We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.
We will also explain what rights you have with regards to your personal data and how you can exercise those rights.
2. Who we are
FeltSecure Labs Limited is a cyber security training, advisory, consultancy and mentoring company registered with Companies House in the UK. This means that FeltSecure Labs Limited determines what data is collected from you, how this data is going to be used and how this data is protected.
Our registered office address is:
FeltSecure Labs Limited
3rd Floor 86-90 Paul Street
London, EC2A 4NE
If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at firstname.lastname@example.org
3. Companies and websites within scope
|FeltSecure Labs Limited||www.feltsecure.com and all other subdomains (learning, members etc) and mobile application Feltsecure Labs|
Unless specifically stated, we consider these websites to be UK based websites; see section 6 below for more information on non-EU data processing.
It includes personal data that is collected through our websites, by telephone, through LiveChat and through any related social media applications.
4. Collection of personal data
We collect personal data from you for one or more of the following purposes:
- 1. To provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest;
- 2. To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services;
- 3. To fulfil a contract that we have entered into with you or with the entity that you represent;
- 4. To ensure the security and safe operation of our websites and underlying business infrastructure, and
- 5. To manage any communication between you and us.
The table in Section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.
In addition, and in order to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:
- Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet;
- Your login information, browser type and version, time zone setting, browser plug-in types and versions;
- Operating system and platform;
- Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and from our site.
In Section 8 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.
5. Lawful basis for the processing of personal data
The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business architecture, accounting and systems infrastructure and compliance organisation means that all personal data is processed on common, Group-wide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also identified below.
When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:
The purpose test – is there a legitimate interest behind the processing?
Necessity test – is the processing necessary for that purpose?
Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?
|Purpose of collection||Information category||Data collected||Purpose for collection||Lawful basis for processing||Data shared with?||Retention period|
|1. To provide you with information||Subject matter information||Name, company name, geographic location, email address, business sector.||To provide appropriate online or email information about products and services that you have requested||Contractual fulfilment||Internally only||Maximum 8 years from the data the information is collected.|
6 months if a marketing email is left unopened
|To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest.||Legitimate interest||Internally only|
|Telephone number||Follow-up to ensure requested information meets needs and identify further requirements||Legitimate interest||Internally only|
|Personal contact information as provided through website forms or at trade shows or any other means.||General mailing list subscription||Consent||Internally only|
|2. Transactional information||Transaction details||Name, physical address, email address, telephone number, bank account details (for credit accounts), other medium of content delivery||To process purchase transactions for products and services with customers, and to ensure any transaction issues can be dealt with.||Contractual performance||Internally only||Maximum 8 years from the date of the performance of the contract.|
6 months from the data the data subject has input personal information but has not proceeded with a transaction.
8 years for VAT records from the performance of the contract
|For accounting and taxation purposes||Statutory obligation||Internally and professional advisers|
|Documentation should any contractual legal claim arise||Legitimate Interest||Internally and professional advisers|
|Payment card data||Primary account number (PAN), cardholder name, service code, expiration date||To fulfil purchase requests using payment cards||Contractual performance||Payment card companies, all in line with PCI DSS||Only retained whist authorisation is pending.|
|3. Fulfilment information||Fulfilment data||Name, dietary requirements||Appropriate catering arrangements for training courses||Contractual performance||Internally and training venues||Maximum 6 years from the date of the performance of the contract.|
|Name, contact and identification details||Access to training courses, attendance registers||Contractual performance||Internally and training venues|
|Name, contact and identification details||Exam attendance, exam results and certifications||Contractual performance||Internally and external examiners, proctors and certification bodies|
|Name, contact details||Licensing details necessary for allocation and maintenance of a licence purchased for use of software and related products, distance and e-learning.||Contractual performance||Internally and any third parties whose products or services you may have purchased from us.|
|Name, address(es), email address, contact details||Actual delivery of products or services, in physical or digital form, that you may have purchased from us.||Contractual performance||Internally and any third party logistics or supplier companies with whom we contract in order to fulfil these requirements.|
|4. Security||Security information||Technical information, as described above, plus any other information that may be required for this purpose||To protect our websites and infrastructure from cyber attach or other threats and to report and deal with any illegal acts.||Legitimate interest||Internally, forensic and other organisations with whom we might contract for this purpose.||Relevant statutes of limitation|
|5. Communications||Contact information||Names, contact details, identification details||To communicate with you about any issue that you raise with us or which follows from an interaction between us.||Legitimate interest||Internally and, as necessary, with professional advisers.||Relevant statutes of limitation.|
Furthermore, the following provides examples of the type of information that we collect from you and how we use that information.
