**Please also see our Terms & Conditions Policy here which forms part of this policy.
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
1.3 For the purpose of the Data Protection Act 1998, the data controller is Do-Be Ltd, The Ca’d’oro, 45 Gordon Street, Glasgow G1 3PE
2. Collecting personal information
2.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(b) information that you provide to us when registering with our website (including your email address);
(c) information that you provide when completing your profile on our website (including your name, gender, date of birth, employment details);
(d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(e) information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
(f) information relating to any purchases you make of our services or any other transactions that you enter into through our website (including your name, address, telephone number, email address and card details);
(g) information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts);
(h) information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); and
(i) any other personal information that you choose to send to us.
2.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
3. Using personal information
3.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of the services available on our website;
(d) supply to you services purchased through our website;
(e) send statements, invoices and payment reminders to you, and collect payments from you;
(f) send you email notifications relevant to our services and your subscription;
(g) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(h) send you marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(i) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(j) deal with enquiries and complaints made by or about you relating to our website;
(k) keep our website secure and prevent fraud; and
(l) verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service).
3.3 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
3.4 All our website financial transactions are handled through our payment services provider, Paypal. You can review the provider’s privacy policy HERE. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, suppliers insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4.4 Except as provided in this policy, we will not provide your personal information to third parties.
5. International data transfers
5.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
5.2 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
5.3 You expressly agree to the transfers of personal information described in this Section 5.
6. Retaining personal information
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information 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 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. Security of personal information
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
7.3 All electronic financial transactions entered into through our website will be protected by encryption technology.
7.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.5 You are responsible for keeping your log-in details, username and password that you use for accessing our website confidential.
8. Amendments
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9. Your rights
9.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 20); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor plus an original copy of a utility bill showing your current address).
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your personal information for marketing purposes.
9.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites. These are provided for your information and convenience only.
10.2 If you follow a link to any of these websites, please note that we have no control over, and are not responsible for, the privacy policies and practices of third parties, and we do not accept any responsibility or liability for these policies or practices.
10.3 Our courses contain voluntary surveys provided by SurveyMonkey. We do not collect or ask for any personally identifiable information other than your IP address. Click SurveyMonkey Privacy Policy for more in depth information on how this data is used. It is possible to avoid using SurveyMonkey completely by simply skipping any survey you encounter on the Site. To do this, do not click any survey link and do not answer any questions. Click ‘Mark as Complete’ to progress without entering any information.
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. About cookies
12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
13. Our cookies
13.1 We use persistent cookies on our website.
13.2 The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
(a) Cookies Policy – at first visit to our website you will see a message alerting you of our privacy and cookie policy. If you’ve seen this message once, you probably won’t want to see it again. We use a cookie to remember this setting. User data are all anonymous.
(b) We use WordPress and this is the Content Management System (CMS) that runs our website. It uses cookies when logging in and out and for remembering some of your settings. They are essential for proper website operation. They are only set if you are a registered user and all user data are anonymous.
(c) Our website uses the plugin ‘WooCommerce’ for e-commerce functionality. To keep track of cart data, WooCommerce makes use of three cookies:
• woocommerce_cart_hash
• woocommerce_items_in_cart
• wp_woocommerce_session_
The first two cookies above contain information about the cart as a whole and helps WooCommerce know when the cart data changes. The third cookie above contains a unique code for each customer so that it knows where to find the cart data in the database for each customer. No personal information is stored within these cookies.
(d) Blog/Post Comments – if you leave a comment on our website e.g. on a page, article or blog post, then a cookie may be stored to ‘remember’ your email address for the next time you post (should you choose the ‘remember me’ option).
(e) Our website uses Wordfence Security employing cookies for three tasks:
• to uniquely identify visitors shown in Wordfence Live traffic;
• to track a user who was previously logged into WordPress but has logged out;
• to ensure that Falcon cache does not show that user cached pages.
If a user has visited a unique page that allows them to bypass country blocking a cookie is set to identify that user so that country blocking does not prevent them from viewing the site.
(f) We use Agile CRM to track: where the visitor is coming from (referrer); pages visited; time spent on each page; geographic information; browser/device used.
14. Analytics cookies
14.1 We use Google Analytics to analyse the use of our website.
14.2 Our analytics service provider generates statistical and other information about website use by means of cookies.
14.3 The information generated relating to our website is used to create reports about the use of our website, to understand how people use our site, and to discover areas on our site with issues. The data it collects helps us see things like how many people visit our site, which country they are from, how many pages they visited, how fast our site loaded, and so on. All data collected is completely anonymous, it does not identify you as an individual in any way.
14.4 Our analytics service provider’s privacy policy is available HERE.
15. Blocking cookies
15.1 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 47) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 52), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you will not be able to use all the features on our website.
16. Deleting cookies
16.1 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so HERE );
(b) in Firefox (version 47), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 52), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
16.2 Deleting cookies will have a negative impact on the usability of many websites.
17 Data protection registration
17.1 We are registered as a data controller with the UK Information Commissioner’s Office.
17.2 Our data protection registration number is ZA254834.
