Privacy Policy 

National Dealer Academy Limited and Finance Cover and Training Limited trading as Calibre Group Solutions (“Calibre”) are totally committed to ensuring that your privacy is protected. Please be assured that any information you provide when using this website or to us by any other means will only be used in accordance with this privacy policy.

We have always complied with the Data Protection Act 1998 and have updated this privacy policy to comply with the General Data Protection Law (GDPR), effective 25th May 2018.

Calibre recognizes that privacy is vitally important when using the Internet for communications. Our privacy policy explains how Calibre collects, stores, uses and shares Personal Data. It also gives your rights under the GDPR law, including the rights for access to what data we hold.

This Policy issued by Calibre is addressed to individuals outside our organisation with whom we interact, including visitors to our website (our “Site”) and other users of our services (“you”).  

We’ve tried to keep it as simple as possible, but if you’re not familiar with terms, such as cookies, IP addresses, pixel tags and browsers, then read about these  key terms first. Your privacy matters to us, so whether you are new to Calibre or a long-time user, please do take the time to get to know our practices – and if you have any questions contact us.

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes) on our website. We will also keep prior versions of this Privacy Policy in an archive for your review.

Who is the Data Controller?
The Controller for the purposes of the GDPR is:

National Dealer Academy Limited and Finance Cover and Training Limited trading as Calibre Group Solutions

Managing Director: Sabina Hegarty

Coach House, Bellevue Mews, London N11 3NY, Phone: 020 8368 7344

Email: contact@calibregroup.co.uk , Website: www.calibregroup.co.uk

Security
As controller we have introduced physical, electronic, administrative and managerial procedures to safeguard and secure the information we collect from you to protect your Personal Data against accidental, unlawful or unauthorised disclosure.

If you have any concerns about providing any data, you can also provide it by telephone. We have implemented appropriate technical and organizational security measures designed to ensure that your personal data remains private and secure.

Who is the Data Protection Officer?
It is not mandatory for us to appoint a Data Protection, but we feel strongly that there should be one point of contact to ensure any issue or concern is handled quickly and efficiently.

The Data Protection Officer of the controller is:

Ms Ali Starrett

National Dealer Academy Limited and Finance Cover and Training Limited trading as Calibre Group Solutions

Coach House, Bellevue Mews, London N11 3NY, Phone: 020 8368 7344

Email: contact@calibregroup.co.uk , Website: www.calibregroup.co.uk

You may, at any time, contact our Data Protection Officer directly with any questions or suggestions regarding data protection.

Should you wish to make a request to access your data, please contact our Data Protection Officer, and we will provide the details securely, free of charge within a maximum of one month, unless there is any legal reason why we must not.

If at any time you should wish to opt out of receiving any communication from us, please contact our Data Protection Officer directly.

Cookies
The web pages of Calibre use cookies. Cookies are text files that are stored in your computer/device via your web browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID, which is a unique identifier of the cookie, so websites and servers can be assigned to the specific web browser where the cookie was stored. This allows visited websites and servers to differentiate the individual browser of the data subject from other browsers that contain different cookies. A specific web browser can be recognized and identified via the cookie ID.

Through the use of cookies, Calibre can provide the users of our “site” with more user-friendly services that would not be possible without the cookie setting.

At any time you may prevent the setting of cookies through our site by adjusting the settings on your web browser, denying the setting of cookies. Also, cookies already set may be deleted at any time via your web browser. If you deactivate the setting of cookies in your web browser, it may be that not all functions of our site are fully usable.

Your Personal Information
Information you provide via our website is held on secure servers and will not be sold, shared or divulged under any circumstances except if required by law. We will only use your personal information for the purposes of delivering the service you requested when providing it.

This Policy
Lawful basis for Processing Personal Data: 
We have to have a lawful basis for processing your Personal Data as set out in Article 6 of the GDPR. At least one of these must apply whenever we process personal data. We have identified the following legal bases for processing your Personal Data:      

In Processing your Personal Data, we may rely on one or more of the following legal bases, depending on the circumstances:

we have obtained your prior express consent to the Processing. This legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way.

  • The Processing is necessary in connection with any contract that you may enter into with us;

  • The Processing is required by applicable law;

  • The Processing is necessary to protect the vital interests of any individual; or

  • We have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms. For example, where you have previously engaged with us or purchased our products prior to the GDPR becoming law.

Collection of Personal Data: 
We may collect Personal Data about you, such as your name, address and contact details. Examples of sources from which we may collect Personal Data include the following:

  • We may obtain your Personal Data when you provide it to us: e.g. where you select the “contact us” option on our site and “opt-in” to receive communication via email, telephone or other means.

  • We may collect your Personal Data in the ordinary course of our relationship with you.

  • We may collect or obtain Personal Data when you visit our Site or use any features or resources available on or through our Site. When you visit our Site, your device and browser will automatically disclose certain information, some of which may constitute Personal Data (see below).

  • Creation of Personal Data: We may also create Personal Data about you, such as records of your interactions using our Site, and details of your account history.

