PRIVACY POLICY
www.gastrolearning.com (“the website”) is owned by GastroLearning Ltd ( “GL”; “we”; “us”; “our”), which is for the purposes of the United Kingdom Data Protection Act 1998 (‘the Act’) the Data Controller and is situated at GastroLearning Ltd, 24 Greenham Road, London N10 1LP.
The Act gives United Kingdom users the right to access information that is held about them.
GL website is an online resource for individuals, marketers, organisations and other, hereinafter referred to as “GastroLearning”. This policy applies to a “Visitor” (which means a person who browses the website but is not a member) or a “User” (which means a person who has enrolled on a course hosted by GastroLearning Ltd as a registered e-learning user to the website). The term “User” refers to a Visitor or a Member. We are committed to protecting any data that we collect concerning our website users. By using our services, you agree to the use of the data that we collect in accordance with this Privacy Policy.
We are committed to protecting your privacy. This Policy indicates the type of processes that may result in data being collected about you. Your use of this website gives us the right to collect that information.
Web server log information
We use a third-party server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system. Our server is located in the United Kingdom.
Use of website server log information for IT security purposes:
Our third-party hosting provider stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our website server provider to make any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation). Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.
IP address lookup
Our company uses third parties to provide information about visitors to our websites. When you visit our website, we will record your IP address. This address will be matched against public and proprietary IP address databases to provide us with information about your visit. This information may identify the organisation to whom the IP address is registered but not individuals. In some limited cases i.e. single person companies, it may be possible to identify personal data from publicly available ICANN data.
Website cookies and link tracking
Cookies allow us to provide important site functionality, so you don’t have to re-enter lots of information. They also allow us to remember what links and pages have been clicked or viewed during a session. If you have provided us with personal data, completing a contact form for example, we may associate this personal data with other information. This will allow us to identify and record what is most relevant to you. By using your browser controls, you are always in control of the cookies we store and access on your computer.
More information on how to control cookies and limit personal data processing can be found at
www.youronlinechoices.com/uk/five-top-tips.
Types of communications
By submitting your email address you are consenting to receive the specific piece of information you requested, as well as allowing us to send you appropriate and useful communications. This includes, but is not limited to; invitations to our industry leading events, our latest assets (guideline summaries, videos and case studies) and promotional offers on future courses.
If you are a customer of GL or third party running a course, you will also receive regular emails related to your course. These updates will also highlight the great new changes taking place at GastroLearning.
At any time, you can opt-out by clicking the link in any emails you receive from us. The link will always be in the footer of the email.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
• Email
When you send an email to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
• Transfer and storage of your information
We may use a third-party email provider to store emails you send us. Our third-party email provider is based in the United States of America.
Emails you send us will be stored outside the European Economic Area on our third-party email provider’s servers in the United States of America. For further information and safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.
• Website forms
When you contact us using any of our website forms, we collect the following information: your name, email address and any information you include in the message field and other fields. We also collect your company name if you provide it.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
• Transfer and storage of your information
Messages you send us via our website forms will be stored on our web servers in the UK and transferred to our email provider’s servers outside the European Economic Area.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
• Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
• Transfer and storage of your information
Information you send us by post is stored in the United Kingdom.
• Informatino we collect when you interact with our website:
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
• Email marketing
When you sign up to receive news and offers about our products and services on our website we collect your email address.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you emails by signing up to receive it using the steps described above.
• Transfer and storage of your information
We use a third-party service to send out our email communications and administer our mailing list, called Active Campaign. You can access their privacy policy here.
Information you submit to subscribe for our email communications will be stored outside the European Economic Area on Active Campaign’s servers in the United States of America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
• Registering on our website
When you register and create an account on our website (at checkout), we collect the following information: your name, company name (if applicable), your address (including country, street address, town/city and postcode), phone number, email address and password (we do not view your password).
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to provide you access to content and updates you have purchased and facilitate the efficient running and operation of our business.
• Transfer and storage of your information
Information you submit to subscribe for our email communications will be stored outside the European
Economic Area on Active Campaign’s servers in the United States of America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Information we collect when you place an order on our website
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you place an order for goods or services on our website, we collect the following mandatory information: name, email address, phone number, billing address, company name (if applicable), VAT number (if applicable) and account password (if you create an account). If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: other than phone number and password, we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: other than phone number and password, we have a legal obligation to issue you with an invoice for the goods and services you purchased from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose.
Legal basis for processing: we collect your phone number and password in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s):
• We collect your password for our legitimate interests in: (i) registering and administering accounts on our website to provide you access to content and updates you have purchased; and (ii) to facilitate the efficient running and operation of our business.
• We collect your phone number for our legitimate interest of more easily and effectively contacting you in relation to your order and your account.
• Marketing communications: At checkout you will have the option of receiving marketing communications from us.
• Offers relating to our goods and services
‘By submitting this form, you agree to us contacting you by email and storing your contact details for future contact about the GL’s products and services. Your contact details will be accessible by employees of GL but will never be shared with or sold to third parties.
Submitting your details also indicates that you have read and agree to our privacy policy and cookie policy. You can, of course, opt out of these communications at any time.
We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
• Transfer and storage of your information
We use a third-party service to send out our email communications and administer our mailing list, called Active Campaign. You can access their privacy policy here.
Information you submit to subscribe for our email communications will be stored outside the European
Economic Area on Active Campaign’s servers in the United States of America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Processing your payment
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a third party payment processor called Stripe. Your payment will be processed by Stripe via a payment gateway.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
• Third party payment processors
The third-party payment processors we use collect, use and process your information, including payment information, in accordance with their privacy policies.
• Transfer and storage of your information
Stripe may transfer information relating to your transaction and the processing of your transaction outside the European Economic Area. Where they do so, they will put appropriate safeguards in place. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
How we collect or obtain information about you from third parties
This section sets out how we obtain or collect information about you from third parties.
Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include other businesses and clients we work with from time to time who may recommend our services to you. These could be business in any industry, sector, sub-sector or location.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you. Information we obtain from third parties will generally be your name and contact details but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass your information on to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract. Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one). We may do this, for example, if we have insufficient information to be able to contact you or to better understand your business.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Disclosure and additional uses of your information:
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
• Telephone providers (UK),
• Email provider (USA),
• Mailing list provider (USA),
• IT service providers (UK),
• Web developers (Belarus), and
• Hosting provider (UK).
Your information will be shared with these service providers only where necessary to enable us to run our business.
Disclosure of your information for legal reasons:
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
• In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
• In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
• For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Google: Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the partners page of Google’s privacy policy.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service and allowing the Google Analytics to work on our website
You can opt out of Google Analytics by installing the browser plugin here
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers. Further information on each of these third parties is set out below.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.
Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts. Our accountants are located in the United Kingdom.
Advisors
Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and other specialists. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice. Our advisors are located in the United Kingdom.
Affiliates
Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Our affiliates can be in in any industry, sector or subsector. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.
Business partners
Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.
Independent contractors
Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.
Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.
Our insurers are located in the United Kingdom.
