1st Formations Privacy Policy

This website is owned and operated by 1st Formations Limited (“we”, “us”, “our”, and “ourselves”).

We are committed to protecting the privacy and security of your personal data. This Privacy Policy describes how we collect, use and store your personal data when you visit our website (regardless of where you visit it from), including when you purchase a product or services or sign up to our newsletter. It also tells you about your rights and how the law protects you.

1. Important information

• Our website is not intended for children and we do not knowingly collect data relating to children.
• This Privacy Policy supplements the other policies (including our terms of use (Terms)) and is not intended to override them.
• We are the controller and responsible for your personal data (we, us or our).
• As we only provide services to corporate entities rather than individuals, we treat all website users and customers who purchase services from us as “corporate subscribers” as defined in the Privacy and Electronic Communications (EC Directive) Regulations 2003. To assist you further in understanding this Privacy Policy, we have set out in Part 5 of Schedule 1 a glossary of terms used, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
• If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us in writing, either:
  • by email to: [email protected]
  • by post to: 1st Formations, 71-75 Shelton Street, Covent Garden, London WC2H 9JQ
• You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
• Your duty to inform us of changes – it is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
• Third-party links - our website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control or liability in respect of these third-party websites, plug in or applications and are not responsible for their privacy policies. You should also read their privacy policies to understand what personal data they collect about you and how they use it.

2. The data we collect about you

• We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.
• We also collect, use and share aggregated data. This is data which does not reveal your identity, so is not classed as personal data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
• We do not collect any special categories of personal data.
• Failure to provide personal data - If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.

3. How personal data is collected

• We collect personal data in the following ways:

  direct interactions	you may provide personal data when you complete online forms, request products/services, subscribe to our services, create a user account, join our mailing lists or correspond with us (by post, phone or email or otherwise).
  automated technology	we automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies. Please see our Cookie Policy here for further details.
  publicly available sources	we may collect personal data from publicly availably sources such as Companies House and the Electoral Register and credit reference agencies, based inside the EU.
  third parties	we may receive personal data from: (a) analytics providers based outside the EU (such as Google); (b) advertising networks inside the EU; (c) search information providers inside the EU; and (d) our suppliers such as payment providers, delivery services, website support and maintenance providers based either inside or outside the EU.
  recording of correspondence	we may monitor, record, store and use any telephone, email or other communication with you. This includes those which contain personal data. We do this to check any instructions given to us, for training purposes, to prevent crime, and to improve the quality of our customer service.

4. How we use your personal data

• We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
  • to perform the contract we are to enter into or have entered into with you;
  • to comply with a legal obligation; and
  • where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.
• We may process your data for more than one lawful ground depending on the specific purpose for which we are using your information.
• Marketing – We may analyse your personal data to form a view on what products and or services we think may be of interest to you. You will only receive marketing communications from us, if you have requested information from us or purchased services from us, you have not opted out or we have another legal basis to send you the marketing communications. Please note that as you are a “corporate subscriber” it is not necessary for us to obtain your consent to direct marketing. However, you will always have the option to opt out of receiving direct marketing messages.
• How to opt out - You can opt out of email or SMS marketing by clicking the unsubscribe button within the particular marketing email or message. You can to opt out of direct marketing at any time by contacting us.
• Even if you opt out of receiving direct marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.
• Change of purpose - We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
• 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 use your personal data in this manner.
• We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
• We only rely on consent as a legal basis for processing your personal data when we share personal data with our partners in respect of referrals. In such circumstances, we will ask you to complete a form which will contain the personal data you consent to being provided to such partners. At the time you complete this form, the partner(s) with whom we will share your personal data will be expressly identified (e.g. the name of the bank if it relates to a referral to open a bank account). We will also ask you to consent expressly to this sharing of your personal data by ticking a tick-box. This will include a statement setting out that you consent to the partner contacting you directly. Whenever you have provided consent, you have the right to withdraw your consent at any time by contacting us.

5. Disclosure of your personal data

• We may share your personal data with third parties further details of which are set out in Part 4 of Schedule 1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International transfers

• When sharing your data with third parties as specified in Part 4 of Schedule 1, it may be transferred outside the European Economic Area (EEA).
• Some of our external third parties 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 ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • We use specific contracts approved for use in the UK which give personal data the same protection it has in the UK with our service providers.
• Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data Security

• The security of your personal information is important to us. Please bear in mind, however, that no security system is guaranteed to be 100% secure. Whilst we strive to protect your personal information, 1st Formations cannot guarantee or warrant the security of our servers, nor can we guarantee that information you supply through this website will not be intercepted whilst being transmitted over the Internet. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
• We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
• We have procedures in place 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.

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.
• Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required 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.
• We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.

9. Your legal rights

• You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact us.
• You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
• We may request specific information from you to help us confirm your identity when you contact us. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
• 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.

10. Changes to this Privacy Policy

• We reserve the right to update this Privacy Policy when required by law or at any time we deem necessary to reflect our processes. We encourage you to periodically refer to this policy to remain up to date – upon your first visit to the website following any changes, you are deemed to have accepted the terms of this Policy.

Schedule 1

Part 1: Types of personal data

Part 2: Lawful basis for processing and processing activities

The lawful basis upon which we may rely on to process your personal data are:

Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.

Part 3: Your legal rights

You have the following legal rights in relation to your personal data:

Part 4: Third Parties

Part 5: Glossary