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©2019 by The Natural Learning Company Ltd..

The Natural Learning Company (TNLC) Privacy Policy

Introduction

TNLC respects your privacy and is committed to protecting your personal data. This privacy notice describes how your personal data is collected, handled, and stored to meet TNLC’s protection standards—and to comply with the law.

1. Purpose of This Privacy Notice

This privacy notice describes how TNLC collects and processes your personal data through your use of this website and the services on it, including any data you may provide.

This website is not intended to be used by children; TNLC does not knowingly collect personally identifiable information from children.

It is important that you read this privacy notice, together with any other privacy notice or fair processing notice provided when personal data is collected or processed, so that you are fully aware of how your data is used. This privacy notice is supplemental to any other notice and is not intended to override.    

Controller



This privacy notice is issued on behalf of TNLC. Reference to " TNLC," "we," "us," or "our" in this privacy notice implies TNLC, who is responsible for processing your data. Unless otherwise stated, TNLC is the controller of this website.

TNLC’s data privacy manager will respond to questions regarding this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact TNLC using the details provided below: 

Contact Information

Email Address:   enquiries@thenaturallearningcompany.co.uk

Postal Address:  Park View, Bracon, Belton, North Lincs DN91QP UK   

You have the right to file a complaint at any time with the Information Commissioner's Office (ICO), the supervisory authority for data protection issues. However, we would appreciate the opportunity to resolve your concerns before you approach the ICO, so please consider contacting us first. 

Changes to the Privacy Notice and Request for Current Data

It is important that the personal data we hold about you is accurate and current. Please notify us of any changes to your personal information during your relationship with us.

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.



2. Data Collection

Personal data or information means any information about an individual from which that person can be identified. It does not include data where identity is removed (anonymous data).

We may collect, use, store, and transfer a variety of personal data, including:


  • Identity Data, including first name, last name, username, or similar identifier, title, date of birth and gender.

  • Contact Data, including email address and telephone numbers.

  • Technical Data, including internet protocol (IP) address, your login data, browser type and version, time zone and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website and our services.

  • Profile Data, including your username and password, preferences, feedback, and survey responses.

  • Usage Data, including information on how you use our website and services.

We also collect, use, and share 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 by law as this data does not reveal your identity, either directly or indirectly. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if by combining Aggregated Data with your personal data directly or indirectly identifies you, we treat the combined data as personal data and subject to the terms of this privacy notice.

Failure to Provide Personal Data



Where collection of personal data is required by law or under the terms of a contract with you or your employer on your behalf, failure on your part to provide the requested data may impede the performance of the contract. You will be notified if cancellation of the contracted service is necessary in this situation.    



3. Personal Data Collection

Data is collected through various methods, including:



Direction interaction, including personal Identity and Contact Data entered to complete a form, or in correspondence via post, phone, email, or otherwise. Included is personal data provided when you:

  • Create an account or make a purchase on our website;

  • Subscribe to our service, or

  • Provide feedback.



Automated technologies or interactions, including Technical Data about your equipment, browsing actions, and patterns. Personal data is collected using cookies, server logs, and other similar technologies. Collected information is used to help diagnose problems with our server and to administer our website, and allows us to deliver content tailored to your interests. We may also receive Technical Data about you when you visit other websites using our cookies.



Third parties or publicly available sources, including personal data (Identity, Contact, and Profile Data) supplied by you or your employer to enable us to provide services via our website. 



4. Using Your Personal Data

Use of your personal data is limited by law. Most commonly, personal data is used:



·       To allow us to fulfil a contract entered into with you or your employer.

·       Where it is necessary for our legitimate interests (or those of a third party), if your interests and fundamental rights do not override those interests.

·       To comply with legal or regulatory obligations. Click https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en to learn more.

·       Generally speaking, we do not rely on your consent as a legal basis to process your personal data, except in sending direct marketing communications via email or text message. You may withdraw consent to receive these marketing messages at any time by contacting us             at: enquiries@thenaturallearningcompany.co.uk

Your personal data may be processed for more than one lawful ground, depending on the specific purpose for its use. Please contact us at enquiries enquiries@thenaturallearningcompany.co.uk if you require additional information.    

