Privacy Notice: Data Protection Compliance

The General Data Protection Regulation (GDPR), which comes in force on 25th May 2018, brings with it a requirement to keep individuals informed about how their data is collected, stored, processed and generally protected.

This is the privacy notice of Zomi Communications Ltd, incorporating The Gravitas Programme. In this document, “we”, “our”, or “us” refer to Zomi Communications Ltd. It serves to inform our clients, contacts and contractors (“contacts”).

We are company number 06299339 registered in England, UK.

Our registered office is at Manger House, 62a Highgate High Street, London, England, N6 5HX. Our email is info@gravitasprogramme.com.

What this privacy notice is for

At Zomi Communications Ltd, we give protection of privacy and confidentiality the highest consideration. The purpose of this policy notice is to provide information about how Zomi Communications will use (or “process”) personal data about its contacts.

This information is provided because Data Protection Law gives individuals rights to understand how their data is used. Contacts are all encouraged to read this Privacy Notice and understand Zomi Communications Limited’s obligations.

Anyone who works on behalf of the Zomi Communications Limited such as employees, associates, contractors and service providers should also be aware of and comply with this Privacy Notice.

Why Zomi Communications Ltd needs to process personal data

In order to carry out its business operations Zomi Communications Limited needs to process a range of personal data about individuals as part of its daily operation.

Uses of personal data will be made in accordance with the company’s legitimate interests, or the legitimate interests of another, provided that these are not outweighed by the impact on individuals, and provided it does not involve special or sensitive types of data.

The company expects that the following uses will fall within that category of its “legitimate interests”:

  • Administration of masterclasses, workshops, coaching sessions and other profiling tools, training products and vehicles (including administration of the finance surrounding these operations)
  • Publication of regular updates, reminders and marketing materials
  • General correspondence (by post, telephone or email)

Types of personal data processed by Zomi Communications Limited

  • Identity data which may include your first name, maiden name, last name, title, gender and date of birth. This may also include photographs and film featuring your image.
  • Contact data which may include work and/or personal addresses (postal and email) and telephone numbers, as provided by you
  • Transaction data which may include details about payments between us and other details of bookings made by you or your employer and any notes collected during courses or coaching sessions pertinent to your development
  • Technical data which may include IP addresses, browser type and version, browser location, operating system and platform and other technology on the devices you use to access this site
  • Usage data which may include information about how you use our website, products and services
  • Marketing and Communication data which may include your preferences in receiving marketing communications and your communication preferences.

How Zomi Communications Limited collects data

The company receives personal data from the individual directly or from your employer. This may be in the form of data collected via our website, from your employer, or during the ordinary course of interaction or communication with you.

How we use your personal 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 or between us and your employer
  • 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

Who has access to personal data and who Zomi Communications Limited shares it with

It may be necessary to share your personal data with our team of trainers, facilitators, and administrators, who may be contractors rather than employees of Zomi Communications Limited. Our administration, finance and marketing functions may also be performed by contractors and we will also be required to share certain information with them for the completion of their roles. All of our contractors adhere to strict security standards.

Otherwise, personal data collected will remain within the company.

How we communicate our services to you

You will receive marketing communications from us if you have:

  • requested marketing information from us; or
  • purchased services from us; or
  • you have provided us with your details when you registered on our website; and
  • in each case, you have not subsequently opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by unsubscribing or contacting us.

How long we keep personal data

Data pertaining to development training and coaching sessions is maintained by the company for a period of three years after the completion of your training sessions or coaching with us. This is the minimum period required by our Professional Indemnity insurance. Once consent has been granted by you, contact information for marketing purposes will be kept indefinitely.

Images and films

During our work we may photograph or film individuals, however this will always be with the express permission of those involved and is for the purpose of capturing and sharing the work we do. We will never use images or footage of an individual in any of our marketing material or on our website without first having received written agreement to the usage of their image in this way.

Your rights

Individuals have various rights under Data Protection Law to access and understand personal data about them held by the company and in some cases ask for it to be erased or amended, or for the company to stop processing it, but subject to certain exemptions and limitations.

Any individual wishing to access or amend their personal data, or who has some other objection to how their personal data is used, should put their request in writing to the company using the address above or via: info@gravitasprogramme.com.

Webcam contact

From time to time we may arrange a meeting with you via a Webcam video calling package. The agreed package will not collect your personal information and sessions are not recorded unless express agreement is obtained from you. Video calls take place using Secure Socket Layer (SSL) encryption to ensure they remain confidential. You will be sent details about your session by email or via calendar invitation. If you want to keep these details private please use an email address that only you have access to.

The software may remain on your device once the session has finished, it may also leave cookies. However, these will not contain identifiable information about you or your meeting.

Cookies

Like most websites, this one uses ‘cookies’, small packets of data that are stored in your web browser. Cookies help us to identify information such as how many people are using our site and what devices they’re using. We also use Google Analytics to analyse data and aggregate patterns of use. This allows us to tailor our service to best meet the needs of the people using it.

You can manage how your browser handles cookies, or refuse them altogether, by changing your settings. www.aboutcookies.org has useful information on how to manage cookies in your browser.

By using this website, you are giving consent to our use of cookies.

Consent

We rely on your consent to engage in certain types of electronic (email/telephone) activity. You may withdraw your consent to receiving such communications at any time by contacting the company.

This policy

Zomi Communications Ltd will update this Privacy Notice from time to time and an updated policy will be posted on our website. You should check for any changes to the policy at regular intervals.

Queries and complaints

Any comments or queries on this policy should be directed to the Company via: info@gravitasprogramme.com.

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