Privacy Policy

Data Protection and Privacy for In Professional Development

Background:

In Professional Development Ltd (“InPD”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, inpd.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Site is owned and operated by In Professional Development Ltd, a private limited company registered in England under company number 10777587.

Registered address: Suite 6A, Blackthorn House, Appley Bridge, Greater Manchester, WN6 9DB.

VAT number: 285136002.

Data Protection Officer: Marc Davis.

Email address: info@inpd.co.uk.

Telephone number: 0161 509 2999.

Postal address: Suite 6A, Blackthorn House, Appley Bridge, Greater Manchester, WN6 9DB.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact Us using the details provided in Part 15.

It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep Us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact Us first, using the details in Part 15.

6. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies and Our Cookie Policy

We do not collect the following special categories of personal data i.e. – race, ethnic origin, politics, religion, trade union membership. In the interests of providing you with specific help where you need it, we ask you if you have any special requirements relating to access on the premises or learning or dietary requirements. We hold this information securely and only for the purpose of carrying out any requests for the specific training you may have booked.

Data Collected	How We Collect the Data
Identity Information including name, title, to sign up for membership, register for a course or event or join our mailing list.	Collected from a Client’s direct input on our platform.
Contact information including address, email address, and telephone number to sign up for membership, register for a course or event or join our mailing list for customers to speak with an advisor.	Collected from a Client’s direct input on our platform.
Business information including business name, position, profession, sector/ industry to sign up for membership, register for a course or event or join our mailing list.	Collected from a Client’s direct input via an electronic form.
Payment information including card details, bank account name and numbers to issue invoices and store account records based outside the EU.	Collected from a Client’s direct input on our platform, by a third-party company. This data is not stored on any of our servers.
Technical information including IP address, browser type and version, and operating system for system administration and to help maintain security and performance of our site and statistical data about your browsing actions and patterns for marketing purposes.	Collected via a third party.
Data from third parties including data collected, technical information, contact information, and profile information.	Please see further information on data collection from third parties in our Cookies Policy located at [https://www.inpd.co.uk/terms-and-conditions].

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and Our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Providing and managing your access to Our Site.	Name, Company Name, email address.	Contract
Personalising and tailoring your experience on Our Site including understanding clients’ patterns, their needs, and services that they are interested in, we analyse browsing histories, customer demographics and market research information using google analytics.	clients account data, e-mail address, browsing data, IP address, and geographical address	Legitimate Interests
Administering Our Site including monitoring how Our website are used so that we are able to provide a personalised browsing experience, to help us improve the website.	Device information, IP address, analysis of website navigation via cookies event trackers, beacons and other technologies.	Legitimate Interests
Administering Our business including calls to our customer service team, to ensure a high level of customer service to our clients, to enable staff training and to manage complaints.	Reports of calls to our Customer service teams, client name, and account ID/ email.	Legitimate Interests
Supplying Our services to you including communicating with you about your account and managing payments for Our services.	Contact details (company name, name, address, postcode, phone number), financial details (credit and debit card details etc), delivery address.	Contract
When we have a service message we need to send you via email regarding your account, or informing you of any changes that might affect your account, our service to you or changes to terms and conditions.	Name and email address.	Legitimate Interest
When you make a request on our website, we will use some of your personal data to carry out verification and anti-fraud activities: we have a legitimate interest in carrying out this activity to prevent and prosecute any fraudulent activity.	Name, billing and shipping address, email address, phone number, and payment information.	Legitimate Interest
We may use your data to establish or exercise our legal rights or to defend against any legal claims.	Identification data and other personal data that may be relevant to the specific legal claim.	Legitimate Interest
When we process your information in response to you exercising your data subject rights.	Name, contact information, other information you have specifically requested.	Legal Obligation

7.1 What We Collect and Why?

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Identity Information including name, title, and date of birth.	Indefinitely
Contact information including address, email address, and telephone number.	Indefinitely
Business information including business name, position, profession, sector/ industry.	Indefinitely
Payment information including card details, bank account name and numbers.	Our third party provider Stripe retain transaction details for a prescribed period of time. Please refer to their privacy notice for details.
Technical information including IP address, browser type and version, and operating system.	Indefinitely
Data from third parties including data collected, technical information, contact information, and profile information.	Indefinitely

9. How and Where Do You Store or Transfer My Personal Data?

We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.

We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.

Where we use certain service providers we will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.

Please contact us using the details below in Part 15 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.

The security of your personal data is essential to Us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

The lawful transfer mechanism of your personal data to countries that do not belong to the European Union and that have not been assessed as offering adequate levels of protection will be performed only:

after Standard Contractual Clauses have been put in place alongside any supplementary measures that are deemed necessary on a case-by-case basis;
for registration on the website or use of services on the website;
for the management of your requests.

