This is privacy notice of How2Become Ltd.
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
This privacy notice is provided in a layered format so you can use the below contents to quickly navigate to the specific areas set out below.
- WHAT IS THE PURPOSE OF THIS PRIVACY NOTICE
- THE PERSONAL DATA WE COLLECT ABOUT YOU
- HOW WE COLLECT YOUR PERSONAL DATA
- HOW WE USE YOUR PERSONAL DATA
- WHO WE SHARE YOUR PERSONAL DATA WITH
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
- QUERIES, REQUESTS OR CONCERNS
- WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you purchase a product, sign up to our newsletter, download a resource, take part in a competition or contact us.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
How2Become Ltd is the controller and responsible for your personal data (collectively referred to as “How2Become”, “we”, “us” or “our” in this privacy notice). Our contact details are:
Registered and Postal address:
2 Mount Sion
For all data matters contact our Data Representative, Joshua Brown, via email at: [email protected]
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections 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 privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username, title, date of birth, gender.
- Contact Data includes billing address, delivery address, email address, telephone numbers, social media usernames.
- Financial Data includes bank account, payment card details.
- Transaction Data includes details about payments to and from you (such as transactional IDs) and other details of products and service you have purchased from us.
- Technical Data includes IP address, your login data, browser type and version, location, operating system and platform, timezone, and other technology on the devices you use to access this website.
- Profile Data includes your username and passwords, purchases or orders made by you, your interests, preferences and feedback.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect your 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 or service you have with us but we will notify you if this is the case at the time.
HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) Analytics providers such as Google based outside the EU, Microsoft’s Bing and social media platforms such as Facebook;
(b) Search information providers such as Google based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from publicly available sources.
Website plugins such as our contact forms (Contact Form 7 and Flamingo), Live Chat service (based outside of the EU).
- You may give us your identity, contact, and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for our products or services;
- Create an account on our website;
- Subscribe to our service or publications;
- Request marketing to be sent to you.
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:
- Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our data representative, Joshua Brown, at [email protected].
- Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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, with the legal bases we rely on to do so.
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 (data representative, Joshua Brown, at [email protected]) 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
(a) Identity (b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(a) Identity (b) Contact (c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity (b) Contact (c) Technical
(a) 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)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
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, products/services, marketing, customer relationships and experiences
(a) Technical (b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
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:
- Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
2. Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the How2Become group of companies for marketing purposes.
3. Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing [email protected] at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product or service experience or other transactions.
5. Change of 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our data representative, Joshua Brown, at [email protected].
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.
WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Third Parties Services:
- Providers acting as processors based in the United Kingdom and United States of America who provide IT and system administration services.
- Freelance web developers, designers and content creators based in the United Kingdom, Ukraine and Belarus.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, bookkeepers, accountants and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the united kingdom who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
A list of additional third parties How2Become use includes that we may share your personal data with (whether using our website or as a customer) include:
Customer Relationship Management software – Infusionsoft (now known as Keap), Gumroad, Marketer’s Choice
Payment terminals & merchant accounts – Sage Pay, Global Payments, Stripe, PayPal, and HSBC bank.
Stripe is the main merchant provider for this website (as of November 2020) and handles transactional payments. Stripe stores your card/payment details. No payment details, other than the name and address, are stored by us.
Please note that payment gateway provides, such as Stripe will certain retain transactional details, even if a “subject erasure request” is made. Stripe must do this to comply with accountancy and money laundering laws among others. Please refer to Stripe’s Privacy Centre to learn more about privacy at Stripe: https://support.stripe.com/questions/personal-data-subject-access-requests-for-eu-residents-under-gdpr
Postal/Services services – Royal Mail and Parcel Force.
External course tutors – Assessment Centre Training Limited.
Accounting services – Kendall Richardson and Burgess Hodgson.
Website plugins – Abandoned Cart Lite for WooCommerce, Admin Columns, Advanced Custom Fields PRO, Akismet Anti-Spam, BackWPup, Beeketing For WooCommerce, Category Order and Taxonomy Terms Order, Check and Enable GZIP compression, Check Email, Contact Form 7, Conversio for WooCommerce, Custom Post Type UI, Duplicate Post, Enable Media Replace, Flamingo, Flexible Shipping, GDPR Cookie Compliance, InfusedWoo Pro, Insert Headers and Footers, iThemes Security Pro, LiveChat, Nextend Social Login, Really Simple CSV Importer, Redirection, Regenerate Thumbnails, Remove base slug from custom-post-type URL, Search & Filter Pro, Simple Login Log, Simple Page Ordering, Wistia WordPress Plugin, WooCommerce, WooCommerce Continue Shopping, WooCommerce Force Sells, WooCommerce Pre-Orders, WooCommerce Shipment Tracking, WooCommerce Tab Manager, WooCommerce Thank You Page – NextMove, WooSidebars, WordPress Advanced Bulk Edit, WordPress Importer, WP Migrate DB, WP Smush, Yoast SEO, ytSubscribe – Youtube Subscribe Button, Metorik, New Relic, LiveChat.
Website servers & security – DigitalOcean (our website server), Sucuri (used to protect and secure data on our websites via Firewalls, and monitoring service. We also use Sucuri to run external back ups of our website and in turn, customer data. We may utilise Sucuri’s cyber security team to assist with any cyber security threat, such as removal of malware. We also utilise firewall and other industry standard protection from CloudFlare. CloudFlare monitors all website traffic to and from our Website. This includes IP addresses and device types. Do to the nature of this work, Sucuri is required to have full access to our website and its servers. This means they have access to customer data.
Website Developers – How2Become uses trusted freelance developers and server experts to maintain and resolve its websites and servers. All freelancers are vetted through UpWork.com’s platform. Due to the nature of their work, the web developers can get access to order details including your name, address, details of your order and online activity within How2Become’s platforms. How2Become does not store your card details on its website or servers – this information is held by Stripe and is not accessible by freelance developers.
We use Google Analytics and Google Ads. To see how Google uses your data, please click here.
New Relic – New Relic monitors How2Become’s website activity to ensure the smooth operation of the website.
Facebook – How2Become uses Facebook Pixels to track, monitor, and collect usage data on our website. Facebook’s privacy information can be found here.
LiveChat – used to provide customr support in real time or via tickets across our website pages. This software tracks user engagement with the site, such as IP Addresses, pages viewed, products purchased, name, and email information.
We also use Bing Ads to promote our business online. Any information that is gathered by Bing Ads will remain anonymous and cannot be used to identify you.
Email marketing – Using the email platform, Keap (also known as Infusionsoft), we gather statistics around open rates, click through rates (the act of clicking a link within an email) using industry standard technologies, including clear gifs to help us improve the content and services we provide. Another third-party, WooFunnels, also monitors our carts and checkouts to send abandoned cart reminder emails, again using industry standard technologies to track open rates, conversion rates, and product interest.
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.
Your personal data may be used by the third party in accordance to section 5 above by third party services who may be internationally based (outside of the European Economic Area (EEA). For example, our website backup’s are maintained by Sucuri.com, a leading website security service provider hosted in the US. Note: Backups of our servers are stored via Digital Ocean, Sucuri, and Amazon S3 – all of which reside in the US but host their own servers worldwide.
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 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.
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: see Your legal rights below for further information.
In some circumstances, we may 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.
YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact our Data Representative, Joshua Brown, via email at: [email protected].
No fee required – with some exceptions
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may 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.
CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 17/02/2021 can be obtained by contacting us.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Representative, Joshua Brown, via email at: [email protected].
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.