This policy also explains your privacy rights and how the law protects you, including how we comply with the General Data Protection Regulation (“GDPR”) and other related legislati on that relates to the use of personal data.
Additional information may be provided on particular pages of this website, for example, on any specific pages where we collect personal data, and you should also refer to those. We also operate cookies on our website and information about that is also provided separately in our Cookies Policy.
Emerald Works Limited is the data controller and is responsible for the use of your personal data. Our full details are set out below.
Address: Emerald Works Limited, Level 1, 50 Frederick Street, Edinburgh, Scotland EH2 1EX
Tel: +44 2077 887 978
You have the right to make a complaint to the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, like the opportunity to assist you with any concerns, so please contact us in the first instance using the details above.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third party links
This website may include links to third party websites, such as our Twitter, Facebook and LinkedIn social media pages. Clicking on those links may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy policies. You should read any policies and other statements on such websites carefully.
Data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data that has been anonymized, such that a person’s identity is removed.
The following information explains the types of personal data that we collect, use, store and transfer. We will only use your personal data as the law allows us to. The categories of personal data that we use include:
- Identity and contact data such as names, titles and other identifiers together with address, email address and telephone numbers.
- Technical data including internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, access times, operating system and platform and other technology on the devices you use to access this website. This may also include information about how you use our website.
- Profile data, such as username and password details.
- Marketing and communications data, which includes preferences in receiving marketing from us and your communication preferences.
- Career data, including your CV, career history information and information about you, including references.
- Financial data (if you are a consumer using the website www.mindtools.com) such as bank account or card payment details when you place an order by signing up to the Mind Tools Club.
How we will use your data
The information below also explains the purposes for which we use different categories of personal data and the legal basis or bases that we believe applies to those uses, where you use the website www.emeraldworks.com or www.mindtools.com. We may process your personal data for more than one lawful basis depending on the purpose for which we are using your data.
We may process your personal data for our legitimate business purposes (or those of our group companies), such as:
- to deliver our products and services;
- to administer this website, including troubleshooting, data analysis, testing, system maintenance and support, so that we can provide and improve the products and services we offer and ensure our website operates properly, and for network security;
- to provide you with marketing communications such as our newsletter if you have shown an interest in receiving information about our products and services;
- to assess and, where appropriate, deal with your application, if you express an interest in working for us;
- to ensure our third party providers can perform their obligations to us; and
- to gather your feedback on our products and services.
If you are a consumer and use the website, www.mindtools.com, we may process your financial data to administer your subscription when you place an order and sign up to the Mind Tools Club, so that we can provide our services to you. This is necessary for the performance of the contract that will be in place between us.
In addition, we may disclose information about you to the extent that we are required to do so by law or for the purpose of legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention) and where we may otherwise do so in accordance with applicable data protection legislation.
How is your personal data collected?
Most of the personal data that we hold is collected either directly through you (or your colleagues), or when you otherwise get in contact with us, for example, by email, over the phone, or through the use of our website. For example, you might provide certain identity information by completing one of our online forms such as on our 'Contact us' page, if you make an enquiry with us, or if you subscribe to our newsletter.
If you fail to provide personal data
Where we need to collect personal data by law, under the terms of a contract we have with the organization you represent or for another lawful reason and you fail to provide that data, we may not be able to fully perform our obligations in accordance with our contract, provide you with the information you require or otherwise properly deal with your request.
Marketing and promotions
From time to time we may use your data including identity and contact data, technical data and marketing and communications data, to contact you with information about our products and services. You will receive marketing communications from us if you have agreed to be included on our marketing database.
You can ask us to stop sending you marketing messages at any time by contacting us at any time by calling us or writing to us by post or email, using the contact details provided above.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will explain the legal basis that allows us to do so. Please also note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
If you would like further information about how we use personal data and the purpose that we might use it for, please contact us using the contact details set out above.
Disclosures of your personal data
We may transfer your personal data to affiliated companies within the Emerald Group. More information about our group companies can be found on the Emerald Group website here: www.emeraldgroup.com.
Your personal data may sometimes be electronically transferred outside the European Economic Union (EEA) (or, in the event the United Kingdom (UK) ceases to be a member of the EEA, the UK) to Emerald’s (and those of our group companies) international offices, for the purposes of providing our products and services and facilitating Emerald Group’s company central management and administration.
Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the safeguards permitted by law is in place.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Those rights are listed below. Please contact us if you would like to exercise any of them. You have the right to:
- Request access to your personal data (a 'subject access request'). This means you can receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. You can ask us to remove personal data where there is no good reason for us continuing to process it. You also have this right where you have successfully exercised your right to object to processing, where we may have processed your data unlawfully or where we are required to erase your personal data to comply with law. We may not always be able to comply with your request where there are particular legal reasons.
- Object to processing of your personal data where we rely on a legitimate interest basis and if the processing impacts on your fundamental rights and freedoms. You can also object to direct marketing. In some cases, we may demonstrate that we have grounds to process your data, which override your rights and freedoms.
- Request restriction of processing. You can ask us to suspend the processing of your personal data: if you want us to establish the data’s accuracy; where our data use is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer need it, to establish, exercise or defend legal claims; or you have objected to use of data but we need to verify whether we have overriding legitimate grounds to use it
- Request a data transfer. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. This only applies to automated information that you provided consent for us to use or is necessary to perform a contract with you.
- Withdraw consent at any time where we rely on consent to process your personal data. This will not affect the lawfulness of processing carried out before you withdraw your consent.
Exercising your rights
You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests, in which case we will keep you updated.
As Emerald is no longer resident within the EU, the GDPR requires us to appoint a GDPR representative under Article 27 of the GDPR, as a point of contact for you if you are an EU citizen. We have formally appointed GDPR-Rep.eu. If you are an EU citizen and you would like to make a data subject request, please visit https://gdpr-rep.eu/q/12993813.