10. Do You Share My Personal Data?

Your personal data will be processed by the internal staff of INPD who have been specifically trained and authorised for this processing. In carrying out the processing for distribution of our products and managing our supply chain your personal data will also be transmitted to third parties that we use to provide our services; these parties have been rigorously assessed for the way in which they manage personal data and may only use your data for the exact purposes that we specify in the contract with them.

The third parties in question belong to the following categories:

Companies such as payment service providers that help us to process your subscription payments.
Professional service providers, such as email delivery suppliers, IT software providers, marketing and research agencies, analytics companies and website hosts who help us to run our business,
Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.
Governmental bodies and regulators to comply with our legal obligations.

Aggregated data that does not identify individuals is shared with internal teams, relevant service providers and brand partners for business planning purposes.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

If we sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

- In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14 and our Cookie policy located at https://www.inpd.co.uk/terms-and-conditions.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for analytics. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop-up prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer or device:

Name of Cookie	Purpose	Strictly Necessary	Expiration
__hs_opt_out	This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when you give visitors the choice to opt out of cookies. It contains the string "yes" or "no".	Yes -strictly necessary	6 months
__hs_do_not_track	This cookie can be set to prevent the tracking code from sending any information to HubSpot. It contains the string "yes".	Yes -strictly necessary	6 months
__hs_initial_opt_in	This cookie is used to prevent the banner from always displaying when visitors are browsing in strict mode. It contains the string "yes" or "no".	Yes -strictly necessary	7 days
__hs_cookie_cat_pref	This cookie is used to record the categories a visitor consented to. It contains data on the consented categories.	Yes - strictly necessary	6 months
hs_ab_test	This cookie is used to consistently serve visitors the same version of an A/B test page they’ve seen before. It contains the id of the A/B test page and the id of the variation that was chosen for the visitor.	Yes - strictly necessary	End of the session
<id>_key	When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login again. The cookie name is unique for each password-protected page. It contains an encrypted version of the password so future visits to the page will not require the password again.	Yes - strictly necessary	14 days
hs-messages-is-open	This cookie is used to determine and save whether the chat widget is open for future visits. It is set in your visitor's browser when they start a new chat, and resets to re-close the widget after 30 minutes of inactivity. If your visitor manually closes the chat widget, it will prevent the widget from re-opening on subsequent page loads in that browser session for 30 minutes. It contains a boolean value of True if present.	Yes - strictly necessary	30 minutes
hs-messages-hide-welcome-message	This cookie is used to prevent the chat widget welcome message from appearing again for one day after it is dismissed. It contains a boolean value of True or False.	Yes - strictly necessary	1 day
__hsmem	This cookie is set when visitors log in to a HubSpot-hosted site. It contains encrypted data that identifies the membership user when they are currently logged in.	Yes - strictly necessary	7 days
hs-membership-csrf	This cookie is used to ensure that content membership logins cannot be forged. It contains a random string of letters and numbers used to verify that a membership login is authentic.	Yes - strictly necessary	End of the session
hs_langswitcher_choice	This cookie is used to save a visitor’s selected language choice when viewing pages in multiple languages. It is set when a visitor selects a language from the language switcher and is used as a language preference to redirect them to sites in their chosen language in the future if they are available. It contains a colon delimited string with the ISO639 language code choice on the left and the top level private domain it applies to on the right. An example will be "EN-US:hubspot.com".	Yes - strictly necessary	2 years
__cfruid	This cookie is set by HubSpot’s CDN provider because of their rate limiting policies. It expires at the end of the session. Learn more about Cloudflare cookies.	Yes - strictly necessary	End of the session
__cf_bm	This cookie is set by HubSpot's CDN provider and is a necessary cookie for bot protection. It expires in 30 minutes.	Yes - strictly necessary	30 minutes

Our Site uses analytics services provided by HubSpot. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and/or services offered through it.

The analytics services used by Our Site uses Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

The analytics services used by Our Site uses the following Cookies:

Name of Cookie

Purpose

Duration

__hstc

The main cookie for tracking visitors.

It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).

6 months

hubspotutk

This cookie keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts.

It contains an opaque GUID to represent the current visitor.

6 months

__hssc

This cookie keeps track of sessions.

This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie.

It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.

30 minutes

__hssrc

Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser.

If this cookie does not exist when HubSpot manages cookies, it is considered a new session.

It contains the value "1" when present.

End of the session

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: enquiries@inpd.co.uk

Telephone number 0161 509 2999.

Postal Address: Suite 6A, Blackthorn House, Appley Bridge, Greater Manchester, WN6 9DB.

16. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated in November 2022.

Privacy Policy

Data Protection and Privacy for In Professional Development

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