based on, and the significance and consequences of those decisions for you are as follows:

  1. Decision: We use AI and machine learning to determine the level of personalisation and resource relevance for the benefit of each user.
    Criteria or reasons for decision: Self-reported data, behavioural insights and profiling.
    Significance and consequences of decision for you: The user will receive a piece of specific information or resource that is relevant to their area of interest or need, through the method that the user is most likely to engage with and benefit from.

Your Rights as a User
Under the GDPR, you have the following rights:

  1. Right to be informed;
  2. Right of access;
  3. Right to rectification;
  4. Right to erasure;
  5. Right to restrict processing;
  6. Right to data portability; and
  7. Right to object.

Children
The minimum age to use our website is 11 years of age. We collect the personal data of children under 16 years of age. We only collect the personal data of children under 16 years of age with the express consent of their parents or guardians. This consent is collected as follows:

  1. Consent form, or; and
  2. Service provision through the provider that already has consent to process chidren’s data (such as school, education provider, health institution or regulatory body)body.

Please see our Children’s Privacy Policy for additional information on how we deal with children’s personal data.

 

How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our data protection officer here:

Rob Finean
rob@elitemind.co.uk
________________________________________
________________________________________

 

Do Not Track Notice
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We respond to browser-initiated DNT signals. If we receive a DNT signal that indicates a user does not wish to be tracked, we will not track that user.

 

How to Opt-Out of Data Collection, Use or Disclosure
In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:

  1. You can opt out of the use of your personal data for marketing purposes or for any irrelevant content. You can opt-out by clicking ‘unsubscribe’ on the bottom of any email or by updating your email preferences in account settings.

Cookie Policy
A cookie is a small file, stored on a user’s hard drive by a website. Its purpose is to collect data relating to the user’s browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

We use the following types of cookies on our Site:

  1. Functional cookies
    Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;
  2. Analytical cookies
    Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc;
  3. Targeting cookies
    Targeting cookies collect data on how you use the Site and your preferences. This allows us to personalise the information you see on our Site for you; and
  4. Third-Party Cookies
    Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:
  5. monitor user preferences to tailor content and services around their interests.

Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

 

Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioners’ Office.

 

Contact Information
If you have any questions, concerns or complaints, you can contact our data protection officer, Rob Finean, at: rob@elitemind.co.uk

 

Children’s Privacy Policy

Website: https://elitemind.academy (the “Site”)

This Children’s Privacy Policy supplements the https://elitemind.academy Privacy Policy and applies to the personal information of children in the United States who are under the age of thirteen (13) (“child” or “children”). This Children’s Privacy Policy is made in accordance with the United States Children’s Online Privacy Protection Act (“COPPA”). Any terms defined in COPPA have the same meaning when used in this Children’s Privacy Policy.

 

Children’s Data We Collect
We collect personal information from children. We only collect personal information from children after sending a direct notice to parents and obtaining verifiable parental consent for the collection of the child’s personal information.

We collect the following personal information from children:

  1. Name;
  2. email address;
  3. health and safeguarding concerns; and
  4. location (IP address).

Collection Methods
We collect personal information from children using the following methods:

  1. directly from child through self-reporting;
  2. from parents or learning providers; and
  3. passively through cookies.

Use of Children’s Personal Information
We use the childrens’ personal information we collect in the following ways:

  1. To deliver the service and personalise the content to child’s needs.
  2. For safeguarding matters, to ensure child’s safety and improve wellbeing
  3. For statistics to influence research, policy and practice in the field of mental health

Public Availability
Children are not able to make their personal information publicly available on our Site.

 

Disclosure to Third Parties
We do not disclose personal information we collect from children to third parties.

 

Third Party Operators
Third parties do not use our Site to collect personal information about children who use our Site.

 

Parental Rights
A child’s parent or guardian can review their child’s personal information, direct us to delete their child’s personal information, and refuse any further collection or use of their child’s personal information. A parent or guardian can also agree to the collection and use of their child’s personal information but not allow us to disclose that personal information to third parties, unless disclosure is part of the service provided by our Site. A parent or guardian can exercise these rights via the following method(s):

  1. Parents can contact us at customerservice@elitemind.co.uk to request access to or deletion of their child’s personal information, or to provide or remove consent for the collection of their child’s personal information..

We will not require a child to disclose more information than is reasonably necessary to participate in an activity on our Site.

 

Contact Information
Questions and concerns about this Children’s Privacy Policy or about our collection and use of children’s personal information, can be sent to:

Name: Evelina Dzimanaviciute
Email: evelina@elitemind.co.uk
Address: ________________________________________
Phone number: ________________________________________