We will only process and store your data for the period necessary to achieve the purpose of the storage, or as required by UK and EU law. If the storage is no longer required or the law dictates that we should no longer keep it, we will securely erase it.

Categories of Personal Data: 
The categories of Personal Data about you that we may Process include:

Personal details: given name(s); preferred name; gender; date of birth / age; nationality; photograph; preferences; and account settings.

Contact details:  telephone number; email address; and social media profile details.

Professional details: professional profile details; association memberships; qualifications and company insight data.

Device details: device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to our Site and other technical communications information.

Payment details: billing address; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date.

Usage details: records of your use of our Site and other services, including: registrations; details of content with which you interact; votes; questions; downloads; ratings; feedback; profile views; search queries; anonymous viewings; page views; player clickstream; chapters; and favourite moments.

Analysis data:  keywords, communities, trends, content quality and content importance.

Views, opinions and interests:  any comments, ratings, views or opinions that you choose to send to us, post via our Site, via a survey, or publicly post via social media platforms; your community interests and solution interests.

Processing your Special Category Data (Sensitive Personal Data) (For definition see Key Terms): We do not seek to collect or otherwise Process your Special Category Data, except where:

  • The Processing is required or permitted by applicable law (e.g. to comply with our diversity reporting obligations);

  • The Processing is necessary for the detection or prevention of crime (including the prevention of fraud);

  • The Processing is necessary for the establishment, exercise or defence of legal rights; or

  • We have, in accordance with applicable law, obtained your prior explicit consent prior to Processing your Special Category Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Purposes for which we may Process your Personal Data:  The purposes for which we may Process Personal Data, subject to applicable law, include:

Our Site:  operating and managing our Site; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Site.

Provision of services to you: providing our Site and other services to you (including suggesting content that may be of interest to you, based on your past activity); communicating with you in relation to those services; recommending content that may be of interest to you; and recommending your content to others.

Marketing communications:   communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law.

Communications and IT operations:  management of our communications systems; operation of IT security; and IT security audits.

Health and safety:  health and safety assessments and record keeping; and compliance with related legal obligations.

Financial management:  sales; finance; corporate audit; and vendor management.

Surveys: engaging with you for the purposes of obtaining your views on our Site or our services.

Improving our Site and our services: identifying issues with existing Site and our services; planning improvements to existing Site and our services; creating new Site and our services.

Disclosure of Personal Data to third parties
We will not share your details with anyone outside of Calibre Group Companies, with the exception of your CV details, only after you have “opted-in” for us to do so.

Minors
Minors under the age of eighteen years old are not eligible to use our Site and we therefore ask that minors do not submit any Personal Data to us, or use any of the services provided on, through or via our Site.

International transfer of Personal Data
We will not transfer your Personal Data to other countries outside the UK.

Data Accuracy
We take every reasonable step to ensure that:

  • Your Personal Data that we Process is accurate and, where necessary, kept up to date;

  • Any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

Data Minimisation
We take every reasonable step to ensure that your Personal Data that we Process is limited to the Personal Data reasonably required in connection with the purposes set out in this Policy.

Data Retention
The criteria for determining the duration for which we will keep your Personal data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

Your legal rights
Subject to applicable law, under GDPR you have rights regarding the Processing of your Personal Data, including:

  • The right to be informed, encompassing our obligation to provide you with ‘fair processing information’, which is through this privacy notice.

  • The right of access to your personal data and supplementary information and for us to be aware of and verify the lawfulness of the processing.

  • The right to rectification if your personal data is inaccurate or incomplete.

  • The right to erasure, also known as ‘the right to be forgotten’, enabling you to request the deletion or removal of personal data where there is no compelling reason for its continued processing.

  • The right to restrict processing of your personal data, enabling us to store the data, but not further process it, ensuring the restriction is respected in future.

  • The right to data portability, allowing you to obtain your data securely and reuse it for your own purposes across different services, without hindrance to usability.

  • The right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.

  • Rights related to automatic decision making and profiling and if applicable give you information about the processing, introduce simple ways for you to request human intervention or challenge a decision and carry out regular checks to make sure that our systems are working as intended.

This does not affect your statutory rights.

You have right to escalate a complaint to the Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf. The Authority for this is the Information Commissioner’s office, who can be contacted at, casework@ico.org.uk

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact the Data Protection Officer using the contact details above. If you do request that we supply you with the personal data we hold, we will provide this within a maximum of one month and will not charge a fee for the access.

Key terms
‘Controller’ means the entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

‘Data Protection Authority’ means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws. In the UK this is the Information Commissioner’s Office (ICO).

‘Personal Data’ means information that is about any individual, or from which any individual is identifiable. Examples of Personal Data that we may Process are provided in Section (3)

‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

‘Processor’ means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

‘Special Category Data’ means Sensitive Personal Data about race or ethnic origin, political opinions, religious beliefs, trade union membership, health, sex life or sexual orientation, genetics or biometrics, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.

We keep your personal information private and safe — and put you in control.

Dated 20th February 2018