This Policy applies to both consumers and business customers. Throughout this Policy, “you” (and “your” and “yours”) refer to the consumer or the natural persons of a business (for example, the contact person or employee of the business customer) we collect and process personal information of. Certain information we collect and process from natural persons in a business context will be considered personal information, if we are able to identify an individual within the business either directly or indirectly from that information.
This Policy applies to all our products and services, including those access via our Website and App (as defined below).
Our Website is not intended for use by children under the age of 13 and we do not knowingly collect or use personal information relating to children. Our Website and App are recommended for those that are 16 years of age or over.
Data controller and contact details
When you access and browse our Website, when you use our App and when you use one of the Services we offer, we collect and use certain personal information about you. When we do so we are regulated by privacy laws and we are responsible as the ‘data controller’ of that personal information for the purposes of those laws.
Working Voices Limited is a limited liability company registered in England and Wales with company number 04018115 and with its registered office address at:
London, England, W1J 6BD
For more information about us and our activities see About Us.
How we collect your personal information
We collect and process personal information from you when you browse our Website, use our App, participate in one of our Services and when you otherwise interact with us. Below, we have set out in more detail how we collect information for each method:
- before you install our mobile software application Learnflix (“App”) you must indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this Policy. When you use our App, we collect certain information from you which includes personal information. Such information may be collected directly or indirectly;
- when you sign up for and/or participate in our coaching and training services (“Services”), either delivered to you by virtual means (through our Website or App) or physically, we will collect and process certain personal information from you, which we may request from you or you may provide us with; and
- when you interact with us, for example by contacting us by telephone, e-mail or other means of communication, by completing a survey, or providing us with feedback.
Changes to this Policy
We may, from time to time, change this Policy. If we make changes, these changes will be posted on our Website and, where appropriate, notified to you by email if we have your email address, or when you next start our App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
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 our relationship with you.
Throughout our Website and App we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you or for information purposes. These third party websites may also gather information about you in accordance with their own separate privacy policies. We do not control the data collection and processing of such third parties. For privacy information relating to these third party websites, please consult their privacy policies as appropriate.
What personal information we collect from you
We collect, use and store different categories of data. Which categories of data we collect and use depends on the particular activities you carry out. We have categorised the data we collect as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you, details of products and services you have purchased from us and details relating to any services we provide or propose to provide to you.
- Technical (Device) Data includes internet protocol (IP) address, 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 and App.
- Usage Data includes details of your use and visits of our Website and App including, but not limited to, traffic data and other communication data and how you use the content of our Website and App and the information input by you, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We use the above information to:
- create and manage your account with us;
- verify your identity;
- provide products and Services to you;
- take payment from you;
- respond to and assist with any queries you may have about our products and Services;
- customise our Website and App and their contents to your particular preferences;
- notify you of any changes to our Website, App or Services that may affect you;
- improve our Services.
Special Categories of Personal Data
Special Categories of Personal Data include 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.
We usually do not collect any such data from you. Nor do we collect any information about criminal convictions and offences.
However, if you choose to use one of our Services, you may provide us with some information about yourself which may fall into the abovementioned Special Categories of Personal Data. For example, you may provide information about certain aspects of your health during a coaching session. When we would ask you for any Special Categories of Personal Data, we rely on your explicit consent to collect and process such personal data. When you provide us with such personal data of your own accord, this is deemed your explicit consent for us to collect and process such personal data. We will only use such personal data specifically for and in relation to the Service you have provided such personal data for.
Cookies and similar technologies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Website or App. Cookies help us recognise you and your device and store some information about your preferences or past actions.
For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.
Our legal basis for processing your personal information
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
- consent: where you have given us clear consent for us to process your personal information for a specific purpose;
- contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
- legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations);
- legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).
We would like to send you newsletters and information about our products and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.
If you have previously agreed to being contacted in this way, you can unsubscribe at any time by contacting us at email@example.com using the ‘unsubscribe’ link in emails or ‘STOP’ number in text messages.
It may take up to five days before your request is processed.
For more information on your rights in relation to marketing, see ‘Your rights’ below.
Purposes for which we may 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, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 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.
|Purpose/activity||Type of data||Lawful basis for processing|
|To register you as a new customer or to install the App||
Taking steps before entering into a contract with you
|To process your purchase, including managing payments, collecting money owed to us and delivering our services to you||
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
|To perform our Services||
Performance of a contract with you
|To manage our relationship with you including contacting you for marketing purposes or notifying you of changes to any Services or our App||
Marketing and Communications
Marketing and Communications
|To administer and protect our business, Website and App including troubleshooting, data analysis and system testing||
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To use data analytics to improve our Website, App, Services, marketing, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of customers for our services, to keep our Website and App updated, to develop our business and to inform our marketing strategy)|
Sharing your personal data
We routinely share data with our internal and external third party suppliers, including:
- our personnel who provide Services to you on our behalf;
- service providers providing IT and system administration services, such as the hosting
provider of our Website;
- service providers providing payment processing software;
- service providers providing analytics services, such as Google Analytics;
- the application store provider, e.g. Apple;
- 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 Policy.
This data sharing enables these third parties to perform functions on our behalf that are required in order to provide you with our Services.
Some of those third party recipients may be based outside the United Kingdom (UK) or European Economic Area (EEA). For further information including on how we safeguard your personal data when this occurs, see the section ‘Transfer of your information out of the EEA’.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
Whether information has to be provided by you, and if so why
We require you to provide Identity Data and Contact Data to enable you to purchase Services and to enable us to fulfil orders you placed. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
Transfer of your information out of the UK/EEA
We may transfer your personal information to our third party suppliers (see ‘Sharing your personal data’, above) based in countries outside of the UK or EEA.
Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
- where we use certain service providers, we may use specific contracts approved by the UK/EEA which give personal data the same protection it has in the UK/EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website or our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How long we keep your personal information
We keep your personal information for as long as necessary to fulfil the purpose for which the information was collected.
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 Rights below for further information.
In some circumstances we will 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.
Under data protection laws you have a number of important rights free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information;
- access to your personal information and to certain other supplementary information that this Policy is already designed to address;
- require us to correct any mistakes in your information which we hold;
- require the erasure of personal information concerning you in certain situations;
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
- object at any time to processing of personal information concerning you for direct marketing;
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
- object in certain other situations to our continued processing of your personal information;
- otherwise restrict our processing of your personal information in certain circumstances.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under privacy laws.
If you would like to exercise any of those rights, please:
- email, call or write to us;
- let us have enough information to identify you (e.g. account number, user name, registration details);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know the information to which your request relates.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
You also have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
How to contact us
Please contact us using the details below if you have any questions about this Policy or the information we hold about you.