This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.authenticityresolved.com or one of our affiliated sites for Finance Inspired 4 Success, Global Leadership Hypothesis e.g. Thinkific, including any information you may provide through these sites when you purchase a product or service, sign up to our newsletter and knowledge gifts or take part in a prize draw, survey or competition.
Authentic Change Solutions Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.
Our full details are:
Full name of legal entity: Authentic Change Solutions Limited
Name Data Protection Officer: Marcus Holtzhausen
Email address: email@example.com
Postal address: 2 Turbary road, Fleet, Hampshire, GU51 1GH
Telephone number: +44(0) 1252-623899
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
• Request access to your personal data
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
As a data subject, you have the following rights in respect of your data under the GDPR. Your rights are as follows:
• The right to be informed about our collection and use of personal data you provide;
• The right of access to the personal data we hold about you (see section 7);
• The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 10);
• The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 3 but if you would like us to delete it sooner, please contact us using the details in section 10);
• The right to restrict (i.e. prevent) the processing of your personal data;
• The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
• The right to object to us using your personal data for particular purposes; and
• Rights with respect to automated decision making and profiling.
If you have any cause for complaint about our use of your personal data, please contact us using the details provided in the introduction. If you are unhappy or unsatisfied with how your data is processed by Authentic Change Solutions Ltd. and raise a complaint with our Data Protection Officer. If you remain unhappy with the response to your complaint, you have the right to lodge a complaint with the Information Commissioner’s Office. The ICO’s address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Cheshire, SK9 5AF. United Kingdom. You can also visit their website for more information - http://www.ico.org.uk/
How we collect your data
We collect data about you through a variety of different methods including:
• Direct interactions: You may provide data by filling in forms on our site or one of our product sites hosted by Thinkific (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
• order our products or services;
• subscribe to our service or publications,
• request resources or marketing be sent to you;
• enter a competition, prize draw, promotion or survey; or
• give us feedback.
• Pulse Surveys
• Knowledge gifts
• Downloadable content
• Tali Ho’s Toolkit - Spreading ripples of change download
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below: analytics providers such as Google based outside the EU;
• Identity and Contact Data from data brokers or aggregators such as Electric Marketing based [inside the EU].
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
The personal data we collect
When you enrol as a student or subscriber ("learned') on our site or related courses, as part of the enrolling process, we collect the personal information you give us. When you download content from our site or a related programme site we collect the personal information you give us.
We will collect different kinds of information from you depending on our relationship with you. We may collect some or all of the following personal, special category and non-personal data.
We may process certain types of personal data about you as follows:
• Identity Data may include your first name, last name, username, marital status, title, date of birth and gender.
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Financial Data may include your bank account and payment card details.
• Transaction Data may include details about payments between us and other details of purchases made by you.
• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
• Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
• Usage Data may include information about how you use our website, products and services.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data, but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
How do you get my consent?
When you provide us with personal information to become a learner on our affiliated programme site, make a purchase, or participate in the course, you imply that you consent to our collecting it and using it for that specific reason only.
How do you get my express consent?
When you provide us with personal information to complete a transaction, verify your credit card, place an order or return a product, we will request your express consent to our collecting it and using it for that specific reason only. If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, and provide you with an opportunity to say no.
How do I withdraw my consent?
If after you consent, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at unsubscribe@financeinspired4success or mailing us at: Authentic Change Solutions, 2 Turbary Road, Fleet, Hampshire, United Kingdom, GU51 1GH.
How we Use Your Data?
We will only use your personal data when legally permitted. The most common uses of your personal data are:
• Where we need to perform the contract between us.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at unsubscribe@financeinspired4success
• Email marketing: we may send you emails about our site or affiliated sites and related course(s), registration, course content, your course progress or other updates. We may also use your email to inform you about changes to the course, survey you about your usage, or collect your opinion.
• Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
• Providing and managing learning experience;
• Our Provision of CPD activities;
• our Market research, including product usage and transactional data.
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. we will always comply with our obligations and safeguard your rights under the GDPR.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our products and services. we will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
We will retain your data for as long as it is needed for the relevant regulatory, assurance and conduct purposes. Your personal data will be retained for the periods as required by GDPR legislation.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.
Please email us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data Lawful basis for processing To register you as a new customer
(a) Identity (b) Contact
Performance of a contract with you To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity (b) Contact
(e) Marketing and Communications
(a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(a) Identity (b) Contact
(d) Marketing and Communications
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records
updated and to study how customers use our products/services
To enable you to partake in a prize draw, competition or
complete a survey
(a) Identity (b) Contact
(e) Marketing and Communications
(a) Performance of a contract with you (b) Necessary for our legitimate interests to study how
customers use our products/services, to develop them and grow our business
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity (b) Contact
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group
restructuring exercise (b) Necessary to comply with a legal obligation.To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising
(e) Marketing and Communications
Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests to develop our products/services and grow our business
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our Site.
Do we Share Your Data?
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
• Service providers who provide IT, system administration services, learning platforms and CPD certificates.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We may use service providers in connection with operating and improving the Site, to assist with certain functions, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations, including through the execution of GDPR-compliant Data Privacy Agreements or Addenda, as applicable.
