PERSONAL AND NON-PERSONAL INFORMATION
WHAT IS NON-PERSONAL INFORMATION AND HOW IS IT COLLECTED AND USED?
Non personal information is information that cannot identify you. If you visit this web site to read information, such as information about one of our services, we may collect certain non-personal information about you from your computer’s web browser. Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information.
Personal information is information that identifies you as an individual, such as your name, mailing address, e-mail address, telephone number, and fax number. We may collect personal information from you in a variety of ways:
- When you send us an application or other form
- When you conduct a transaction with us, our affiliates, or others
- When we collect information about in you in support of a transaction, such as credit card information
- In some places on this web site you have the opportunity to send us personal information about yourself, to elect to receive particular information, to purchase access to one of our products or services, or to participate in an activity.
- Any photos, videos, or texts shared with us about your progress throughout the course as outlined in the User Agreement
ARE COOKIES OR OTHER TECHNOLOGIES USED TO COLLECT PERSONAL INFORMATION?
HOW DOES Overcoming Stuttering Co. USE PERSONAL INFORMATION?
DOES Overcoming Stuttering Co. SHARE PERSONAL INFORMATION WITH OTHERS?
HOW IS PERSONAL INFORMATION USED FOR COMMUNICATIONS?
We may contact you periodically by e-mail, mail or telephone to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this web site allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via e-mail. The e-mail response or confirmation may include your personal information. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.
HOW IS PERSONAL INFORMATION SECURED?
We have implemented generally accepted standards of technology and operational security in order to protect personally-identifiable information from loss, misuse, alteration, or destruction. Only authorized personnel and third party vendors have access to your personal information, and these employees and vendors are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.
This site contains links to other sites that provide information that we consider to be interesting. Overcoming Stuttering Co. is not responsible for the privacy practices or the content of such web sites.
This site may provide public discussions on various business valuation topics. Please note that any information you post in these discussions will become public, so please do not post sensitive information in the public discussions. Whenever you publicly disclose information online, that information could be collected and used by others. We are not responsible for any action or policies of any third parties who collect information that users disclose in any such forums on the web site. Overcoming Stuttering Co. does not agree or disagree with anything posted on the discussion board. Also remember that you must comply with our other published policies regarding postings on our public forums outlined in the User Agreement..
HOW CAN A USER ACCESS, CHANGE, AND/OR DELETE PERSONAL INFORMATION?
Overcoming Stuttering Co. will not intentionally collect any personal information (such as a child’s name or email address) from children under the age of 13. If you think that we have collected personal information from a child under the age of 13, please contact us.
Data Protection Policy
Why This Policy Exists
This data protection policy ensures Overcoming Stuttering Co. :
Complies with data protection law and follows industry best practices
Protects the rights of staff, clients, affiliates, and partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach
EU General Data Protection Regulation (GDPR) Protection Law
1. Policy Statement
Every day our business will receive, use, and store personal information about our clients, affiliates, partners, and colleagues. It is important that this information is handled lawfully and appropriately, in line with the requirements of the Data Protection Act 2018 and the General Data Protection Regulation (collectively referred to as the ‘Data Protection Requirements’). We take our data protection duties seriously, because we respect the trust that is being placed in us to use personal information appropriately and responsibly.
2. About This Policy
This policy and any other documents referred to in it, sets out the basis on which we will process any personal data that we collect or process. This policy does not form part of any employee’s contract of employment and may be amended at any time. The company as a whole is responsible for ensuring compliance with the Data Protection Requirements and with this policy. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Officer.
3. What Is Personal Data?
Personal data is defined as data, (whether stored electronically or paper based) relating to a living individual who can be identified directly or indirectly from that data, (or from that data and other information in our possession). Processing is any activity that involves use of personal data. It includes obtaining, recording, or holding the data, organizing, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring personal data to third parties under privacy control conditions. Sensitive personal data includes contact info, address, session activity on the platform, IP location etc. Sensitive personal data can only be processed under strict conditions, and used for express purpose that it was collected for.
4. Data Protection Principles
Anyone processing personal data, must ensure that data is: Processed fairly, lawfully and in a transparent manner. Collected for specified, explicit, and legitimate purposes and any further processing is completed for a compatible purpose. Adequate, relevant and limited to what is necessary for the intended purposes. Accurate and where necessary, kept up to date. Kept in a form which permits identification for no longer than necessary for the intended purposes. Processed in line with the individual’s rights and in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures. Not transferred to people or organizations situated in countries without adequate protection and without firstly having advised the individual
5. Fair And Lawful Processing
The Data Protection Requirements are not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the individual. In accordance with the General Data Protection Regulation (GDPR), we will only process personal data where it is required for a lawful purpose. The lawful purposes include (amongst others): whether the individual has given their consent, the processing is necessary for performing a contract with the individual, for compliance with a legal obligation, or for the legitimate interest of the business. When sensitive personal data is being processed, additional conditions must be met.
Collection Of Information
We Receive And Store Information About You Such As:
Information you provide us: We collect information you provide to us which includes: your name, email address, address or postal code, payment method, and telephone number. We collect this information in a number of ways, including manual entry while you are using our service, interact with our client service, participate in surveys or marketing promotions, provide reviews or ratings, taste preferences, set preferences in Your Profile/Account, or otherwise provide information to us through our service or elsewhere.
We collect information regarding you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service.
