About this policy
This policy describes how we use your personal data when you use our websites (https://crotraining.co.uk/, https://shop.crotraining.co.uk/ , https://lms.crotraining.co.uk/ ) or when we provide services to you. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.
You can read, print and save this whole policy or click on the links below to see specific information about:
Who we are and how you can contact us
We are Astra Nova Ltd. (company number 07046220, registered address - 150 Locket Road Harrow, London HA3 7 NZ, UK)
You can contact us in writing at the above address or by emailing firstname.lastname@example.org. If you would like to speak to us please call us on +44 (0) 208 099 5342.
What personal data we collect about you
- personal data that you provide to us. There are lots of ways in which you may share your personal data with us, for example, you may register on our website, purchase and/or complete one of our training courses, post on social media sites that we run, or contact us in connection with services that you would like to buy, or have already bought, from us. The personal data that you provide to us may include your name, job title, employer, address, e-mail address, birthday and phone number.
- personal data that we receive from third parties. We may be provided with your personal data by yourself, your employer or your client, if they have engaged us to provide training courses on their behalf. The personal data provided may include your name, email address and job title. We may also receive personal data in terms of feedback from service providers, such as courier companies that we use in the execution of our business.
What we use your personal data for
We use your personal data in the following ways:
- personal data that you provide to us is used to:
- process and respond to any enquiry you make
- provide you with the information and services that you, your employer or your client requests from us
- send you a certificate by email on completion of your course(s)
- alert you when your training or other services are due to expire
- provide you with marketing information in accordance with your marketing preferences (see How we use your personal data for marketing)
- manage and administer our business
- review and improve our services
- to give access to our products and services
- personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.
- personal data about your use of our website is used to:
- administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device
- to allow you to participate in interactive features of our service, when you choose to do so
- as part of our efforts to keep our site safe and secure
- to make suggestions and recommendations to you and other users of our site about services that may interest you or them
When we need your consent to use your personal data
Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:
- we are entering into and carrying out our obligations under a contract with you
- we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights
In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent. In these circumstances we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.
Please refer to the section on How we use your personal data for marketing to read about marketing consents.
Personal data you are legally obliged to provide
You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our services to you.
Your rights to know what personal data we hold and to control how we use it
You have a legal right to know what personal data we hold about you - this is called the right of subject access. You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to us by post or email using the details in the Who we are and how you can contact us section.
You also have rights to:
- prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
- have inaccurate personal data corrected, blocked or erased
- object to decisions being made about you by automated means
- object to our using your personal data in ways that are likely to cause you damage or distress
- restrict our use of your personal data
- require that we delete your personal data
- require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file
You can find full details of your personal data rights on the Information Commissioner’s Office website at ww.ico.org.uk.
Automated decision making and profiling
We undertake automated decision making for the following purposes:
- where it is required for the delivery of our goods or services
- to alert trainees that their certificates are about to expire
- as part of our product or service offering
You are entitled to ask that we do not make automated decisions about you or use your personal data for profiling purposes. Please refer to the section on Your rights to know what personal data we hold and to control how we use it for details on how to exercise your rights.
When we will share your personal data with others
We share your data with the following people in the day to day running of our business:
- if you have been enrolled in a course by your employer or client, they are able to access your training records, including exam questions you got wrong, in order to monitor performance and identify gaps in knowledge which need to be addressed
- any business partners, suppliers and sub-contractors we work with to provide you with services that you have requested from us
- advertisers and advertising networks, such as email service providers
- analytics and search engine providers that assist us in the improvement and optimisation of our site
We may also share your personal information with third parties on a one-off basis, for example, if:
- we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
- we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction
How we keep your personal data safe
We take every care to ensure that your personal data is kept secure. The security measures we take include:
- only storing your personal data on our secure servers
- ensuring that our staff receive regular data security awareness training
- keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises
- destroying any records of credit card numbers as soon as they are entered into (and encrypted by) our secure finance software
- maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems
- enforcing a strict policy on the use of mobile devices and out of office working
Please remember that you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. Please do not to share your passwords with anyone.
Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our websites; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.
How we use your personal data for marketing
We will add your details to our marketing database if:
- you make an enquiry about our services
- you provide your details and indicate that you are happy to receive marketing communications when signing up for a product demonstration
- you buy our services
- you have told a third party that you would like them to pass us your contact details so that we can send you updates about our services
- you have registered an account on our website and have indicated during the sign up process that you are happy to receive marketing communications
We may send you marketing communications by email, telephone, text message, fax, pots or social media.
You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), or you may ask us not to send you any marketing communications at all.
We may ask you to indicate your marketing preferences when you first register an account on our website. You can check and update your current marketing preferences at any time by emailing us at email@example.com or by telephoning +44 (0) 208 099 5342.
We never share your personal data with third parties for marketing purposes.
When we will send your personal data to other countries
Astra Nova Ltd is based in the UK and also has offices in Bulgaria who have access to your personal data.
How long we keep your personal data
We only keep your personal data for as long as we actually need it. In practice, this means we keep data for up to 8 years after the end of the contract, unless for legal reasons, it needs to be retained for longer. In practice, this means that we will usually keep:
- your name and contact details for 8 years
- a record of the services, including a copy of your full customer file, we provide to you for 8 years
- complaint records for 8 years
- contracts for 8 years (after the contract end date)
How you can make a complaint
If you are unhappy with the way we have used your personal data please contact us to discuss this using the email address firstname.lastname@example.org or by telephoning +44 (0) 208 099 5342
You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.
How we keep this policy up to date
We will review and update this policy from time to time. This may be to reflect a change in the services we offer or to our internal procedures or it may be to reflect a change in the law.
The easiest way to check for updates is by looking for the latest version of this policy on our websites(https://crotraining.co.uk/, https://shop.crotraining.co.uk/ , https://lms.crotraining.co.uk/) or you can contact us by email on email@example.com or by telephone on +44 (0) 208 099 5342 to ask us to send you the latest version of our policy.
Each time we update our policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.
This is policy version 0.0.1 which came into effect on 29th May 2018.