Privacy Policy

Secret Compass Ltd ("we", "our" or "Secret Compass") is committed to protecting the privacy of all individuals in respect of whom we hold personal information. This privacy policy is relevant to the website at www.secretcompasstv.com and training.secretcompasstv.com. Please read the following Privacy Policy which explains how we use and protect your personal information. This Privacy Policy applies to the use of all our services and websites (and web-based services) on which a link to this policy appears (the "Sites").

For the purpose of the Data Protection Act 2018 and the EU General Data Protection Regulation (the "GDPR") (together, the “Data Protection Legislation”), the data controller is Secret Compass Ltd registered company number 7746209 with registered address 14 Whitehouse Street, Bedminster, Bristol, BS3 4AY.

We take your privacy seriously and we are committed to keeping your information private. To the extent we are required by law, we have notified the United Kingdom's Information Commissioner's Office that we will process your personal information in accordance with the Data Protection Legislation (as defined above).

By providing us with any information about yourself (including via the Sites), you understand that we will process your personal information in accordance with this Privacy Policy.

This Privacy Policy covers

1. What personal information we collect about you and how we collect it

2. Our legal basis for collecting and using your personal information

3. How we will use your personal data

4. Personal information that we share with third parties

5. Automated Processing of your personal data, including Profiling

6. Data retention, data security and transfers of personal information outside of the European Economic Area (EEA)

7. Your rights - Accessing, erasing and updating your personal information

8. How to unsubscribe from any email alerts that you receive

9. Changes to our Privacy Policy

10. Legal and Contact Information

1. What personal information we collect about you and how we collect it

Information that you provide us directly

We collect personal information whenever you contact us and provide us with information that we are able to identify you by, including when you contact us by phone, email, live chat or when you sign up to use any of our services.

In particular, we collect and use your personal, contact and user account information when you:

• Enrol, complete and claim your certificate for a Secret Compass Training Course;

• Create an account for our Learning Management System, hosted by Thinkific;

• Subscribe to receive email updates from us;

• Take part in market research or surveys; and;

• Every time you e-mail, call or otherwise contact us;

We also collect information about the payment methods that you use for any transactions that you make.

Information that we collect from third parties

Where you work for a third party that purchases products and services direct from Secret Compass they are required to provide information about you in order to deliver your training. It is that third party's responsibility to ensure that it has informed you, and where necessary, obtained your consent to do this. Should you have any questions about how third parties use your data, you should direct these to that party.

Information that we automatically collect (including use of "cookies")

This website uses cookies to improve your experience when visiting the website.  Cookies are small files saved to your device that track, save and store information about your interactions with and usage of the website.  This allows the website, through its server to provide you with a tailored experience within this website.

If you don’t want cookies to be stored on your device, you should make the necessary changes to your device or the relevant browsers or apps. Please note that if you disable cookies, some services or website functionality may not be available.

We use the following cookies:

• Essential cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, and to use online forms.

• Analytical cookies. This website uses Google Analytics tracking software to better understand how you use it.  This software will save a cookie to your device in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information.  You can read Google's privacy policy here for further information.

• Marketing cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences. These cookies also record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website, the advertising displayed on it and communications sent more relevant to your interests.

By continuing to use this site, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests, and further help us to improve the site.

Other cookies may be stored on your device by external vendors when this website uses referral programs, sponsored links or adverts.  These cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected without your consent.

2. Our legal basis for collecting and using your personal information

Data Protection Legislation mandates that any personal information can only be used where there is a lawful basis to do so. At Secret Compass, we rely on one or more of the following grounds to legally collect and use your personal information:

• The data is necessary for the performance of the contract which we have with you (i.e. to provide our services to you);

• We are using your personal information where it is in our legitimate interests to do so;

• We have a legal obligation to process your personal information;

• You have consented to the use of your personal information by us.

Where we rely on your consent to process any of your personal information, you may revoke your consent at any time. Any such revocation will not affect the lawfulness of any prior use of that personal information.

Where your data is provided to us by a third party who you work for, they are the Data Controller for that information and have the obligation to set their own Lawful Basis for processing.

