1.1. Interact respects your privacy and is committed to protecting your Personal Data. This privacy notice will inform you as to how we look after your Personal Data when you make contact with us (as an associate, client or website visitor) and tells you about your privacy rights and how the law protects you.
2. Important Information and who we are
2.1. Interact specialises in training and development of communication skills in the workpace, using theatre-skills to deliver a practice-based learning experience. We use freelance associates with acting backgrounds to deliver programmes for our clients. We operate in both the UK and international markets, with our offices based in Southwark, London.
3. The purpose of this privacy notice
3.1. This privacy notice aims to give you information on how Interact collects and processes your Personal Data through it’s services, including any data you may provide through working as an associate, using our consultancy services, or entering information through this website.
3.2. Our services are not intended for any user under the age of 13 and we do not knowingly collect data relating to them.
3.3. It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
4.1. IRP Ltd. t/a Interact. and its affiliates is the controller and responsible for this website and your Personal Data (collectively referred to as “we”, “us”, “Interact” or “IRP Ltd” in this privacy notice).
4.2. If you have any questions or concerns in regards to what is stated here, you are welcome to contact us directly on email@example.com
5. Changes to the privacy notice and your duty to inform us of changes
5.1. This version was last updated on 16th May 2018.
5.2. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
6. Third-party links
6.1. Our 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.
7. The data we collect about you
7.1. Personal data, or personal 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).
7.2. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:
7.2.1. Identity Data includes first & last name, Company, job title.
7.2.2. Contact Data includes registered addresses, email address and telephone numbers.
7.2.3. Financial Data includes bank account details for making payments through invoices for chargeable services
7.2.4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
7.2.5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
7.2.6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
7.2.7. Usage Data includes information about how you use our website, products and services.
7.2.8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
7.2.9. We may also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy notice.
7.3. We do not collect any Special Categories of Personal Data about you whilst you visit our website (this 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). Nor do we collect any information about criminal convictions and offences.
8. If you fail to provide Personal Data
8.1. Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
9. How is your Personal Data collected?
9.1. We use different methods to collect data from and about you including through:
9.1.1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes Personal Data you provide when you:
9.1.2. applying for our products or services;
9.1.3. creating an account on our website;
9.1.4. request marketing to be sent to you;
9.1.5. give us some feedback.
9.2. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies.
10. How we use your Personal Data
10.1. We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
10.1.1. Where we need to perform the contract we are about to enter into or have entered into with you.
10.1.2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
10.1.3. Where we need to comply with a legal or regulatory obligation.
(see below to find out more about the types of lawful basis that we will rely on to process your Personal Data)
10.2. Generally we do not rely on consent as a legal basis for processing your Personal Data.
11. Purposes for which we will use your Personal Data
11.1. We have set out below a description of the ways we may use your Personal Data. We must use your data only on a lawful basis and may do so to fulfil a contract we have with you; to comply with legal obligations; to lawfully gain information to help us develop our services; to monitor how our website is being used; for marketing and communications purposes to keep you informed of developments and new products; to identify issues with our website etc. that we need to fix.
11.2. We undertake the following activities (this is not an exhaustive list) which may involve your data:
11.2.1. We register you as a new customer
11.2.2. We provide you access to something you have paid for (a product or service)
11.2.3. We need to process payments for the services we have provided to you
11.2.4. We can contact you to discuss our services or the progress of particular tasks we’re undertaking for you
11.2.5. We can use software analytics to evaluate the performance of our site and improve the customer experience
12.1. 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 and offers may be relevant for you (we call this marketing).
12.2. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us registered for an event, in each case, you have not opted out of receiving that marketing.
12.3. We will not supply your details to any company outside Interact for marketing purposes. Currently only we will contact you for marketing purposes. If in the future we ask a third party approved by us to contact you in order to fulfil the services we provide to you we will ensure that we have a GDPR agreement with that third party regarding the use of any data we supply them about you for the purposes of their contacting you.
13. Opting out
13.1. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you by contacting us at firstname.lastname@example.org.
13.2. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. Please see right of erasure.
15. Change of purpose
15.1. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
15.2. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
15.3. If all or part of IRP Ltd. t/a Interact is sold, merged or is otherwise transferred to another entity, the information you have provided through the web site may be transferred to such entity as part of that transaction.
15.4. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
16. Disclosures of your Personal Data
16.1. If the need arises, and there is a lawful basis for doing so, 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.
17. International transfers
17.1. We do not currently transfer your Personal Data outside the European Economic Area (EEA), however we may employ services based in markets outside the EEA, where we ensure that they hold data protection legislation that is adequate to comply with the contractual obligations we go by.
18. Data security
18.1. Our Data Protection Policy describes the security measures we have taken 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.
18.2. 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.
19. Data retention
19.1. 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.
19.2. 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 requirements.
19.3. Details of retention periods for different aspects of your Personal Data are available in our retention policy which you can request from us by Contacting us
19.4. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
19.5. In some circumstances you can ask us to delete your data: see below for further information.
19.6. In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
20. Your legal rights
20.1. Under certain circumstances, you have rights under data protection laws in relation to your Personal Data including to:
20.1.1 Requesting access to your Personal Data (commonly known as a “data subject access request”) which enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
20.1.2. Requesting correction of the Personal Data that we hold about you which 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.
20.1.3. Requesting erasure of your Personal Data which 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.
20.1.4. Objecting 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.
20.1.5. Requesting a restriction of processing of your Personal Data which enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
20.1.6. Requesting the transfer of your Personal Data to you or to a third party means 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.
20.1.7. You can withdraw your 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 to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us on firstname.lastname@example.org.
21. No fee usually required
21.1. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
22. What we may need from you
22.1. 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
23. Time limit to respond
23.1. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
24. Glossary – Lawful Basis
24.1. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.
24.2. 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.
24.3. Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
25. Third parties - External Third Parties
25.1. Service providers acting as data processors based in the United Kingdom who provide IT, cloud-based software and system administration services.
25.2. HM Revenue & Customs, Disclosure and Barring Service, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
26. Contact us