PRIVACY POLICY
1. Purpose and Scope
The Study Centre undertakes to ensure the confidentiality of the personal data of all persons (hereinafter referred to as personal data subjects) who were/are in contact with it. Such personal data subjects may include applicants, students, course participants, other seekers of education or services of the Study Centre, or legal entities that are customers of these services or their performers on the basis of relevant agreements. This includes protecting data from unauthorized access, modification, disclosure, or destruction, as well as managing them in accordance with current data protection legislation.
The purpose of this privacy policy is to clearly, concisely and transparently define how the Study Centre collects, stores and uses personal data. Each personal data subject familiar with this document has given their consent to the collection, storage and use (including accumulation, processing and exchange) of data by the Study Centre. They have also been informed of their rights and the purposes of data collection.
The Study Centre is responsible for communicating this privacy policy to all interested parties.
2. Collection methods
The Study Centre collects personal data:
- when communicating with the center by phone, email, website or web chat,
- when subscribing to services or in the case of orders,
- in the process of interaction with messages sent by the Study Centre,
- by obtaining personal information from companies where the subjects of personal data study or work,
- when requests are received through external suppliers,
- when participating in events to establish professional connections,
- in case of reports of problems with the websites or services of the Study Centre,
- during the controlled online assessment,
- when registering third-party software related to the products and services of the Study Centre.
The Study Centre may also collect information if a person consents to the use of cookies during a visit to the website.
Telephone conversations may be recorded for the purpose of staff training or dispute resolution. Recordings are stored for 3 months and are only accessible to the customer service management team.
The content of the chat, pre-chat and post-chat surveys are stored for 13 months. During this period, you can request that such content be edited, which will result in the removal of all personal information, by sending an email to data@cim-mia.com.
3. Collected information
The Study Centre may collect the following information about personal data subjects:
- name, date of birth, contact information (address, telephone, email),
- information about the place of work (company name, position, address),
- payment details (if necessary),
- resume (to confirm experience, skills, membership, etc.),
- IP address, geolocation when visiting the center's web resources,
- data on the use of websites and online services of the center,
- information from cookies,
- identification photographs (passport, driver's license) for online assessment.
If individuals consent to receive marketing communications, information about their interaction with the emails (opening, clicking on links) is collected. This is necessary to analyze the effectiveness of communications.
The Study Centre takes appropriate technical and organisational measures to protect the personal data of personal data subjects from the risks of loss, unauthorised access, destruction, use, modification or disclosure.
Information is considered non-confidential if the person has made it publicly available, as well as data available from open sources for the Study Centre or third parties.
Special category data
The Study Centre does not generally collect data about special categories. However, some individuals may provide health-related information if it is necessary to receive services from the center. For example, participants may share such data to make reasonable health adjustments to an assessment or to allow a deferment. Similarly, guests and delegates at events may provide information about dietary requirements.
This information is stored only for the required period and is used solely for its intended purpose.
The legal bases for using information
The Study Centre uses personal information to:
- processing purchases and providing our services,
- establishing and maintaining contacts with persons,
- improving user interaction with the website.
When making purchases, the Study Centre collects the following data:
- name, date of birth, contact information (phone, email),
- address, billing address,
- company name and its details (if necessary)
This information is necessary for the execution of the contract. Without its provision, persons will not be able to purchase or enter into contracts with the Study Centre.
After purchase, the Study Centre may send messages about its products and services. This is done out of legitimate interest. Individuals may opt out of such messages or, conversely, agree to receive marketing mailings.
For free products and services, data is processed on the basis of legitimate interest exclusively for a specific purpose.
5. Sharing data with
The Study Centre will transfer personal data to third parties only for the purpose of providing services, fulfilling concluded agreements, if required by law or to ensure the protection of legal rights.
Third-party communications
Also, the Study Centre does not disclose information about a person to third parties in order to obtain commercial information from them, unless the person has specifically provided consent to do so.
Service providers
The Study Centre discloses personal data to third parties only when necessary to provide its services and conduct business. Such third parties include:
- telephone and email providers,
- payment service providers,
- IT providers,
- hosting companies,
- postal services and printing houses,
- providers of benefits for participants,
– digital accreditation provider.
The Study Centre also uses Google Analytics and Google Signals to analyze user behavior on the site. Any personal data associated with this is anonymized.
Personal data will not be disclosed to third parties for the purpose of obtaining commercial information from them unless individuals provide explicit consent to this.
Social media and third-party advertising partners
The Study Centre may collect certain anonymous or pseudonymous data about visitors to the website, their interactions on social networks and other online platforms, and when clicking on published links. This includes IP address, device location, time and date of access, referring websites and information about the links distributed.
This data processing is carried out for the purpose of monitoring user engagement and adapting the products and services of the Study Centre.
Mailing, Printing and Fulfilment Companies
The Study Centre will disclose personal data only to printing companies and companies performing tasks on behalf of the centre, exclusively for agreed purposes, such as sending out magazines, prompt communication with members or marketing mailings. These data are properly encrypted and deleted once the specific purpose has been achieved.
