Privacy policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, "we", "us" and "our" refer to Catalyst Editorial Ltd. For more information about us, see section 14.
2. The personal data that we collect
2.1 In this Section, we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers.
2.3 We may process your personal data provided in the course of the use of our services and generated by our services in the course of such use ("service data"). For example, we use Zoom Video Communications, Inc. to schedule meetings and to deliver online training. This service provider collects trainees’ information when they register or attend online training. Its privacy policy can be found here.
2.4 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.5 We may process data about your use of our website and services ("usage data"). This usage data is collected by Squarespace, as explained here https://support.squarespace.com/hc/en-us/articles/360001264507-The-cookies-Squarespace-uses. You can opt out of Squarespace cookies when you first visit our website.
3. Purposes of processing and legal bases
3.1 In this Section, we set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations - We may process your personal data to operate our website, provide our services, to generate invoices, bills and other payment-related documentation. The legal basis for this processing is the proper administration of our website, services and business.
3.3 Communications - We may process contact data, transaction data and/or communication data to communicate with you by email, SMS, post, fax and/or telephone. The legal basis for this processing is the proper administration of our website, services and business.
3.4 Research and analysis - We may process usage data to research and analyse the use of our website and services. The legal basis for this processing is to monitor, support, improve and secure our website, services and business generally.
3.5 Record keeping - We may process your personal data to create and maintain our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests in properly and efficiently running our business in accordance with this policy.
3.6 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the assertion of our legal rights, your legal rights and the legal rights of others.
3.7 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.2 We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 The hosting facilities for our website are provided by HostPapa, which is situated in Canada. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of Canada. For more information, see HostPapa’s privacy policy here.
6. Retaining and deleting personal data
6.1 This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Contact data will be retained for a maximum period of three years following the date of the most recent contact between you and us;
(b) Transaction data will be retained for a maximum period of ten years following the date of the transaction;
(c) Communication data will be retained for a maximum period of three years following the date of the most recent contact between you and us; and
6.4 If you grant to us a licence to publish any of your personal data, we may continue to retain and publish that personal data after the end of the relevant retention period specified in this Section 7 in accordance with the applicable licence terms, subject to your data subject rights. If we cease to publish such personal data after the end of the relevant retention period specified in this Section 7, that personal data will be retained for a maximum period of three years following the date that publication ceases.
6.5 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
7.3 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8. Your rights
8.1 In this Section, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Personal data of children
10.1 Our website and services are targeted at persons over the age of 18.
10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
11. Updating information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
12. Acting as a data processor
12.1 In respect of usage data and service data, we do not act as a data controller; instead, we act as a data processor.
12.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
13. Amendments
13.1 We may update this policy from time to time by publishing a new version on our website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
14. Our details
14.1 This website is owned and operated by Catalyst Editorial, Ltd.
14.2 We are registered in England and Wales under registration number 9257127, and our registered office is at First Floor, 40 Eastgate Street, Bury St Edmunds, IP33 1YW, Suffolk, UK.
14.3 You can contact us by email: enquiries[at]catalyst-editorial.co.uk
15. Data protection registration
15.1 We are registered as a data controller with the UK Information Commissioner's Office.
15.2 Our data protection registration number is ZB222623.