Data Protection and Privacy Policy

Introduction

This site [https://valueconversation.co.uk] is operated by 12boxes Ltd.

Reg. No. 4354090. Registered in England. Registered office:
27 Old Gloucester Street | London WC1N 3AX | United Kingdom

12boxes collects and uses personal data only as it is needed to deliver to you our training and coaching services, including this website.

Your personal data may include information such as:

• Name
• Address
• Telephone number
• Email address
• Other data collected that could directly or indirectly identify you.

Our Privacy Policy sets out to describe what data we collect, what we may collect in the future, and how and why we use your personal data. It also describes options we provide for you to access, update or otherwise take control of your personal data that we process.

If at any time you have questions about our practices or any of your rights described below, you may reach our Data Protection Officer by contacting us at privacy@12boxes.com.

What information do we collect?

We collect information so that we can provide the best possible experience when you enquire about or use our training and coaching services.

Much of what would be regarded as personal data is collected directly from you when you:

• create an account or purchase any of our services (eg: billing information, including name, address, payment details);
• consult a 12boxes coach (eg: phone number, session notes);
• undertake an online training course (eg: courses started and progress within them)
• complete contact forms or request information from us (eg: email)
• participate in surveys or other activities we organise that might require information about you.

We may also collect additional information when delivering our services to you which may not be so obvious:

Account related information is collected when you use our services, such as account number, purchases, when products renew or expire, information requests, support requests and notes or details explaining what issues you raised and how we responded.

Cookies and similar technologies on our websites may now or in the future allow us to track your browsing behaviour, links clicked, items purchased, your device type, and to collect various data, including analytics, about how you use and interact with our services. This allows us to provide you with more relevant product offerings, a better experience on our sites and mobile applications, and to collect, analyse and improve the performance of our services. We may also collect your location (IP address) so that we can personalise our services to you and your location.

Data about Usage of Services may now or in the future be automatically collected when you use and interact with our services, including metadata, log files, cookie/device IDs and location information. This information includes specific data about your interactions with the features, content and links (including those of third-parties, such as social media plugins) contained within the services, IP address, browser type and settings, the date and time the services were used, information about browser configuration and plugins, language preferences and cookie data, information about devices accessing the services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data, and some of this data collected might be capable of and be used to approximate your location.

Supplemented Data may be received about you from other sources, including publicly available databases or third parties from whom we have purchased data, in which case we may combine this data with information we already have about you so that we can update, expand and analyse the accuracy of our records, identify new customers, and provide products and services that may be of interest to you. If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

How we use information

We minimise the data we collect and limit its use and purpose to only that:

1. for which we have been given permission
2. as necessary to deliver the services you purchase or interact with
3. as we might be required or permitted for legal compliance or other lawful purposes.

These uses include:

Delivering, improving, updating and enhancing the services we provide to you. We collect various information relating to your purchase, use and/or interactions with our services. We utilise this information to:

• Improve and optimise the operation and performance of our services (again, including our websites and mobile applications)
• Diagnose problems with and identify any security risks, errors, or needed enhancements to the services

• Detect and prevent fraud and abuse of our services and systems
• Collecting aggregate statistics about use of the services
• Understand and analyse how you use our services and what products and services are most relevant to you

Some of the data collected is aggregated or statistical data about how individuals use our services and is not linked to any personal data.

Where data is personal data, or is linked or linkable to personal data, we will treat it as such.

Sharing with trusted third parties

First, what is not shared:

• This site is powered by WordPress. By default, WordPress does not share any personal data with anyone.
• The software powering our training courses is WP Courseware supplied by Lighthouse Media, LLC. If a course is offered for free, then the users registration information is only stored in the WordPress users table. WP Courseware does not collect any credit card data whatsoever. WP Courseware only sends required data to the payment gateways.

We may share your personal data with third parties with which we have partnered to allow you to integrate their services into our own services, and with trusted third party service providers as necessary for them to perform services on our behalf, such as:

• Conducting surveys
• Communicating with you, such as by way of email or survey delivery
• Customer relationship management

We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilising, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).

