PRIVACY POLICY

It is Changetoolbox Ltd’s policy to respect your privacy regarding any information we may collect while operating our website or social media channels.  

This privacy policy (“Privacy Policy”) applies to www.changetoolbox.com the ‘Website’, our Change Community Online platform and our social media channels, LinkedIn, Facebook and Twitter (collectively herein referred to as ‘Social Media’) . We respect your privacy and are committed to protecting personally identifiable information you may provide us through the Website or Social Media.  

We have adopted this Privacy Policy to explain what information may be collected on our Website and Social Media, how we use this information, and under what circumstances we may disclose the information to third parties.  

Collection and use of personal data: 

Personal data, or personal information (herein “Information”), means any Information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

This Privacy Policy applies only to Information we collect through the Website and Social Media but does not apply to our collection of Information from other sources. 

We may collect the following information: 

Identity Data: which includes full name and job title 

Contact Data: which includes contact information including phone number, email address and at times home address 

Non-Personal Data: which will not directly or indirectly reveal your identity and includes company information such as company name, company address including post code, number of employees 

Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses 

Technical Data: which includes website address, internet protocol (IP) address

Usage Data: which includes information about how you use our website, products and services.

Marketing and Communications Data: which includes your preference in receiving marketing from us and your communication preferences#

Other information relevant to: Consultancy/workshops/events/webinars and newsletters and/or Licenses/subscriptions and/or any other services/products and tools 

We may collect Information from you when you: 

 ·         submit an enquiry 

 ·         sign up to an event/workshop/consultancy/webinar/newsletter/subscription/license 

 ·         sign up to our memberships 

 ·         purchase any of our services, products or tools 

This information is collected and processed on the legitimate purpose of providing you with information about our services, products and tools. 

We collect Technical and Usage Data from visitors to our Website and our Change Community Online platform using analytics tools, cookies and web logs. This information is only used to improve the service you experience whilst navigating on our site. 

The information collected may be used to provide you with additional information about our services, promotions, products, tools, events, consultancy services, webinars and workshops. Please be aware that you may need to confirm a subscription in the first place for some of these and subscribers can change or cancel their subscriptions at any time in accordance with the cancellation policy. 

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, 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
including basis of legitimate interest
To register you as a new
Client/Customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver
our services and products
including:
(a) Identity
(b) Contact
(c) Financial
(a) Performance of a contract
with you
(a) Manage payments,
fees and charges
(b) Collect and recover
money owed to us
(d) Transaction
(e) Marketing and
Communications
(b) Necessary for our
legitimate interests (to recover 
debts due to us)
To manage our 
relationship with you
which will include:
(a) Notifying you about
changes to our terms of
privacy policy
(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 enable you to partake
in a prize draw,
competition or complete a
survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(a) Performance of a contract
with you
(b) Necessary for our
legitimate interests (to study
how customers use our
products/services, to develop
them and grow our business)
To administer and protect
our business and this
Website & Change 
Community Platform
(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
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
(a) Necessary for our
legitimate interests (to study how
customers use our 
products/services, tools and 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, tools to keep our
Website & Change Community
Platform updated and relevant,
to develop our business and to
inform our marketing strategy)
To make suggestions and 
recommendations to you
about products or services,
tools that may be of 
interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and 
Communications
(a) Necessary for our legitimate
interests (to develop our
products/services and tools
and grow our business)

Use of Third Parties:   

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen. 

We will receive personal data, including Identity and Contact data from various third parties as set out below:

a)    Eventbrite as our event/webinar/workshop/consultancy management tool. 

b)    SurveyMonkey and SmartSurvey as our Customer Satisfaction Survey tools.

c)    Social media channels, including LinkedIn, Facebook, Twitter and Instagram. 

d)    Acuity Scheduling for our diary management and consultancy meetings.   

We use Mailchimp for our marketing and marketing campaigns. We also use ECOMSILVER as our web developer to host and manage both our Website and our subscription membership and license platform, Change Community Online. 

We also use Social Media to advertise our services and run marketing campaigns. 

We may use other third-party providers instead of or in addition to those listed, to enrich your online user experience and support the management and tools operating through us and these may change from time to time at the sole discretion of Changetoolbox Ltd.

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.

Links to external sites: 

Our services may contain links to external sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy and terms and conditions of every site you visit. We have no control over, and accept no responsibility for the content, privacy policies or practices of any third-party sites, products or services. 

Controlling your personal information: 

We are committed to being transparent about how we use your personal data and take the security of personal data very seriously. 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. 

Marketing and Opting Out: 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  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, tools and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods, services, tools from us and you have not opted out of receiving that marketing. 

You have full control over the marketing messages you receive regarding additional products and services, tools that we offer. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind  at any time and ask us to stop sending you marketing messages at any time by writing to or emailing us at: info@changetoolbox.com 

Third-party marketing: 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask third parties to stop sending you marketing messages at any time by contacting them.   

Your legal rights: 

Please be aware that you have the following data protection rights:

 • The right of access to the personal data Changetoolbox Ltd processes on you 

This means you can request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you would like a copy of the information held on you, please contact us at: 

info@changetoolbox.com    

 • The right to rectification of your personal data 

This means you can request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

If you believe that any information we hold on you is incorrect or incomplete, please write to or email us as soon as possible, at: info@changetoolbox.com and we will promptly correct any information found to be incorrect. 

 • The right to erasure of your personal data in certain circumstances 

This means you can request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

The right to restrict processing of your personal data

This means you can request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

 ·        If you want us to establish the data's accuracy. 

 ·        Where our use of the data is unlawful, but you do not want us to erase it. 

 ·        Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 

 ·        You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. 

 • The right to data portability in certain circumstances 

This means you can request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

 • The right to object to the processing of your personal data that was based on a public or legitimate interest 

This means you can object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

 • The right to withdraw consent at any time 

This means you can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services, tools to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to withdraw your consent, please contact us by writing to us at: info@changetoolbox.com

Data retention - how long will you use my personal data for? 

 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

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, regulatory, tax, accounting or other requirements. 

Cookies: 

To enrich and perfect your online experience, we use "Cookies", similar technologies and services provided by others to display personalised content, appropriate advertising and store your preferences on your computer. 

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Our Website uses cookies to help us identify and track visitors, their usage of our Website, Change Community Online platform and their website access preferences. Changetoolbox Ltd visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our Website, with the drawback that certain features of Changetoolbox Ltd websites may not function properly without the aid of cookies. By continuing to navigate our website without changing your cookie settings, you hereby acknowledge and agree to our use of cookies. 

Privacy Policy changes: 

Although most changes are likely to be minor, we may change its Privacy Policy from time to time, and this is at our sole discretion. 

We encourage visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such changes.

Complaints or queries:  

If you wish to complain about this Privacy Policy or any of the information set out in it please contact us by writing to us at: info@changetoolbox.com 

You can also complain to the ICO if you are unhappy with how we have used your data. 

The ICO’s address: 

Information Commissioner’s Office 

Wycliffe House 

Water Lane 

Wilmslow 

Cheshire 

SK9 5AF

Helpline number: 0303 123 1113   

Glossary: 

LAWFUL BASIS 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/products/tools and the best and 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 us, by writing to us at: info@changetoolbox.com 

Performance of Contract 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.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

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