3. How we use your personal information

We will use your personal information to enable us to provide our Services to you and enable you to use the Sites, including, for the following purposes:

Performance of a Contract

We will use your personal information for the following purposes where it is necessary to perform a contract, or enter into a contract, with you:

• To authenticate your identity and administer your training account;

• To provide the third party commissioning the services with proof of training;

• To deal with your enquiries and requests;

• To process your orders for any services or products that you purchase from us;

• To provide you with updates about developments on our Sites;

• To enable our data processors (such as our group companies and hosting providers) to provide services (or components thereof) requested by you.

Legitimate Interest

We may use your personal information where we have a legitimate business interest to do so. These legitimate interest are:

• To personalise aspects of our services to you;

• To carry out market research or surveys about our products and services;

• For marketing and strategic development purposes, for example to identify trends usage;

• To enable our data processors (such as our group companies and hosting providers) to provide services (or components thereof) requested by you;

• For the proper keeping of business records;

• To analyse and create statistical reports based on the services we provide and our performance of those services.

Legal Obligation

We will use your personal information where we are legally obliged to do so, this includes:

• For financial reporting and auditing purposes,

• For anti-money laundering or fraud prevention, detection and reporting;

• To maintain records of actions taken on your account.

Consent

We will use your personal information where we have your consent to do so:

• To provide you direct marketing information related to information about the products and services we offer;

It is your responsibility to ensure that any information submitted as part of the registration process is accurate and up to date.

4. Personal information that we share with third parties

In order to provide the services offered on our Site, we sometimes need to share your personal information with other companies in the Secret Compass group. However, we will continue to be responsible for the usage and security of your personal information when this happens. 

Where a third party eg. your employer, has paid for access to one of our courses, we may share the results of the course, and your name / email address with them for verification purposes. Those using access codes for course discounts will have the relevant information shared with the course discount purchaser to identify and manage fraudulent use.

Secret Compass’s data processors

We may also share your personal information with third party processors or suppliers that we engage to provide services to us and/or support our offering to you (such as our hosting, database and marketing platform providers). These third parties may need to process your personal information on our behalf to provide our services. Where this is the case we take great care to only appoint reliable third parties who can guarantee the security of your personal information and our business information. Note that these third parties simply process personal information on behalf of Secret Compass and have no right to use, disclose or transfer your personal information in any other way. Please see below in relation to our policy for transfers of personal information outside the EEA.

Other circumstances where we use or share your personal information

In certain circumstances, we may be required by law to disclose your personal information for investigative, regulatory or other related purposes to third parties such as government bodies, law enforcement agencies, banks or other financial institutions and data protection regulators.

5. Data retention, data security and transfers of personal information

We take steps to protect your personal information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We will only keep your personal information for as long as we reasonably require and for the activities we have detailed above. This means we will retain personal information for the duration of any contract we have with you, in line with any legal obligation for data retention (such as that for HMRC) or, primarily, until erasure is requested by you.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your personal information, we cannot guarantee the security of your data transmitted via email and/or our website; any transmission is at your own risk.

The personal information that we collect from you will be stored and processed within the UK and the EEA.

6. Your rights - Accessing, erasing and updating your personal information

Should you have any queries or complaints in relation to how we use your information please contact us via the details set out at section 10 below. You have the right to access the personal information we hold about you and to ask us to:

• make any changes to ensure that any personal information we hold about you is accurate and up to date;

• erase or stop processing any personal information we hold about you where there is no longer a legal ground for us to hold it; or

• transfer any information we hold about you to a specified third party.

Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner's Office regarding such issues. Further information about how to make a complaint can be obtained at www.ico.org.uk or by telephoning 0303 123 1113

7. How to unsubscribe from any email alerts that you receive

If you have elected to receive information about our products or services, and would like, at any time, to unsubscribe from this service, please email make an enquiry through our contact page or click on the "unsubscribe" link at the bottom of an email.

8. Changes to our Privacy Policy

Secret Compass may amend this Privacy Policy at any time and where we make material changes to it we will provide notice on our website. By continuing to use our services and/or our Sites, you agree to the updated Privacy Policy. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) our services and/or our Sites.

This privacy policy was last updated in July 2020.