We teach practical, innovative, lifelong learning skills for everyone to reduce stress, increase resilience and promote adaptability. Turn life’s challenges into personal growth.
Charity no: 1107527 | Registered no: 04756998
Privacy Policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
2. Credit
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
3. How we use your personal data3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process; and
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, gender, date of birth, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
3.5 We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include that related to Emotional Logic tools usage and course materials access. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.6 We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.8 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
3.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis 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 and our legitimate interests, namely the proper administration of our website and business.
3.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis 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.
3.11 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4.3 Financial transactions relating to our website and services are handled by our payment services providers, stripe.com. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) “account data”, “profile data”, “service data”, “publication data”, “enquiry data”, “customer relationship data”, “transaction data”, “notification data”, “correspondence data” will be retained indefinitely, until you inform us that you no longer require to be a member of the Emotional Logic lifelong learning method community.
(b) “usage data” will be retained for a maximum period of two years following access to our websites or services.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this policy by email or through the private messaging system on our website.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you object to the processing under certain rules of applicable data protection law; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10. Cookies that we use
10.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: laravel_session);
(b) status – we use cookies [to help us to determine if you are logged into our website (cookies used for this purpose are: remember_web_<generated id>);
(c) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: XSRF-TOKEN);
11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: _ga.
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 This website is owned and operated by The Foundation for Growth Through Grieving.
13.2 We are registered in England and Wales under Company Number 4756998, and our registered office is at South Highlands, Blachford Road, Ivybridge, Devon, PL21 0AD.
13.3 Our principal place of business is at South Highlands, Blachford Road, Ivybridge, Devon, PL21 0AD.
13.4 You can contact us: (a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
14. Data protection registration
14.1 Our data protection officer’s contact details are: Data Protection Officer, contactable at office@emotionallogiccentre.org.uk.
14.2 We are registered as a data controller with the UK Information Commissioner’s Office. Our data protection registration number is ZA278332.
14.3 Our Legitimate Interests Assessment (LIA) dated 16th April 2018 is detailed below:
Purpose test
The Charitable Purposes of The Foundation For Growth through Grieving (trading as the Emotional Logic Centre – ELC) are:
- The relief of any persons who are in conditions of poverty or sickness arising from grieving, and the prevention of any sickness which may arise from grieving.
- The advancement of the education of the public in the nature of grieving and the provision of suitable training for persons wishing to learn about or work with unrecognised aspects of grieving.
- The promotion of religious and cultural harmony, in particular where relationships have broken down as a result of unrecognised aspects of grieving.
The ELC vision is: “One day, people everywhere will feel empowered to harness their unpleasant emotions during times of change or hurt, and turn them to constructive, useful purposes,”
and ELC mission is: “To train and support networks of skilled practitioners who enable individuals and families to learn practical life skills that help to turn the stress of unpleasant emotions into an ability to build adaptability and stronger relationships.”
Processing of data is all targeted at achieving the above aims and objectives, where grieving is not restricted just to bereavement through death but rather applies to any situation of loss. Emotional Logic was developed by a doctor as a lifelong learning, ‘home-or-workplace’ conversational method quite akin to systemic family therapy. It helps people of all ages to understand how unpleasant loss emotions have useful purposes when seen as part of an integrated process of adjusting to change, disappointment, setback or hurt. When one member of a family learns this way to understand and talk about emotions, he or she can teach it to others in the family, so a spreading wave of understanding can transform the atmosphere and social environment for growing children. Emotional Logic provides a solution-focused approach to managing distress, tension or confusion. It brings feelings and reasoning into a constructive partnership that leads to a values-based action plan. It is not counselling or therapy. It is a transferable life skill that builds relationship anywhere, anytime. The Emotional Logic Centre provides training for all ages to understand emotions in this constructive way.
