PRIVACY POLICY – PRACTIVE LIMITED
BACKGROUND:
Practive Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://practive.net, and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law
Please read this Privacy Policy carefully and ensure that you understand it.
1. Information About Us
Our Site is owned and operated by Practive Limited, a Limited Company registered in England under company number 04568820.
Registered address: 28 Wilton Road, Bexhill On Sea, East Sussex, England, TN40 1EZ
Main trading address: 86-90 Paul Street, London EC2A 4NE
VAT number: 805311078
Our site is hosted and maintained by Bluequest Creative Services Ltd: https://bluequest.co.uk/privacy-policy
For Data Protection queries please contact:
Email address: info@practive.net
Telephone number: 020 8699 9524
Postal address: 86-90 Paul Street, London EC2A 4NE
2. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site and our business communications with you under Legitimate Interest. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
3. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office (https://ico.org.uk)
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Our website is not intended for children and we do not knowingly collect any personal data relating to children.
| Data Collected | How We Collect the Data |
| Identity Information including name, job title, gender. | Direct interaction – you may give us your identity and contact data when you interact with our website, contact us about delivery or take part in one of our sessions. |
| Contact information including address, email address, telephone numbers. | Direct interaction – you may give us your identity and contact data when you interact with our website, contact us about delivery or take part in one of our sessions. |
| Business information including business name, job title, profession. | Direct interaction – you may give us your identity and contact data when you interact with our website, contact us about delivery or take part in one of our sessions. |
| Technical information such as internet protocol (IP) address, browser specifications, system information and device specification via the devices you use to access our website. | Direct interaction - we collect this information from the devices you use to access our website. |
| Data from third parties including technical information, contact information, profile information. | Identity and contact information - from our client which can be based inside or outside the UK, from publicly available information from Companies House, Information Commissioner’s Office, LinkedIn and the Electoral Register based inside the UK. |
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how may use your personal data, and our lawful bases for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
| Administering Our Site. | IP address, operating system, browser and device specifications. | Legitimate Interest for business access. |
| Administering our business and managing our relationship with you. | Identity and contact details. | Legitimate interest to enable delivery function. |
| Supplying our services to you. | Identity, financial and contact details. | Legitimate interest to enable delivery function. |
| Managing payments for our services. | Identity, financial and contact details. | Legitimate interest to enable payment processes. |
| Personalising and tailoring our services for you. | Identity and contact details. | Legitimate interest to enable bespoke delivery and attendance feedback. |
| Communicating with you. | Identity and contact details. | Legitimate interest to deliver services. |
| Supplying you with information by email that you have opted-in-to (you may opt-out at any time via email or an unsubscribe button). | Identity and contact details. | Legitimate interest to deliver services, inform and evaluate delivery. |
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by emailwith information, news, and offers on products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, wemay process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
| Type of Data | How Long We Keep It |
| Identity Information including name, job title, gender. | As long as reasonably necessary to fulfil the purposes for which we collected it and/or for business continuity. |
| Contact information including address, email address, telephone numbers. | As long as reasonably necessary to fulfil the purposes for which we collected it and/or for business continuity. Legal Obligation. |
| Business information including business name, job title, profession. | As long as reasonably necessary to fulfil the purposes for which we collected it and/or for business continuity. |
| Technical information such as IP address, browser type and version, time zone settings, operating system/platform and technology via the devices you use to access our website. | As long as reasonably necessary to fulfil the purposes for which we collected it and/or for business continuity. |
| Data from third parties including technical information, contact information, profile information. | As long as reasonably necessary to fulfil the purposes for which we collected it and/or for business continuity. |
8. How and Where Do You Store or Transfer My Personal Data?
We store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation,
AND
We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
AND
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
Please contact us using the details below in Part 12 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
The security of your personal data is essential to us and, to protect your data, we take a number of important measures, including the following:
• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions;
We sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. We may sometimes contract with the following third parties to supply certain products AND services.
| Recipient | Activity Carried Out | Sector | Location |
| Microsoft Office 365 | Productivity, file storage, meetings and diary management. | We use Office 365 Suite and its associated applications to send and receive emails, create and manage documents, to manage schedules, to manage presentations. | UK |
| Google Workspace | Productivity. | We use Google Workspace and its associated applications to manage documents, spreadsheets, file storage. | USA |
| Zoom | Online meetings. | We use Zoom to host meetings, interviews, training, coaching sessions. | Holland, Germany and Ireland |
| LinkedIn Ads | Online marketing. | We use our LinkedIn Company page and our staff connections to promote Practive on LinkedIn, acquire new customers and engage with our followers. | UK and US |
| Online marketing. | We use our Twitter Account to promote Practive and engage with our followers. | UK and US | |
| Online marketing. | We use our Facebook Page to promote Practive and engage with our followers. | UK and US | |
| Mailchimp | Email marketing service. | We use Mailchimp for communicating with staff and Contractors. | US |
| Dropbox | sFTP. | We use Dropbox to send files securely to our clients and contractors. | UK |
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally,we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, or you have made multiple requests it may take us longer. In this case, we will notify you and keep you updated.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: info@practive.net
Telephone number: 020 8699 9524
Postal Address: 86-90 Paul Street, London EC2A 4NE
12. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up to date.
This Privacy Policy was last updated on 29th June 2022.