This Information Includes:
Your activity on our platform such as course progress and search queries
Details regarding your interactions with client service such as the date, time and reason for contacting us
Transcripts of any chat conversations that you initiate on our platforms
In the event that you initiate phone support, your phone number
Device IDs or unique identifiers, device and software characteristics (such as type and configuration)
Connection information, statistics on page views, referral URLs, IP address, and standard web log information
We use the information we collect to provide, analyze, administer, enhance, and personalize our services and marketing efforts, to process your registration, your orders, your payments, and your communication on these and other topics.
Our primary aim is always to enhance the user experience. We do so in several ways using the data that we collect, but a few examples are: determining your general platform usage, required action item completions, login details, etc. which then helps us know what difficulties the you’re facing within the platform, with which can then use to take action to minimize the effort on your end. We collect other information, such as most visited links on our website, which then help us conclude what content was most watched, enabling us to create additional content geared toward our users’ needs and personal preferences.
6. Processing For Limited Purposes
7. Notifying Individuals
If we collect personal data directly from an individual, we will inform them about:
The purpose or purposes for which we intend to process that personal data, as well as the legal basis for the processing.
Where we rely upon the legitimate interests of the business to process personal data, the legitimate interests pursued.
The types of third parties, if any, with which we will share or disclose that personal data.
The fact that the business intends to transfer personal data to a non-EEA country or international organization and the appropriate and suitable safeguards in place.
How individuals can limit our use and disclosure of their personal data.
Information about the period that their information will be stored or the criteria used to determine that period.
Their right to request from us as the controller access to and rectification or erasure of personal data or restriction of processing.
Their right to object to processing and their right to data portability.
Their right to withdraw their consent at any time (if consent was given) without affecting the lawfulness of the processing before the consent was withdrawn.
The right to lodge a complaint with the Information Commissioner's Office.
Other sources where personal data regarding the individual originated from and whether it came from publicly accessible sources.
8. Adequate, Relevant And Non-Excessive Processing
We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.
9. Accurate Data
We will not keep personal data longer than necessary for the purpose or purposes for which it was collected. We will take all reasonable steps to destroy or erase from our systems, all data which is no longer required.
11. Processing In Line With Data Subject’s Rights
We will process all personal data in line with data subjects’ rights, in particular their right to:
- Confirmation as to whether or not personal data concerning the individual is being processed.
- Request access to any data held about them by a data controller.
- Request rectification, erasure or restriction on processing of their personal data.
- Lodge a complaint with a supervisory authority.
- Data portability.
- Object to processing including for direct marketing.
- Not be subject to automated decision making including profiling in certain circumstances.
12. Data Security
We will take appropriate security measures against unlawful or unauthorized processing of personal data and against the accidental or unlawful destruction, damage, loss, alteration, or unauthorized disclosure of or access to personal data transmitted, stored, or otherwise processed.
We will put in place procedures and technologies to maintain the security of all personal data from the point of the determination of the means for processing and point of data collection to the point of destruction. Personal data will only be transferred to a data processor if he or she agrees to comply with those procedures and policies, or if he or she puts in place adequate measures himself/herself.
We will maintain data security by protecting the confidentiality, integrity, and availability of the personal data, defined as follows:
- Confidentiality: Only people who are authorized to use the data can access it.
- Integrity: Personal data should be accurate and suitable for the purpose for which it is processed.
- Availability: Authorized users should be able to access the data if they need it for authorized purposes. Personal data should therefore be stored on the Overcoming Stuttering Co. central computer system & databases instead of individual PCs.
Our Security Procedures:
- Entry controls: Any stranger seen in entry-controlled areas will be reported.
- Securing lockable desks and cupboards all the time. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)
- Data minimization will be practiced.
- Pseudonymisation and encryption of data will be the primary state of storing the data.
- Methods of disposal: Paper documents would be shredded. Digital storage devices would be physically destroyed when they are no longer required. - - - - - Electronic data would be deleted once it’s intended purpose is fulfilled.
- Equipment: Staff has to ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.
Transferring Personal Data Outside of the EEA: We may transfer any personal data we hold to a country outside the European Economic Area (‘EEA’) or to an international organization, provided that one of the following conditions applies:
- The country to which the personal data is transferred ensures an adequate level of protection for the data subjects’ rights and freedoms.
- The data subject has given his consent.
- The transfer is necessary for one of the reasons set out in the Act, including the performance of a contract between us and the data subject, or to protect the vital interests of the data subject.
- The transfer is legally required on important public interest grounds or for the establishment, exercise or defense of legal claims.
- The transfer is authorized by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.
Subject to the requirements above, personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Those staff may be engaged in, among other things, the fulfilment of contracts with the data subject, the processing of payment details and the provision of support services.
13. Disclosure And Sharing Of Personal Data
14. Subject Access Requests
To these ends, the company has a privacy statement setting out how data relating to individuals is used by the company.
Individuals must make a formal request for information we hold about them. Employees who receive a request should forward it to the data department immediately.
When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:
- We will check the caller’s identity to make sure that information is only given to a person who is entitled to it.
- We will suggest that the caller put their request in writing if we are not sure about the caller’s identity and where their identity cannot be checked.
- Where a request is made electronically, data will be provided electronically when possible.
- Our support team will refer a request to the data processing department or the Data Protection Compliance Manager for assistance in difficult situations.
15. Changes To This Policy
We may modify this Privacy Statement at any time, but we will provide prominent advance notice of any material changes to this Statement, such as posting a notice through the Services, on our websites, or sending you an email, to provide you the opportunity to review the changes and choose whether to continue using the Services. For detailed information on GDPR, please visit https://www.eugdpr.org/