The Circle Line

Privacy

About this policy

This privacy policy sets out how The Circle Line Limited (“we”, “us”, “our”) uses and protects any personal data that you give us when you use the website at www.thecircleline.co.uk or otherwise engage with our services. 

Your data is important to us and we are committed to safeguarding your information in accordance with data protection and privacy laws. We want you to know what information we collect, how we use it and how you can control what we do with this information. If you have any questions about this privacy policy including any requests to exercise your legal rights, please contact us (see “Our Contact Details” section below).

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. You can also obtain historic versions of our privacy policy by contacting us. This policy is effective from 2 December 2019. 

What information we collect

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

proof of identity, home address, details of your qualifications and accreditations, name of your supervisor and details of your professional experience; 

information from third parties to verify the information you have provided; and 

feedback in relation to the services we provide.

We may also collect, use and share aggregated data for any purpose. Aggregated data could be derived from your data but will not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific service feature. However, if we combine or connect aggregated data with your data so that it can directly or indirectly identify you, we treat the combined data as your data which will be used in accordance with this privacy policy.

What data does The Circle Line collect and what data do Practitioners collect? 

Practitioners keep short, written notes on sessions where appropriate and store those securely. The Circle Line does not have access to any data disclosed during a session to Practitioners, or any personally identifiable information (PII) that is not disclosed to The Circle Line in relation to our services. Practitioners are the Data Controllers for any PII and other forms of data you disclose to them.

Practitioners are governed by their accrediting bodies’ code of ethics, including data privacy. You may request Practitioners’ Privacy Policies.

When do we collect this information? 

We collect this information:

How do we use this information?

We will only use your personal data where we have legal grounds to do so. Generally, we will process your data in the following circumstances: 

We have set out in the section below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data:

 

Fulfilment of contract

 

Required in order to comply with legal obligation

 

Processing based on legitimate interests

 

Your consent (which you can withdraw at any time)

 

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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

Marketing

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 or by contacting us at any time. Where you opt out of receiving these marketing messages, we will still continue to use your personal information to provide you with services which may include sending you service messages.

We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

When do we share your information? 

We do need to share your data with other parties in some circumstances. We pass information about you to other parties as follows:

Service providers based outside Europe

We use third party service providers to enable us to provide services to you. These third parties are only allowed access to your information as needed for the relevant element of the services. They’re not allowed to use it for any other purpose. Some of these third party companies are located, or have servers that are located outside the UK and European Economic Area. Where we share your information with such companies, we take all steps reasonably necessary to ensure your information is treated securely and in accordance with this privacy policy.

However, please note that the data protection and other laws of such countries may not be as comprehensive as those in the UK or European Economic Area. We’ll only transfer your personal information to a territory outside of the UK or European Economic Area under the following circumstances:

Please note that our website may contain links to other websites. Please note that we do not have any control over those other websites and we are not responsible for the protection and privacy of any information which you provide whilst visiting such sites. Please exercise caution and look at the privacy statement applicable to that website.

Changes to our business

If we decide to change or restructure our business we may need to pass your personal information to another company so we can continue to effectively deliver the products and services to you.

Also, if we become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our assets, then your information may be included in the assets that are transferred to the new owner and may be provided to the entities and advisors involved. Such a transaction could involve us: (i) retaining the right to continue to use transferred personal information in addition to the right of the new owner to use such information; and (ii) engaging in additional transfers of personal information (including new personal information) with the new owner from time to time following such a transaction.

If there are changes to our business (such as a re-organisation or restructuring), your personal information will remain subject to this privacy policy (as amended from time to time). However, where your personal information is transferred to a new owner following a merger or acquisition it may be subject to a different privacy policy. We, or the new owner, will provide notice to you before any of your personal information becomes subject to a different privacy policy. 

Security

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. 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. 

Please note that you must keep your password confidential. If you have any concerns that your account, password or personal information has been put at risk, please contact us straight away.

Cookies

We may ask for your permission for a small file called a cookie to be placed on your computer’s hard drive. If you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website and better experience, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

How long do we keep your information?

We keep your information for only as long as necessary. The length of this retention period depends on the purpose for which the data was obtained and its nature. For example: 

What are your rights?

You can see the personal information we hold about you when you log in to your account. We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. This means you have the right to:

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 could refuse to comply with your request in these circumstances.

Changes to Policy

We may amend and update this policy from time to time, and any changes in the future will be posted on this page. 

The date of the latest update to this privacy policy is set out at the top of this policy.

Our Contact Details

TCL is The Circle Line London Limited (t/a The Circle Line), a limited company registered in England and Wales under company number 12147684, VAT reg number 331 7386 05, with registered address at Kemp House, 160 City Road, London EC1V 2NX. 

Please contact us with any questions or comments about this policy or to contact us about your personal data issues by email at [email protected].

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