Data Privacy Policy

1. Statement of Purpose

Breakthrough2Performance respects your privacy and is committed to protecting your personal data. Our Privacy Policy aims to give you information on how we collect and process your personal data when you visit our website, including any data that you may provide when you use our website, or sign up to receive our marketing material and sets out the rights you have in relation to your personal data.

We have a separate Data Processing Agreement which further explains how we collect, process, store and destroy information supplied by you when you engage our services and extends to our commitment of collecting and processing personal data only where it is necessary for us to do so, where it is relevant to the purposes for which it was collected and that it is retained in-line with pre-agreed time-scales, or for as long as we are legally obliged to retain it.

2. About Breakthrough2Performance

In relation to our website and for the purposes of the compliance to the General Data Protection Regulations (GDPR), the Data Controller is
Breakthrough2Performance Limited (referred to as ‘we’, ‘our’, ‘B2P’).

The user of our website and other business or personal contacts that we deal with as customers or suppliers, are referred to within this Policy as
‘you’, ‘your’, ‘user’.

Our full contact details are:-

Full Name of Legal Entity:
Breakthrough2Performance Limited

Registered Office:
15 Towcester Road, Old Stratford, Milton Keynes MK19 6AN

Postal and Office Address:
8 Hamilton Lane, Far Bletchley, Milton Keynes MK3 5LU

Registered Number:
8309281 (Registered and operating in England)

3. Collection of your Data

Personal data relates to information about an individual from which that person can be identified e.g. does not include data where the identity has
been removed ‘anonymous’ data.

Breakthrough2Performance may collect, use and store different kinds of personal data about you either as a result of:-

1. You accessing our website;

2. Direct interaction by filling in forms, corresponding with us by post, phone or email;

3. Discussing the provision or engagement of our services;

4. Completing an on-line enquiry;

5. Providing a service to us;

6. Requesting to be included in our marketing activities.

Such data may include:-

Contact Data:
Your title, name address, email address, telephone numbers, business name, billing address, payment details.

Technical and Usage Data:
Information about your computer hardware or software that may be automatically collected by Breakthrough2Performance where this supports us
with the operation of our service(s), to maintain the quality of our service and to provide general statistics regarding the business of our
website, in the form of:- your IP address, browser type, domain names, access times and how long you may spend on one of our pages. We may also
use third-party services such as Google Analytics that collects, monitors and analyses such information.

Marketing:
Your preferences in receiving marketing material from us and your communication preference(s).

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Breakthrough2Performance
public message boards, this information may be collected and used by others.

Breakthrough2Performance does not read any of your private online communications.

4. Use of your Data

Breakthough2Performance collects and uses your information to operate our website and deliver the services you have requested.

We may also use your data to:-

  • Register you as a new customer;
  • To fulfil our contractual obligations with you (under an agreement we are about to enter into or have entered into);
  • Respond to enquiries, questions and queries;
  • Inform you of other services or events available from Breakthrough2Performance;
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support,
    reporting and hosting of data), detecting fraud or site abuses;
  • Surveys to conduct research about your opinion of current services or new services that could be offered;
  • Billing information and collecting monies owed to us;
  • Notifying you in relation to legal obligations or providing update information on our Company or Privacy Policy;
  • Where we need to comply with a legal or regulatory obligation.

5. Data Collection, Transfer, Processing and Retention

Personal data will be collected by B2P in the following ‘data formats’ and ‘transferred’ back to you as follows:-

Data Formats

(information received)

 

Transfer Methods

(response to enquiry)

Purpose of Processing

Retention

Period

Enquiry via our website

Email

Audio / Mobile / Phone

Email

Audio / Mobile / Phone

Delivery of services as requested.

6 months from initial enquiry.

B2P has processes in place to ensure that personal data held remains accurate, up-to-date, relevant and retained in-line with our data retention strategy above.   Should an enquiry result in a formal request for services, B2P will issue a formal Customer Service and Data Processing Agreement.

6. Sharing your Information

Breakthrough2Performance does not sell, rent or lease its customer lists to third parties.

We may share your data with another Company where our business or its assets are acquired for example, in the context of a possible Company sale or re-structure.  In these instances we will, as far as practicable, share anonymised data with the other parties before the transaction is complete and in-line with the extent to which we are required do to so under the terms of any agreement, or for other reasons to comply with legal obligations placed upon us.

Other than as set out in this Policy, we shall not disclose your personal data to third parties without obtaining your prior and written consent, unless we are required by law to do so.

7. Data transfer in the EU

Our core systems, data and administration services are all carried out and stored within the UK.

We do not share data with countries outside of the European Economic Area with the exception of the following third-party service providers:-

  • MailChimp to send out and administer our e-newsletter mailing list.
  • Email services provided by Google Ireland Limited who are GDPR compliant and have data centres in the UK.

8. Security of your Personal Data

Breakthrough2Performance secures your personal information from unauthorised access, use or disclosure and has controls in place to ensure
data is not lost or accidently destroyed.

Breakthrough2Performance secures the personally identifiable information you provide on computer servers in a controlled, secure environment,
protected from unauthorised access, use or disclosure.

Only authorised personnel will have access to your data.

