Privacy Policy

Overview

iTrain is committed to protecting the privacy of all data subjects it interacts with during the normal course of business. This privacy notice sets out the basis on which any personal data collected, provided to or processed by iTrain is managed in line with the requirements of European Union's General Data Protection Regulation (GDPR) and other applicable/prevailing data protection regulatory requirements.

Personal Data

Under the GDPR personal data is defined as:

"any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

Responsibilities

All employees/staff and contractors of iTrain who interact with data subjects are responsible for ensuring that they are aware of this privacy policy and that the processing of their data by iTrain is allowed. For questions, comments and requests regarding this privacy notice please contact iTrain via email or by using the Contact page.

The Managing Director is responsible for all aspects of iTrain's Privacy Policy as well as for ensuring that this notice is made available to data subjects prior to iTrain processing their personal data.

Who is iTrain?

iTrain is the controller and responsible for your personal data and is based at 5th Floor, 167-169 Great Portland Street, London, W1W 5PF. iTrain provide training and consultancy services to professional service firms in the UK and overseas.

Why does iTrain need to collect and store personal data?

To assist iTrain in providing their training and consulting services, iTrain needs to collect personal data for business development, marketing, introductions, industry news, referrals, business services and other activities required in the operation of a standard consulting business, iTrain's "Legitimate Business Interest".

Usage

iTrain will;

• Process (collect, store and use) the information you provide in line with the European Union's General Data Protection Regulation (GDPR).
• Endeavour to keep your information accurate and up to date.
• Keep it no longer than is necessary.
• The iTrain team will adhere to client data privacy policies provided to iTrain in writing and exclusively use iTrain client systems for email, the storage of client data and any other client related activities.
• Excluding contractual agreements, invoices and business support documents, no client specific data is stored on iTrain's internal business systems.
• Any personal information provided, collected or processed will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Third Parties

As part of the services provided, iTrain may share your personal data with third party service providers acting as processors who provide IT and system administration services (including the iTrain Chatbot Ali chatbot service), professional advisers, auditors and insurers regulators and other authorities who require reporting of processing activities in certain circumstances. Any third parties that iTrain shares your personal data with other than regulators and His Majesty's Revenue & Customs are obliged to keep your details securely and only use them to deliver the service they provide to iTrain. When your data is no longer required, they will dispose of the details in line with iTrain procedures, unless we are legally required to do otherwise. iTrain will never only pass on sensitive personal data to a third party without prior written consent.

iTrain do not transfer your personal data outside of the European Economic Area (EEA).

How and What Personal Data is Collected?

Personal data is collected when you apply for our products and services, enter into a contract for our services and through the standard business channels of general correspondence (phone/email), networking events, recommendations, referrals, business cards, internet searches and work focussed social media profiles.

Normally, only standard business contact details are retained such as name, job title, email address, phone and LinkedIn profile. Where iTrain needs to collect your personal data by law, or under the terms of a contract it has with you and you fail to provide that data as requested, iTrain may not be able to perform the contract it has with you.

iTrain Business Systems

iTrain solely uses cloud-based systems (Microsoft 365, iManage, HubSpot, and others) for the retention of all business data with two-factor (multi-factor) and single sign-on authentication systems in place where available. Please note that the transmission of information via the internet is not completely secure and therefore iTrain will do its best to protect your personal data but cannot guarantee the security of any data transmitted.

iTrain Chatbot Ali Service

iTrain's Chatbot Ali is a chatbot service providing focused training services geared to an individual's training requirements at their 'Point of Need'. This service is an on-premise web interface accessible to all individuals. Mobile Coach LLC (www.mobilecoach.com) acts as the data processor on behalf of and under the control of iTrain in respect of all processing activities. Usage by individual users is tracked and reports provided to clients on a quarterly basis. All personal data is processed and stored within a UK data centre and only agreed Chatbot questions, system infrastructures and usage reporting analytics are stored in this data centre. All client specific training content remains with the client infrastructure and is accessed through secure hyperlinks by the Service.

Lawful Basis for Processing Personal Data

iTrain may process your personal data for more than one lawful ground depending on the specific purpose for which it uses your data.

Set out below in table format is a description of the ways iTrain plan to use your personal data and the legitimate bases relied on.

Purpose / Activity	Type of Data	Lawful Basis for Processing
To register you as a new client / customer	Identity Contact	Performance of a contract with you
To process and deliver your order, manage payments, fees and charges, and to collect and recover money owed	Identity Contact Financial Transaction Marketing and communications	Performance of a contract with you Necessary for our legitimate interests
To manage our relationship with you	Identity Contact Profile Marketing and communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests
To administer and protect our business, website, systems, servers and data hosting services	Identity Contact Technical	Necessary to comply with a legal obligation Necessary for our legitimate interests
To provide individual user training	Identity Contact	Consent Necessary for our legitimate interests

Where Consent is required to process personal data this must be explicitly given for iTrain to process such personal data. When sensitive personal data is requested, iTrain will always outline how and when information will be used.

You may withdraw consent at any time by contacting iTrain via email or by using the Contact page form, and a written confirmation of your withdrawal and deletion of your personal data will be sent to you within in 14 working days.

Retention Period

iTrain is required to retain information in accordance with the law. How long certain kinds of personal data should be kept may also be governed by regulatory bodies, agreed practices and specific business-sector requirements. Personal data may be held in addition to these periods depending on individual business needs.

Unless otherwise required, iTrain will store and process personal data for as long as is reasonably necessary to fulfil the purposes it was collected.

Your rights as a Data Subject

At any point while iTrain is in possession or processing your personal data, you, the data subject, have the following rights;

• Right of access – you have the right to request a copy of the information iTrain holds about you.
• Right of rectification – you have the right to correct data that iTrain holds about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data iTrain holds bout you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your personal data.
• Right to portability – you have the right to have the data iTrain holds about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

Under what circumstances will iTrain contact me?

iTrain may contact you directly from time to time when it has your express consent to do so, or is acting in accordance with the performance of its contract with you or in circumstances in which it has a legitimate interest, such as sending you email promotions or newsletters of interest.

Can I find out the personal data that iTrain holds about me?

At your request, iTrain can confirm what information we hold about you and how it is processed. In the event iTrain holds personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of iTrain or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.

What forms of identification will I need to provide in order to access this?

When personal data access is requested, iTrain accepts passport, driving licence, birth certificate, or a utility bill no more than three months old.

Complaints

In the event you wish to make a complaint about how your personal data is being processed by iTrain, or third parties, or how your complaint has been handled, you have the right to lodge a complaint directly with the ICO supervisory authority (https://ico.org.uk/concerns) or iTrain.

Changes to this iTrain Privacy Notice

Any changes iTrain makes to this privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back on a regular basis to see any updates or changes.