Action and Theory Privacy Statement
This Privacy Statement was published May 24th, 2018. You can see the previous version here.
In Action and Theory we are committed to protect and respect your privacy in compliance with EU- General Data Protection Regulation (GDPR) 2016/679, dated April 27th 2016. This privacy statement explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. This Privacy Statement applies to the use of our products and to our sales, marketing and customer contract fulfilment activities. It also applies to individuals seeking a job in Action and Theory.
Who are we?
Action and Theory is an award winning leadership development consultancy, which partners with a number of international organisations.
Action and Theory Ltd is a company registered in England and Wales Company No: 7683084.
Our registered office is: Action and Theory Ltd, Kemp House, 152 – 160 City Road, London, EC1V 2NX, United Kingdom.
Our Data Protection Officer can be contacted by email email: firstname.lastname@example.org.
When do we collect personal data about you?
- When you are using our services.
- When you interact with us in person, through correspondence, by phone, by social media, or through our websites.
- When we collect personal information from other legitimate sources, such as third-party data aggregators, Action and Theory marketing partners, public sources or social networks. We only use this data if you have given your consent to them to share your personal data with others.
- We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and Action and Theory.
Why do we collect and use personal data?
We collect and use personal data mainly to perform direct sales, direct marketing and deliver excellent customer service. We also collect data about suppliers, partners and persons seeking a job or working in our company.
We may use your information for the following purposes:
- Send you marketing communications which you have requested. These may include information about our products and services, events, activities, and promotions of our associated partners’ products and services. This communication is subscription based and requires your consent.
- Send you information about the products and services that you have purchased from us.
- Perform direct sales activities in cases where legitimate and mutual interest is established.
- Provide you content and venue details on a webinar or event you signed up for.
- Reply to a ‘Contact me’ or other web forms you have completed on one of our Action and Theory websites (e.g. to download a whitepaper).
- Follow up on incoming requests (customer support, emails, or phone calls).
- Perform contractual obligations such as order confirmation, license details, invoice, reminders, and similar. The contract may be with Action and Theory directly or with an Action and Theory partner.
- Contact you to conduct surveys about your opinion on our products and services.
Our legal basis for collecting personal data:
Collecting personal data based on consents
The collection of personal data based on consent from the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consents will always be stored and documented in our systems.
Collecting personal data based on contracts
We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.
Collecting personal data based on legitimate interest
We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between Action and Theory and the individual person has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.
What type of personal data is collected?
We collect name, phone number, title and email address, in addition to your company’s name and contact information. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our websites we may collect IP-address and actions taken on the site.
If you add comments, etc. on our website blog, the information can be read by anyone with access to the website blog and used for purposes over which Action and Theory or you have no control. Therefore, Action and Theory is not responsible for any information you submit to th website blog.
If you apply for a job at Action and Theory, we collect the data you provide during the application process.
Action and Theory does not collect or process any special categories of personal data, such as public unique identifiers or sensitive personal data.
How long do we keep your personal data?
We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.
This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymised.
Your rights to your personal data
You have the following rights with respect to your personal data:
- The right to request a copy of your personal data that Action and Theory holds about you.
- The right to request that Action and Theory corrects your personal data if inaccurate or out of date.
- The right to request that your personal data is deleted when it is no longer necessary for Action and Theory to retain such data.
- The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications:
- If you want to withdraw your consent to e-marketing, please make use of the link to manage your subscriptions included in our communication. Please note that you may still receive system messages and administrative communications from Action and Theory, such as booking confirmations and other relevant notifications about your account.
- The right to request that Action and Theory provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
- The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
- The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
Any query about your Privacy Rights should be sent to to email@example.com.
This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.
Do we share your data with anyone?
We do not share, sell, rent, or trade your information with any third parties without your consent, except from what is described below:
Third-party Service Providers working on our behalf:
We may pass your information on to our distributors, agents, sub-contractors and other associated organisations with the purpose of them providing services to you on our behalf.
Third-party Product Providers we work in association with:
If required by law:
We will disclose your personal information if required by law or if we, as a company, reasonably believe that disclosure is necessary to protect our company’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.
Use of sub-contractors (processors and sub-processors)
If the sub-contractor processes Personal Data outside the EU/EEA area, such processing must be in accordance with the EU Privacy Shield Framework, EU Standard Contractual Clauses for transfer to third parties, or another specifically stated lawful basis for the transfer of personal data to a third party.
If a new sub-contractor is signed or a change of sub-contractor is performed related to our leadership development service, the customers will be notified in line with our Terms of Service.
Changes to this Privacy Statement
Action and Theory reserves the right to amend this Privacy Statement at any time. The applicable version will always be found on our websites. We encourage you to check this Privacy Statement occasionally to ensure that you are happy with any changes.
If we make changes that significantly alter our privacy practices, we will notify you by email or post a notice on our websites prior to the change taking effect.
Your right to complain with a supervisory authority
If you are unhappy with the way in which your personal data has been processed, you may, in the first instance, contact firstname.lastname@example.org.
If you remain dissatisfied, then you have the right to apply directly to your national supervisory authority for a decision. The supervisory authorities can be contacted at:
Information Commissioner’s Office (ICO)
Federal Data Protection and Information Commissioner (FDPIC)
Valstybinė duomenų apsaugos inspekcija in Lithuanian
Each individual German state has a Data Protection Authority which is responsible for the enforcement of data protection laws and competent in respect of data controllers established in the relevant state