Payment information
The Study Centre:
- does not store credit/debit card data except for the purpose of paying for services. This data is securely stored and deleted after payment,
- does not transfer financial information to third parties,
- may engage other companies (payment processors, direct debit services) to provide financial services to individuals. These companies use the data only to perform the tasks of the Study Centre.
Research
The Study Centre has the right to transfer personal data to third parties for the purpose of conducting research activities on its behalf, including interviewing training subjects, only with the prior written consent of the personal data subjects for such processing. The personal data subject has the right to change the consent parameters at any time through the official website of the Center.
Qualifications
Evaluation procedure: The following data of education applicants are provided to the evaluation platform providers: last name, first name, patronymic, registration number and results of qualification tests/evaluation.
The system for presenting assessment results: The surname, first name, patronymic and registration numbers of education applicants are transmitted to the external control presentation and assessment system.
Remote Assessment Platform: The third-party service provider is provided with the education seeker's full name, email address and registration number.
Locations of certification: If necessary, the following data may be transferred to examination centers: surname, first name, patronymic, registration number, contact e-mail address and phone number of the applicant for education. The transfer is carried out solely for the purpose of communication regarding the visit and the collection of a pre-agreed additional fee. After completion of certification measures, personal data is subject to destruction.
Video conferencing platforms Zoom, Google Meet: Remote classes with education seekers and other persons are subject to mandatory recording. The storage period for video recordings is 18 months. In the event of unresolved disputes, the storage period may be extended to one year.
Verification requests
The Study Centre has the right to receive and process requests for verification of membership and qualification level of training subjects. As part of the exercise of administrative and disciplinary powers, the Center has the right to provide third parties with information on membership status, qualification level and status of a certified marketer without obtaining the prior consent of the personal data subject. Outside of the specified cases, the provision of any information is carried out exclusively with the presence of a duly executed and signed consent from the personal data subject.
Disciplinary
In the event of a violation of disciplinary proceedings in relation to a member of any qualification level, provided that the validity of the complaint is confirmed, the Center shall make public the personal data of such member and the results of the disciplinary proceedings. Such processing of personal data shall be carried out on the basis of the legitimate interests of the Center.
Sharing information for legal reasons
The Centre undertakes to provide information about personal data subjects in cases stipulated by the rules of common law or legislative requirements. In particular, this may concern information about illegal actions or threats to public safety.
6. Retaining data
The Study Centre stores personal data only for the period necessary to achieve the purpose of their processing. The storage period is determined taking into account:
- regulatory and legal requirements for the Center (in particular, in the area of tax accounting);
- terms of contractual relations with personal data subjects;
- the presence of consent of the subjects of personal data;
- the legitimate interests of the Center as a business entity.
As a general rule, the processing and storage of personal data is carried out during the term of the Agreement and 3 (three) years after its termination.
Purchase
When personal data subjects purchase educational/consultative or other services from the Study Centre, in particular training courses, events, etc., the Centre shall store the relevant information for 6 (six) years after the end of the financial year in which the purchase took place, in accordance with the requirements of tax legislation. In cases of purchase of materials regulated by the Copyright, Designs and Patents Act 1988, copyright declarations shall be stored for 7 (seven) years in accordance with the legislation.
Requests
In the absence of consent from the subject of personal data to further communication, the information is stored for the period necessary to process and fulfill the request, and additionally for 12 (twelve) months, after which it is subject to deletion.
Membership
Membership information is retained for 10 (ten) years from the date of the last update for the purpose of:
- verification of member status;
- provision of information on previous membership history upon request of third parties;
- providing the opportunity to renew membership.
Qualifications and assessments
Qualification data, including assessment results, shall be retained for 25 (twenty-five) years to ensure verification of the qualification level. Records of the real-time assessment process shall be retained for 18 (eighteen) months in accordance with the requirements of the external regulatory audit of the Study Centre.
Register for complimentary activities or content
Personal data of subjects are stored for the entire period of their participation in the relevant events and are subject to destruction after 12 (twelve) months from the date of completion of such participation.
7. Profiling and automated decision making
The Center has the right to use information about interactions with personal data subjects to assess the relevance and quality of its own goods and services. At the same time, the Center does not carry out automated profiling and does not use an automated decision-making system for personal data subjects.
8. Individuals rights
Taking into account the restrictions established by law, the subject of personal data has the right to:
- submit a request to receive a copy of personal data and information on the procedure for their use;
- contact the Study Centre with a request to make changes, delete personal data or limit their processing in case of doubts about their authenticity, the need for deletion or the legality of their use;
- to object to the processing of personal data, taking into account the specific features of a particular situation, in cases where such processing is carried out on the basis of the legitimate interests of the Centre, for direct marketing purposes or for research or statistical purposes;
- revoke the given consent to the processing of personal data. All informational messages from the center contain the option to refuse the mailing;
- receive personal data in a structured, commonly used, machine-readable format for the purpose of transmitting them to another controller. However, in certain cases, the Centre may be prevented from providing some or all personal data, in particular if this may result in a breach of the privacy of third parties.
9. Concerns and complaints
In case of concerns or questions regarding the collection, storage or processing of personal data, the subject of personal data is advised to first contact an authorized employee of the Center to discuss and resolve disputes.
Alternatively, inquiries can be sent to the email address: data@cim-mia.com