All information you provide is stored on secure servers based in the UK.

Our website is hosted by a third-party provider registered in London, who are GDPR compliant, with SSL encryption, regular security updates,
firewalls and have a UK based datacentre. Google collects information through the use of Google Analytics on our website. We use cookies on our
website and our website may contain links to and from other websites.

We use a third-party email provider to store emails you send to us. Our email services are provided by Google Ireland Limited, who are GDPR
compliant and have datacentres located in the UK.

We use a third-party service provider to send out our e-newsletter and administer our mailing list. Their privacy policy is available here:-
https://mailchimp.com/legal/privacy/

You acknowledge that the Internet is not a completely secure medium for communication and accordingly, we cannot guarantee the security of any
information that you send to us, or we send to you, via the Internet. We are not responsible for any damages which you, or others, may suffer as a
result of the loss of confidentiality of such information.

Electronic files will be permanently deleted from all sources. Where Breakthrough2Performance believes information may still exist elsewhere in
another form, it will notify relevant parties immediately and agree the action(s) to be undertaken. Paper-based documentation will be shredded
using a cross-blade shredder, or where large-scale disposal is necessary we will engage an industry accredited confidential waste shredding company and
obtain a destruction certificate.

Breakthrough2Performance does not record telephone calls for training purposes or otherwise.

If we discover that there has been a breach of personal data that poses a risk, we will report this to relevant parties immediately and to the
Information Commissioner within 72 hours of discovery. We will record all breaches regardless of their effect. If you require further detailed
information please contact us to request a copy of our Data Protection Policy.

9. Data Retention

One of the key principles of GDPR is that the personal data we store and process shall be adequate, relevant and limited to what is required for the purpose it was originally collected. Our standard policy is to retain information for only as long as is necessary.

Data will only be stored and retained, in-line with our data retention strategy, or for as long as we are legally obliged to retain it.

We will carry out regular reviews to remove any personal data or records that are out-of-date or no longer relevant and these will be disposed of, in-line with our disposal schedules, in a managed and secure way.

10. The right to Correction and Opting Out

You have a number of rights under GDPR, these include the right to:-

  1. See the information we hold about you;
  2. Request that any inaccuracies are corrected;
  3. Request the deletion or removal of personal data where there is no compelling reason for its continued use;
  4. Restrict or block the processing of your personal data;
  5. Object to the processing of your personal data.

Where you have provided consent to us to use your personal data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use.

There is also a right under GDPR to receive personal data in a structured, commonly used and machine-readable format and to transfer your data to another service provider or data controller. This right applies where your data is being processed on the basis of your consent or in-line with the contract to which we are party.

You may also request to be removed from our email alerts or mailing lists at any time by emailing us directly.

We would appreciate an opportunity to deal with any concerns you may have therefore if you have any questions about our Privacy Policy, wish to exercise any of your rights, or have concerns about the processing of your personal data please contact Jannine Smart, Director, jannine@nullb2phr.co.uk.

You have the to make a complaint at any time to the Information Commissioners Office (ICO), and independent supervisory body in the UK responsible for data protection matters, set up to uphold information rights, which will investigate your complaint.You can do so through their
website: https://ico.org.uk/concerns/ or by emailing: casework@nullico.org.uk or calling their helpline on: 0303 123 1113.

11. Use of Cookies

We use cookies on our website. A cookie is a text file sent to your hard disk by a webpage server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a webserver in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time by helping you to personalise your on-line experience. The purpose of a cookie is to tell the webserver that you have returned to a specific page. For example, if you register with Breakthrough2Performances site or services, a cookie helps Breakthrough2Performance to recall your specific information on subsequent visits.

You have the ability to accept or decline cookies. Some web browsers automatically accept cookies but you can usually modify your own browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website or services.

12. Third-party Links and Websites

Our website may contain links to and from other websites. These linked sites are not under the control of Breakthrough2Performance and we are not responsible for the policies and/or contents of any Linked Site, including without limitation any link contained in a Linked Site, or any changes or updates to a Linked Site.

We are also not responsible for any webcasting or any other form of transmission received from any Linked Site. Breakthrough2Performance is providing these links to you only as a convenience and the inclusion of any link does not imply endorsement by Breakthrough2Performance of the site or any association with its operators.

You should further note that third-party links and websites will have their own Privacy Policies and we encourage you to review the privacy statements of websites you choose to link to from Breakthrough2Performance so that you can understand how those websites collect, use and share your information. Breakthrough2Performance is not responsible for the privacy statements or other content on websites outside of Breakthrough2Performances website and cannot accept responsibility or liability for any loss or damage (financial, reputational or otherwise) caused as a result.

13. Changes to our Privacy Policy

This Privacy Policy is effective from May 2018.

Breakthrough2Performance will occasionally review and update this Policy and we reserve the right to update or make changes. We would encourage you
to periodically review this Policy to be informed of how we are protecting your information.

Where material changes are made to this Policy you will be informed either through the email address you have provided or by us posting a prominent
notice on our website.

14. Contacting Us

If you have any questions about this Policy, please contact us.

Contact:
Jannine Smart, Director

Tel:
01908 274189

Mobile:
07919 552769

Email:
jannine@nullb2phr.co.uk