Privacy Policy

Privacy Policy

GDPR Compliance Statement

Who we are

This is the privacy statement of Sancus International

Types of personal information we collect

We may collect, use and store different types of personal information about you, which we have grouped together as follows:

Types of personal information

Description

Identity data

ID information including your name, title and date of birth.

Contact data

Home address/Work, e-mail address and telephone number

Financial data

Payment details

Transactional data

Details of payments to and from you and other details about services you purchase from us

Communications data

Information contained in letters, emails and other forms of electronic communications and conversations between us

Social relationships data

Details about your family, friends and other relationships

Marketing data

Details about your preferences in receiving marketing communications from us and our partners

Consents data

Any permissions, consents or preferences that you give us

Usage data

Information about how you use our website, products and services

Special category data

Some types of personal information are defined as special. We will only collect and use these types of information where we need to and if the law allows us to:

• Racial or ethnic origin
• Political opinions, religious or philosophical beliefs
• Trade union membership
• Genetic or bio-metric data used for ID purposes
• Sexual orientation
• Criminal convictions data

What we use your personal information for

We collect and use personal information to:

• Deliver and improve our services, as set out in contacts and agreements with you
• Properly manage our business in an effective manner
• Contact you by post, email or telephone to respond to your queries and provide you with information that you request of us
• Understand your needs and how they may best be met.
• Send marketing communications to you
• Manage events, to promote our business and its services
• Manage your marketing preferences and keep our records up to date
• Administer our website and internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• Improve our services and website and ensure that content is presented in the most effective manner for you and your device
• Process financial transactions, e.g. payments for services we provide to you, or refunds due to you
• Perform corporate activities such as the sale, merger or reorganisation of our business
• Prevent and detect crime, fraud or corruption and protect our rights and interests
• Meet our legal responsibilities to the police and other law enforcement agencies and government bodies

The legal basis for processing your personal information depends on the type of information and the context in which you provide it. We rely on one or more of the following lawful grounds for processing your personal information:

Consent – where you have agreed to us processing your information for a specific reason (e.g. you have consented to receive marketing materials from us)

Soft opt-in – where we have an existing relationship that allows us to send electronic marketing communications to you on an opt-out basis

Contract - the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you

Legal obligation - the processing is necessary for compliance with a legal obligation we have such as keeping records for compliance with our obligations

Legitimate interests – the processing is necessary for our legitimate interests, such as:

• to provide our services or information to you or any organization you work for;
• to prevent and detect theft, fraud and other criminal activity;
• to protect our business interests;
• to manage our business (including business planning and promotion)
• to investigate complaints;
• to evaluate, develop or improve our services or products; or
• to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

• you have given us your explicit consent to process that data;
• we are required by law to process that data;
• the processing is necessary to carry out our obligations under employment, social security or social protection law;
• the processing is necessary for the establishment, exercise or defence of legal claims; or
• you have made the data manifestly public.

Where we collect your personal information from

We may collect personal information about you from the following sources:

From you directly e.g. contact details provided by phone, email, when you create an account with us or at an event.

From your use of our services: e.g. your IP address, location, domain name, browser type, device ID, dates and times you access our services, number of website visits, navigation history within, to and from the site.

From third parties: e.g. Publicly available resources such as Companies House, internet social network sites such as LinkedIn, market researchers, job boards, marketing companies and events companies, analytics providers such as Google Analytics.

From CCTV footage.

Who we share your information with

We may share your personal information with the following third parties:

• Other companies owned or jointly owned by Directors of Paragon Education
• Service providers, including providers of document analysis tools used by us in the course of providing our products and services
• Commercial partners of ours, where you have opted in to receiving marketing information from them
• The police and other law enforcement agencies and HMRC and other government bodies where we have a legal or regulatory obligation to do so
• Debt recovery agencies, to recover overdue amounts due to us
• Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business

Automated decisions

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement) which have a legal or similarly significant effect on you.

If you choose not to give your personal information

If you choose not to give your personal information, it may delay or prohibit us from meeting our obligations or lead to us cancelling the service you have with us.

How long we keep your personal information

If you have previously opted in to receive communications from us, or are an active contact, we will continue to hold your personal information. You may, at any time, exercise your right to stop receiving marketing and promotional information from us by unsubscribing or by contacting us at the email address provided below. At that point, we will delete your personal information from our central communication database and only contact you on matters concerning current work.

Where we hold your personal information internationally

Personal information of customers or individuals in Republic of Ireland and other non UK countries is held on our database in the UK. Their personal information is subject to the same GDPR legislation as that of our UK customers and is therefore protected to the same standards.

Using our website

Our website may contain links that make it easy for you to visit other websites. If you use such links to leave the website and visit a website operated by a third party, we are not responsible for the protection and privacy of any personal information which you provide while visiting such websites. You should exercise caution and look at the privacy statement applicable to the website in question.

We may use cookies, i.e. small amounts of data stored on your computer and revealed to us when you use our website. We use cookies only to make it easier to identify you when using the website, not to collect additional information about you. You can configure your web browser not to accept cookies, although this may hinder the functionality of the website.

Your rights

Under data protection law you have the following rights in respect of the personal data about you that we process

Access to your information – You have the right to request a copy of the personal information about you that we hold.

Correcting your information – We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.

Deletion of your information – You have the right to ask us to delete personal information about you where:

• You consider that we no longer require the information for the purposes for which it was obtained
• We are using that information with your consent and you have withdrawn your consent – see Withdrawing consent to using your information below

• You have validly objected to our use of your personal information – see Objecting to how we may use your information below
• Our use of your personal information is contrary to law or our other legal obligations.

Objecting to how we use your information – You have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest or pursuant to the legitimate interests of us or a third party then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.

Restricting how we use your information – in some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information but you don't want us to delete the data. Where this right to validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

Transfer– if we process personal information that you provide to us on the basis of consent or because it is necessary for the performance of a contract to which you are party, and in either case that processing is carried out by automated means, then you have the right to have that personal information transmitted to you in a machine readable format. Where technically feasible, you also have the right to have that personal information transmitted directly to another controller.

Withdrawing consent using your information – Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.

Please contact us in any of the ways set out in the “Contact information and further advice” section if you wish to exercise any of these rights.

Changes to our privacy statement

We keep this privacy statement under regular review and will place any updates on this website. Paper copies of the privacy statement may also be obtained by emailing us at info@sancusinternational.com with your address.

This privacy statement was last updated on 02^nd August 2020.

Contact information and further advice

Paragon Education has appointed a data privacy manager. If you have any questions about this privacy statement or how we handle your personal information please contact the data privacy manager by e-mailing info@sancusinternational.com

Complaints

We seek to resolve directly all complaints about how we handle personal information but you also have the right to lodge a complaint with the regulator in your jurisdiction:

For customers in the UK, please contact the Information Commissioner's Office:

By phone: 0303 123 1113

By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Online: https://ico.org.uk/global/contact-us/email/

For customers in the Republic of Ireland, please contact the Data Protection Commissioner:

By phone: +353 (0)761 104 800

By fax: +353 57 868 4757

By post: Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland.

By email: info@dataprotection.ie