The Emotional Logic Centre continues to research and develop new methods and tools to communicate the EL method well. As a lifelong learning method, we process data to inform those who have expressed an interest through any communication channel of access to training, whether that be tried and tested, or innovative new, courses or materials that help people find greater freedom and adaptability in life. The individual person benefits through being provided awareness of opportunities to extend their lifelong learning practice of the EL method; the ELC benefits in being able to propagate understanding of the method through wider areas of society. The ripples of such lifelong learning can positively impact workplace, homelife, education and healthcare arenas, and can be cross-generational. As an example, in a time where many studies consistently raise awareness of the prevalence of anxiety and depression causing significant distress and debilitation across many sectors of our society, without regard to age, socio-economic, cultural or any other delineating factor, it is critically important to be able to share good information about interventions that have great track record of having positive outcome to greater resilience and adaptability.
Without ability to share information about EL, the method and associated breakthrough tools and training would remain unharnessed for the good of society. ELC has no intention to use any data in any unethical or unlawful way and is simply genuinely interested in getting the good news as far and wide as possible in support of the stated charitable aims and vision/mission stated.
Necessity test
The processing of personal data is necessary to share information about access to the EL method lifelong learning opportunities. Since this is person-focussed lifelong learning, personal communications to individuals is absolutely reasonable, as ELC aims to be person-centric as an organisation, sharing information about learning opportunities only to those to whom the specific opportunity is deemed pertinent. Experience has shown us that generic advertising of training opportunities does not reach well at all those who have already expressed interest in EL, nor connect well with those people who would most obviously benefit from accessing the method; rather, personal contacts have had the most helpful outcomes. ELC also seeks to understand the effectiveness of its training opportunities and from time to time will solicit feedback from learners about their experiences.
Balancing test
As a person-centric organisation, the relationships of individuals to the ELC organisation are invariably based on personal conversations during which individuals have expressed interest to learn more. Notwithstanding a few exceptions (see below), data stored is of a very generic nature related to contact details and the nature of any contracts (purchases) made and any conversation had about further learning opportunities. ELC considers it reasonable to keep records of conversations about an individual’s learning progress in order to be able to share information about further opportunities for growth or practice of the method, and ELC is happy to explain this policy to individuals upon request. ELC does not find it at all likely, especially given the anticipated volume of sharing information, that individuals would object or find communications intrusive; there would be limited impact to the individual that may take the form of very occasional telephone, email or written letter interrupts.
Data pertaining to individual Personal Learning Appointments, in which a tutor helps to guide the self-help learning of an individual, inevitably causes more personal information to surface and those data will be handled accordingly; these appointments can apply to both adults and children and may include vulnerable individuals. All are treated with equal sensitivity and privacy.
ELC firmly believes the minor impact to an individual of the data stored and any learning opportunity notification is minimal compared to the potential of having the EL method positively impact both their lives and the social networks within which they live and breathe.
ELC can offer an opt-out to any individual who desires to cease their learning of EL or notification of further opportunities to do so.
ELC confirms that “Legitimate interests” is the most appropriate lawful basis for processing, outside of “Contracts” that applies to data processing for training services or resources sold through ELC’s website, events or network of skilled practitioners. We understand our responsibility to protect the individual’s interests, and have conducted the legitimate interests assessment (LIA) above to ensure that we can justify our decision. We have identified the relevant legitimate interests, and have checked that the processing is necessary and there is no less intrusive way to achieve the same result. We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests. We only use individuals’ data in ways they would reasonably expect, unless we have a very good reason. We are not using people’s data in ways they would find intrusive or which could cause them harm, unless we have a very good reason. If we process children’s data or those of vulnerable adults, we take extra care to make sure we protect their interests. We have considered safeguards to reduce the impact where possible. We have considered whether we can offer an opt out. If our LIA identifies a significant privacy impact, we have considered whether we also need to conduct a DPIA. We keep our LIA under review, and repeat it if circumstances change. We include information about our legitimate interests in our privacy information.