Purpose/Activity

Registration as a new user


Types of Data

  • Identity

  • Contact


Lawful Basis

  • Performance of a contract with your employer


Purpose/Activity

To manage our relationship with you, including:

  • Notification of changes in our terms or privacy policy

  • Request for feedback


Types of Data

  • Identity

  • Contact

  • Profile


Lawful Basis

  • Performance of a contract with your employer

  • Compliance with a legal obligation

  • Legitimate interests (to maintain current records and evaluate use of services)


Purpose/Activity

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)


Types of Data

  • Identity

  • Contact

  • Technical


Lawful Basis

  • Legitimate interests (to run our business; provision of administration and IT services; network security; fraud prevention; business reorganisation; restructuring exercise)

  • Legal compliance


Purpose/Activity

To use data analytics to improve our website, services, customer relationships and experiences


Types of Data

  • Technical

  • Usage


Lawful Basis

  • Legitimate interests (to define types of customers for our products and services; website relevance; business development and strategy)

Using your Personal Data

Cookies

Your preferred browser can be set to refuse all or some browser cookies, or to alert you when websites set or access cookies. If cookies are disabled or refused, some parts of the website may be inaccessible or fail to function properly.


Change of Purpose

Personal data is collected and used for a specific purpose, unless we determine its use for another reason is compatible. Please contact us at enquiries @therealorganisation.com to receive an explanation of how processing for another purpose meets that criteria.


If your personal data must be used for an unrelated purpose, we will notify you and explain the legal basis that allows its use.


We may process your personal data without your knowledge or consent, in compliance with the rules stated above, where required or permitted by law.


5. Disclosure of Personal Data

We may be required to share personal data with the parties listed below for the purposes identified in the table provided in “4. Using Your Personal Data” above.

  • Internal Third Parties as defined in the Glossary

  • Third parties to whom we may choose to sell, transfer, or merge part of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change to our business occurs, new owners may use personal data in the same manner as set out in this privacy notice.

We require all third parties to respect the security of your personal data and treat it in accordance with the law. Third-party service providers are not allowed to use your personal data for their own purposes. Use of personal data is permitted only for specified purposes and must be in accordance with our instructions.

 

6. Data Security

Appropriate security measures are in place to prevent personal data from accidental loss, misuse, alteration, or unauthorized disclosure. Additionally, access to personal data is limited to those employees, agents, contractors, and third parties who are authorized to process the data on our behalf, under specific instruction, and subject to a duty of confidentiality.



Procedures are in place to deal with any suspected personal data breach. You and, if legally required, any applicable regulator will be notified of a breach.



7. Data Retention

Your personal data will be retained only as long as necessary to fulfil the purpose(s) for which it was collected, including legal, accounting, or reporting requirements.

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.

Law requires that we keep basic information about our customers (including Contact, Identity, and Transaction Data) for six years following the last use of the website and/or services for liability and tax purposes.

In some circumstances, you can ask us to delete your data. See Request Erasure below for further information.

We may anonymize personal data (to remove any association with personal identity) for research or statistical purposes, in which case the information may be used for an indefinite period without further notice to you.    

8. Your Legal Rights

Under certain circumstances, you have rights relating to your personal data under the General Data Protection Regulation (GDPR). Click on this link to find out more about these rights: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en



If you choose to exercise any of the rights contained in GDPR, please contact us at enquiries@thenaturallearningcompany.co.uk

These rights are subject to certain exceptions and exclusions, and we may be unable to comply in full with your request.


Fees

You are not required 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.



Request for Specific Information

We may 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 security measure ensures that personal data is not disclosed to an unauthorized person. We may also contact you to ask you for additional information to speed up our response.

Response Time

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer if your request is particularly complex. In this case, we will notify you and keep you informed. 

9. Glossary

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 at enquiries@thenaturallearningcompany.co.uk

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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation.