Privacy policy and GDPR compliance
1. What information do we collect and what do we do with it?
When you enroll as a student or subscriber (“learner”) on our site or related courses, as part of the enrolling process, we collect the personal information you give us such as your name and email address.
Email marketing: we may send you emails about our site and related course(s), registration, course content, your course progress or other updates. We may also use your email to inform you about changes to the course, survey you about your usage, or collect your opinion.
2. How do you get my consent?
When you provide us with personal information to become a learner on our site, make a purchase, or participate in the course, you imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at [email protected]
3. Disclosure
We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service
4. Thinkific
Our course and site is hosted by Thinkific Labs Inc. (“Thinkific”). They provide us with the online course creation platform that allow us to sell our product/services to you.
Your data is stored through Thinkific’s data storage, databases and the general Thinkific application. They store your data on a secure server behind a firewall.
Payment:
If you make a purchase on our site, we use a third party payment processor such as Stripe or Paypal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.
For more insight, you may also want to read Thinkific’s Terms of Service here https://www.thinkific.com/resources/privacy-policy/ or Privacy Statement here https://www.thinkific.com/resources/terms-of-service/ .
5. Third Party Services
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
Once you leave our course website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.
Links
When you click on links on our course site, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
6. Security
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
Cookies
We collect cookies or similar tracking technologies. This means information that our website’s server transfers to your computer. This information can be used to track your session on our website. Cookies may also be used to customize our website content for you as an individual. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer.
We use cookies to recognize your device and provide you with a personalized experience.
We also use cookies to attribute visits to our websites to third-party sources and to serve targeted ads from Google, Facebook, Instagram and other third-party vendors.
Our third-party advertisers use cookies to track your prior visits to our websites and elsewhere on the Internet in order to serve you targeted ads. For more information about targeted or behavioral advertising, please visit https://www.networkadvertising.org/understanding-online-advertising.
Opting out: You can opt out of targeted ads served via specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page.
We may also use automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
Web Analysis Tools
We may use web analysis tools that are built into the BUSINESS NAME website to measure and collect anonymous session information.
7. Age of Consent
By using this site, you represent that you are at least the age of majority in your state or province of residence, or country or that you are the age of majority in your state or province of residence.
8. Changes to this Privacy Policy
We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
If our site or course is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
QUESTIONS AND CONTACT INFORMATION
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact us at [email protected]
GDPR notice
Privacy Policy
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.vivienscreativitylab.thinkific.com
By providing us with your data, you warrant to us that you are over 13 years of age.
Vivien Capper is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full contact details are:
Full name: Vivien jane Capper
Email address: [email protected]
Postal address: 27 Via Tanaro, Ardea, (Rome), Italy 00040
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would be extremely grateful if you would contact us first if you do have a complaint so that we, together with thinkific who hosts the course can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing: [email protected]
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through email, text, social media messaging, social media posting or any other communication that you send us via the thinkific.com website or vivienscreativitylab.thinkific.com website . We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our online course.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our online course and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our online course and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business of online learning. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests .
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at vivienscreativitylab.thinkific.com or thinkific.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required by law.
We do not carry out automated decision making or any type of automated profiling.
3. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this: vivienscreativitylab.thinkific.com/cookie-policy
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources based inside the EU.
4. MARKETING COMMUNICATIONS
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time contacting the course platform thinkific.com
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or or by emailing us at thinkific.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
Service providers who provide IT and system administration services. (In our case our service platform provider thinkific.com)
Professional advisers, government bodies, lawyers etc.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7. DATA SECURITY
The service provider thinkific.com have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
The service provider thinkific.com have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
8. DATA RETENTION
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.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at vivienscreativitylab.thinkific.com or thinkific.com
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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
10. THIRD-PARTY LINKS
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.
11. COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see: vivienscreativitylab.thinkific.com/cookie-policy