We use 3rd-party solutions for marketing and analytics. This processing occurs on third party platforms on accounts owned by Company This processing is subject to our Data Privacy Agreements or Addenda with these third parties, and their respective privacy policies.
International transfers or if transfers out of EEA occur
We share your personal data within our group of companies which may involve transferring your data outside the European Economic Area (EEA).
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Relevant privacy policies of providers we deal with:
Our programme and course sites
Our course and product site are hosted by Thinkific Labs Inc. ('Thinkific"). They provide us with the online course creation platform that allow us to sell our product/services to you.
Your data is stored through Thinkific's data storage, databases and the general Thinkific application. They store your data on a secure server behind a firewall.
If you make a purchase on our site or the Thinkific site, we use a third-party payment processor such as Stripe or PayPal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers
When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system. Email marketing (if applicable): With your express permission, we may send you emails about our store, new products and other updates.
Third party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
What are cookies?
Cookies are small files of letters and numbers. These files are either stored in the memory of your computer or other device such as mobile phones or tablet devices (these cookies are generally known as session cookies) or are placed on the hard drive of your device (generally known as persistent cookies).
For more details about cookies and details of how to delete and disable cookies you can visit www.aboutcookies.org and also see our section on more information and turning cookies off below.
What cookies are on the Authentic Change Solutions website?
Authentic Change Solutions use Google Analytical cookies.
Analytical cookies allow us to recognise and to count the number of visitors to our website, to see how visitors move around the website when they are using it and to record which content viewers view and are interested in. This helps us to determine how frequently particular pages and advertisements are visited and to determine the most popular areas of our website and/or services. This helps us to improve the service which we offer to you by helping us make sure our users are finding the information they are looking for, by providing anonymised demographic data to third parties in order to target advertising more appropriately to you, and by tracking the success of advertising campaigns on our website.
This cookie helps us determine the number of unique visitors to our website. You may reject or delete these cookies by downloading and installing the Google Analytics Opt-out Browser Add-on available here.
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We use this Google Analytics cookie to help us to record the length of individual sessions from our users on our website. Each time you move to a new page within our website within 30 minutes of arriving the cookie updates so that we know that you are still actively using our website within a single session.
This cookie helps us determine the referral method for people visiting our website. This helps us to analyse the traffic arriving at our website and to determine which are the most popular routes (e.g. direct, search engine search, email link)._utmc
Similar to _utmb, we use this Google Analytics cookie to help us record the length of individual sessions on our website.
This cookie logs details about the visitor’s browser and computer.
Other cookies used to generate statistical data is:
YouTube cookies might be set if the user watches any website hosted YouTube videos. They are used to estimate bandwidth and compile stats on video seen.
We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. If you provide PayPal with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, PayPal follow all PCI-DSS requirements and implement additional generally accepted industry standards.
We collect cookies or similar tracking technologies. This means information that our website's server transfers to your computer. This information can be used to track your session on our website. Cookies may also be used to customize our website content for you as an individual. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer.
• We may also use automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.
• Please note that because there is no consistent industry understanding of how to respond to "Do Not Track" signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
Web Analysis Tools
We may use web analysis tools that are built into Authentic Change Solutions and Finance Inspired 4 Success or product (Thinkific) websites website to measure and collect anonymous session information.
Our company’s commitment to data security:
Services and websites, we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information. If we do discover a security breach affecting your data, every effort will be made to provide a notification within 72 hours of our team learning of the occurrence.
General Data Privacy Regulation (GDPR)
The GDPR took effect on May 25, 2018, and is intended to protect the data of European Union (EU) citizens.
If you are a resident of the European Economic Area (EEA), or are accessing this Site from within the EEA, you have certain rights with respect to your data. We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to firstname.lastname@example.org. Rights that you may have, depending on the country in which you live, include:
• Accessing, correcting, updating, or requesting deletion of your information.
• If you request that your account be deleted, you will lose access to all of our programs in which you are actively registered.
• Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.
• Opting out from receiving marketing communications that we send you at any time. You can exercise this right by selecting the “unsubscribe” or “opt-out” link in the marketing emails we send you. Additionally, you may update your email preferences by changing the settings in your account.
• Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
• Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available here.
Data Controller and Data Protection Officer
If you reside in a country in the European Economic Area or in Switzerland, then your personal data collected by Company is controlled by Authentic Change Solutions, 2 Turbary Road, Fleet, Hampshire GU51 1GH
If you reside outside of the European Economic Area and Switzerland, then the personal data collected by the Company is controlled by Authentic Change Solutions, 2 Turbary Road, Fleet, Hampshire, GU51 1GH, United Kingdom.
Children’s Privacy Statement
This children’s privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen and provides important information regarding their rights under federal law with respect to such information.
• This Site is not directed to children under the age of thirteen and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of the Site. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of the Site, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Site.
• Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we also do NOT knowingly distribute such information to third parties. We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through the Site.
• Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we do NOT condition the participation of a child under thirteen in the Site’s online activities on providing personally identifiable info.
This Policy was last reviewed in June 2020. The content of the Policy may be reviewed and changed without prior notice, if any significant changes are made to the Policy, this will be communicated to you.
Last Updated : June 2020