For the purposes of the Data Protection Act 1998 (“DPA”), the data controller is Mind Gym Limited. Our registered office is at 160 Kensington High Street, London W8 7RG. Our company registration number is 03833448 and our data protection registration number is Z8884652.
If after reading this policy, you have any queries, please send an email to firstname.lastname@example.org or send a letter to the address above.
1. Your Data
Your “Data” means any information that we collect about you or any information that you provide to us. This includes information by which you are personally identifiable, including, without limitation, your name, address, telephone number, email address, financial details, job title (if you have one), user name (your “Registered User Name”), password, comments posted to us or submitted online, photos and other information from which you can be identified and which you may disclose to us when you use our services or otherwise via the Website at any time. Your Data also includes information about your personal preferences, your lifestyle and personal aspirations. Certain information relating to your physical or mental health or condition may constitute “sensitive personal data”. As there may be circumstances in which we collect sensitive personal data, it is for this reason that we place particular emphasis on ensuring that adequate steps are in place to protect your personal data. If you have concerns about this please contact us.
2.When do we collect your Data?
2.1 We collect your Data from you when you:
2.1.1 register, create or use your Mind Gym account or sign up for any services provided by Mind Gym. Where you have created an account on our Website, we refer to you as a “Registered User”. You will also be asked to choose a suitable user name at the time of registration – this is your “Registered User Name”. Remember, when you register and create a Mind Gym account, it is important to ensure that you keep your Registered User Name and password secure;
2.1.2 provide information by filling in forms through any of our services or products. This includes information provided at the time of registering to use Mind Gym or when you subscribe or sign up to any of our services;
2.1.3 provide us with details about your aspirations and skills that you feel you are lacking in and want to improve;
2.1.3 post a comment on the Website including, without limitation, on a message board or when you send a message to another Registered User;
2.1.4 enter a competition, promotion or other feature hosted by Mind Gym;
2.1.5 make a complaint, report a problem to us, submit an enquiry or provide other feedback through the Website or otherwise; or
2.1.6 disclose your Data to us or otherwise through the Website or at any other point (for example, if you send us a letter or you call us).
3.How do we use your Data:
3.1 We use your Data to:
3.1.1 make suggestions as to the areas of the Website that may be of most interest to you on the basis of the Data that you have provided;
3.1.2 to carry out our obligations arising from any agreements entered into between you and us;
3.1.2 monitor, develop and improve the Website service and experience;
3.1.3 process your registration as a Registered User;
3.1.4 process any competition entry or submission made by you;
3.1.5 process and deal with any complaints or enquiries made by or about you;
3.1.6 monitor and investigate any suspected breach of the Website Terms and Conditions of Use or Registered User Terms made by or otherwise relating to you;
3.1.7 to send you, where we have your consent, our Mind Gym e-newsletter and details of other offers or services that may be of interest to you from time to time by email or by post. If you have decided to opt-in, you can opt-out of receiving any information pursuant to paragraph 3.1.7 at any time. Simply amend your preferences: (i) by sending an email to email@example.com; or (ii) by clicking on the “unsubscribe” link in the e-newsletter or other communication itself;
3.1.8 to notify you about changes to our services.
If you are an existing customer, we will only contact you by electronic means (email or SMS) with information about products and services similar to those which were the subject of a previous sale to you. If you do not wish to continue receiving these emails please send us an email to firstname.lastname@example.org and we will remove you from our mailing list.
4.Will we pass on your Data to third parties?
4.1.If you choose to post a message on our Website or if you upload any other material to our Website you must ensure that you comply with the Mind Gym Terms and Conditions of Use and Registered User Terms. Your chosen Registered User Name will be the identity by which you are known on the Website. This will be publicised and posted on the Website if you choose to post a message or where you upload any other material to our Website. Where other Registered Users wish to exchange tips or otherwise communicate with you, they will be able to identify you by your Registered User Name and any other information you may yourself disclose via the Website.
4.2 Please use your Data responsibly. Always think carefully before disclosing your Data or other information publicly on the Website. It is important that you are aware that any of your Data or other information which you disclose to another Mind Gym registered user may then be disclosed on the Website by that user. As stated in the Terms and Conditions of Use and Registered User Terms, we have no responsibility or control over the contents of communications made between Registered Users although you can make a complaint about another Registered User as detailed in the Registered User Terms.
4.3 We may also pass your Data to other parties as follows:
4.3.1 to our employees and agents to administer your Registered User Account and the services provided to you by us now or in the future or any correspondence or other communication entered into between You and us;
4.3.2 in some cases we may use a technical partner to conduct some processing of your Data on our behalf. This is always subject to strict contractual control and is in compliance with the DPA and we require all of our service providers to maintain the confidentiality of your Data that we disclose to them;
4.3.3 in order to gather some general statistical information about visitors and users of the Website, sales patterns, traffic volumes and related matters, your Data may be passed on to reputable third parties but these details will be anonymised and will not include information personally identifying you;
4.3.4 we may disclose your Data to the police, regulatory bodies or legal advisers in order to comply with any legal obligation, or in order to enforce or apply our agreements with you (the Mind Gym Terms and Conditions of Use or Registered User Terms);
4.3.5 to third parties if you have expressly asked us to do so; or
4.3.6 if we sell or buy any business or assets, in which case we may disclose your Data to the prospective seller or buyer of such business or assets.
4.4 Other than in the circumstances outlined in paragraph 4.3 above, We will not provide your Data to any third party without your consent or unless we are required to do so by law.
5.Data Security and Transfers
5.2 The transmission of information via the internet can never be completely secure. We will protect your Data; however, we do stress that any transmission is at your own risk.
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7. Access to and Updating your Data
7.1 You are responsible for ensuring that the Data that we hold for you is accurate and up-to-date. You must make sure that you update your Data as soon as possible with any and all relevant changes. You can update your details by (i) by sending an email to email@example.com; or (ii) by clicking on the “unsubscribe” link in the e-newsletter or other communication itself;
8. Links to other websites
9. Contact us
9.1 You may request details of personal information which we hold about you under the DPA. A nominal processing fee will be payable. If you would like a copy of the information held on you, please contact us by email at firstname.lastname@example.org, or write to us at 160 High Street Kensington, London, W8 7RG.
9.2 If you believe that any information we are holding about you is incorrect or incomplete, please write to us or email us as soon as possible, at the above address. We will correct any information found to be incorrect as soon as is practicable.
Last updated: 30 January 2015