Communicating with you. We may contact you directly or through a third-party service provider regarding products or services you have signed up to or purchased from us, such as necessary to deliver transactional or service-related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:

• Email
• Text (SMS) messages
• Telephone calls
• Messages through applications such as Microsoft Teams

You may also update your subscription preferences with respect to receiving communications from us in ways which will be made clear each time we communicate with you.

If you believe that anyone has provided us with your personal information and you would like to request that it be removed from our database, please contact us at privacy@12boxes.com.

Transfer of personal data abroad. If you use our services from a country other than the UK, your communications with us may result in transferring your personal data across international borders. Also, when you call us or initiate a chat or video conference, we may provide you with support from one of our locations outside your country of origin. In these cases, your personal data is handled according to this Privacy Policy.

Compliance with legal, regulatory and law enforcement requests. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.

To the extent we are legally permitted to do so, we will take reasonable steps to notify you if we are required to provide your personal information to third parties as part of legal process.

Website analytics. We use multiple web analytics tools provided by service partners such as Google Analytics to collect information about how you interact with our website or mobile applications, including what pages you visit, what site you visited prior to visiting our website, how much time you spend on each page, what operating system and web browser you use and network and IP information. We use the information provided by these tools to improve our services. These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our website. Each cookie cannot be used by anyone other than the service provider (eg: Google for Google Analytics). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside. Though information collected does not include personal data such as name, address, billing information, etc., the information collected is used and shared by these service providers in accordance with their individual privacy policies. You can control the technologies we use by managing your settings through the ‘cookie banners” that may be presented (depending on URL of website visited) when you first visit our webpages, or by utilising settings in your browser or third-party tools.

Targeted advertisements. Targeted ads or interest-based offers may be presented to you based on your activities on our webpages, and other websites, and based on the products you currently own. These offers will display as varying product banners presented to you while browsing. We also partner with third parties to manage our advertising on other websites such as Facebook, Twitter, Google and Microsoft. Our third-party partners may use technologies such as cookies to gather information about such activities in order to provide you with advertising based upon your browsing activities and interests, and to measure advertising effectiveness.

Third-party websites. Should our website or our mobile applications contain links to third-party websites please note that we are not responsible for the privacy practices or the content of third-party sites. Please read the privacy policy of any website you visit.

How you can control your data held by us

Where we contact you by email, we will provide you with links to view, update, or delete your personal data relating to email, or to update your subscription preferences.

If you wish to view, update, or delete other personal data we hold about you, please contact privacy@12boxes.com or write to us at the address below.

If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honoured only to the extent it is no longer necessary for any services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

How we secure, store and retain your data

We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including utilisation of encryption where appropriate.

We retain personal data only for as long as necessary to provide the services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:

• mandated by law, contract or similar obligations applicable to our business operations;

• for preserving, resolving, defending or enforcing our legal/contractual rights; or
• needed to maintain adequate and accurate business and financial records.

If you have any questions about the security or retention of your personal data, you can contact us at privacy@12boxes.com.

Age restrictions

Our services are available for purchase only for those over the age of 16. Our services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 16. If you know of or have reason to believe anyone under the age of 16 has provided us with any personal data, please contact us.

Changes in our Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.

Data Protection Authority

12boxes Limited is the data controller for https://valueconversation.co.uk and is registered on the Information Commissioner’s Office’s Register of Data Controllers under number Z3064815.

You may direct questions or complaints in respect of how we handle your Personal Data to the Information Commissioner’s Office.

www.ico.org.uk

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Phone: 0303 123 1113 Fax: 01625 524510

Contact us

If you have any questions, concerns or complaints about our Privacy Policy, our practices or our services, you may contact our Data Protection Officer by email at privacy@12boxes.com. You may also contact us by either of the following means:

By Mail: Attn: Office of the Data Protection Officer, 12boxes Limited, 27 Old Gloucester Street, London WC1N 3AX

By Phone: 020 7100 1528

By Fax: 0330 088 3773

We will respond to all requests, inquiries or concerns within 30 days.