|Context||Types of Data||Primary Purpose for Collection and Use of Data|
|Account Registration or Membership Application||We collect your name, contact information, and professional information such as your company or industry when you create an account. We also collect information relating to the actions that you perform while logged into your account.||We have a legitimate interest in providing account related functionalities to our users. Accounts can be used to save your preferences and transaction history.|
|Certification||We collect attendance records from events, meetings, or examinations, as well as the information you enter on exams (which may include video of you and your surroundings if you select the online testing option), customer service interactions, and any certification verification requests that you have made.||We have a legitimate interest in ensuring that our certification standards are being met, including when and how our members are verifying those certifications.|
|Cookies and Third Party Tracking||We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites.||We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics.|
|Demographic Information||We collect personal information, such as your age, gender, or location.||We have a legitimate interest in understanding our users and providing tailored services.|
|Email Interconnectivity||If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.||We have a legitimate interest in understanding how you interact with our communications to you.|
|Feedback/Support||If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.||We have a legitimate interest in receiving, and acting upon, your feedback or issues.|
|Mailing List||When you sign up for one of our mailing lists we collect your email address or postal address.||We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.|
|Mobile Devices||We collect information from your mobile device such as unique identifying information broadcast from your device and location when visiting our website or using our application.||We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.|
|Partner Promotion||We collect information that you provide as part of a co-branded promotion with another company. We may also have service providers collect information on our or our partners’ behalf.||We have a legitimate interest in fulfilling our promotions.|
|Website interactions||We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.||We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud or other security incidents.|
|Web logs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.|
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, our affiliates, or publicly available sources. For example, we may receive information on graduates from a university or an employer.
6. Storage of personal data
FeltSecure is a UK-domiciled organisation whose primary offices are in the UK.
- The majority of our websites and web applications are hosted in the EU and are accessed only by our EU-based staff.
- Four of our websites, as identified in section 2 above, are targeted at non-EU customers and are accessed by staff located outside the EU. Our US website is the only one of our websites that is also hosted outside the EU. In all these instances, we have appropriate contractual and security measures in place to ensure that personal data is protected.
- Our customer relationship management, marketing and accounting systems for all our businesses are either EU-based or hosted by companies participating in the EU – U.S. Privacy Shield Framework.
- We use a wide range of Cloud Service Providers (CSPs) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
- Unless we specifically state otherwise all of the CSPs that we use utilise EU-located processing facilities.
- Our payment processors and banking arrangements are based in the EU and, for our US website, in the USA.
- We ship and deliver physical products around the world; we therefore use logistics companies that are based outside the EU and operate in other countries. We have appropriate legal and security relationships with those partners.
- We resell products supplied by organisations outside the EU. This may mean that our resale partner will have access to information about data subjects who purchase their products.
- We operate a data retention policy in respect of all data, whether paper-based or digital and those aspects of it which relate to personal data are contained in the table at 5, above.
7. Use of Personal Information
In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our website.
- To track your progress through our certification programs.
- To verify your certifications when requested by you or a third party.
- To provide training and services or to process returns.
- To improve our services and product offerings.
- To conduct analytics.
- To respond to inquiries related to support, sales, or other requests.
- To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
- For internal administrative purposes, as well as to manage our relationships.
- We may also use your name, location or photo for marketing purposes.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you register for membership we may collect your information to perform our contract with you. But we also collect your information as we have a legitimate interest in maintaining your information after your membership concludes so that we can quickly and easily respond to any questions about your history with the organization. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in maintaining our programs.
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
- Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
- Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
- Public. Some of our websites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publically available.
- Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
You can make the following choices regarding your personal information:
- Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
- Changes To Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. Note that we may keep historical information in our backup files as permitted by law. If our website does not permit you to update or correct certain information contact us at the address described below.
- Deletion Of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
- Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
- Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
8. Security measures
We have what we believe are appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our ISMS. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
9. Your rights as a data subject
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email email@example.com or use the information supplied in the Contact us section below. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:
- The right to be informed
- The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
- a) The purposes of the processing
b) The categories of personal data concerned
c) The recipients to whom the personal data has been disclosed
d) The retention period or envisioned retention period for that personal data
e) When personal data has been collected from a third party, the source of the personal data
- If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
- The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
- The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
- The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:a) The accuracy of the personal data is contested
b) Processing of the personal data is unlawful
c) We no longer need the personal data for processing but the personal data is required for part of a legal process
d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing
- The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
- The right to object
You have the right to object to our processing of your data where
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research;
- Processing involves automated decision-making and profiling.
The following additional information relates to our privacy practices:
- Transmission Of Information To Other Countries. As a multi-national non-profit we transmit information between and among our affiliates. As a result your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
- Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
- Information for California Residents. California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the “Contact Information” section below.
11. Contact us
Alternatively, you can contact us at our global HQ using the following postal address or telephone numbers:
3rd Floor 86-90 Paul Street
London, EC2A 4NE
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/.