Privacy Policy & Terms of Use
Privacy Policy
“Companions For Leadership” is a trading name of Companions For Leadership Limited (“CFL”). CFL is committed to data security and the fair and transparent processing of personal data. This privacy notice sets out how we will treat the personal data which you provide to us in compliance with applicable data protection law, in particular the General Data Protection Regulation (EU) 2016/679 (GDPR).
Please read this notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data, how to contact us and supervisory authorities if you would like to report a concern about the way in which we process your data.
Who are we?
Companions For Leadership Limited (formerly named Oxford Leadership Limited) is a registered company (registered company number 10107693) (“OLL). Our registered address is 2nd Floor Eden House 2 St. Aldates Courtyard, 38 St. Aldates, Oxford OX1 1BN, United Kingdom.
CFL is a trading partner of Oxford Leadership Academy Limited (“OLA”). OLA is independently owned and run independent of CFL. CFL is a reseller of certain programs owned by OLA, including but not limited to the digital offering SML Online and OLA controls registration and access to the SML Online platform. For the purposes of GDPR of SML Online, OLA is the ‘controller’ of the personal data you provide to the platform or OLA as a client or potential client of OLA, including through the OLA website (www.oxfordleadership.com), an OLA event, or other OLA online or paper based form. Please see the OLA website for the OLA Privacy Policy.
CFL owns and operates www.cflglobal.com. For the purposes of GDPR, CFL is the ‘controller’ of the personal data you provide to us as a client or potential client of CFL, including through our website, an event, or other online or paper-based form.
What personal data does CFL collect?
We may collect and process the following personal data:
Information you provide to us
If you:
- complete a form on our website;
- complete a survey;
- correspond with us by phone, e-mail, or in writing;
- report a problem;
- sign-up to receive our newsletter;
- enter into a contract with us to receive products and/or services,
we may collect your name, e-mail address, postal address, and job role.
You may also choose to provide us with your telephone number if you would like to be contacted by telephone.
Information CFL collects about you
If you visit our website, we may automatically collect the following information:
- technical information, including the internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit to our website such as the products and/or services you searched for and view, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Information we receive from other sources
We may also receive information about you if you use any of the other websites or social media platforms we operate or the other services we provide.
If you are a participant in one of our programmes, we may also receive information about you from your employer when they contract to receive products and/or services from us.
Information about other people
If you provide information to us about any person other than yourself, such as your relatives, next of kin, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.
How do we use your personal data?
When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.
Contract performance:
We may use your personal data to fulfil a contract, or take steps linked to a contract:
- to provide the products and/or services to you;
- to communicate with you in relation to the provision of the contracted products and services;
- to provide you with administrative support such as account creation, security, and responding to issues; and
- provide you with industry information, surveys, information about our awards and events, offers and promotions, related to the products and/or services.
Legitimate interests:
Where this is necessary for purposes which are in our, or third parties, legitimate interests.
These interests are:
- providing you with newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered by CFL which may be of interest to you;
- communicating with you in relation to any issues, complaints, or disputes;
- improving the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our website;
- performing analytics on sales/marketing data, determining the effectiveness of promotional campaigns.
You have the right to object to the processing of your personal data on the basis of legitimate interests as set out below, under the heading Your rights.
Consent:
where you have given your express consent to receive marketing communications, we may use your personal data to:
- send you newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered by CFL which may be of interest to you;
- developing, improving, and delivering marketing and advertising for products and services offered by CFL.
We only process your sensitive personal data when we have obtained your explicit consent to do so.
Where required by law: we may also process your personal data if required by law, including responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.
Who do we share your personal data with?
We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it.
We may also share your personal data with trusted third parties including:
- legal and other professional advisers, consultants, and professional experts;
- service providers contracted to us in connection with provision of the products and services such as our associate consultants, providers of IT services and customer relationship management services; and
- analytics and search engine providers that assist us in the improvement and optimisation of our website.
We will ensure there is a contract in place with the categories of recipients listed above which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.
Where a third party recipient is located outside the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws.
We will share personal data with law enforcement or other authorities if required by applicable law.
How long will we keep your personal data?
Where there is a contract between us, we will retain your personal data for the duration of the contract, and for a period of 6 years following its termination or expiry, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities. Where you have consented to marketing communications, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us.
Where do we store your personal data and how is it protected?
We take reasonable steps to protect your personal data from loss or destruction.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Where you have a username or password (or other identification information) which enables you to access certain services or parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights
Under the GDPR, you have various rights with respect to our use of your personal data:
Right to Access
You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond with 30 days of request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information. Or if your request is manifestly unfounded or excessive.
Right to rectification
We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
Right to erasure
You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.
Right to object
In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.
Right to restrict processing
In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have queried the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful, and you elect that processing is restricted rather than deleted. Please contact us using the contact details provided below.
Right to data portability
In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request that your personal data is ported to you, please contact us using the contact details provided below.
Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception, we will explain this to you in our response.
Terms of Use
The following terms and conditions are for the use of www.cflglobal.com website (the Site) which is owned by Companions For Leadership Limited (CFL). You may access the Site in several ways, including but not limited to the World Wide Web, PDA and mobile phone. These terms and conditions apply whenever you access the Site, on whatever device.
By using the Site you are deemed to have accepted these conditions.
Permitted Use
Subject to what is said below, material from the Site may be downloaded, viewed, listened-to, printed, copied on the hard disk of your computer (but not photocopied) and used for: your own personal, non-commercial purposes; internal business purposes; or the non-commercial purpose of using the Site as a personal information resource in good faith ONLY. Single copies of pages from the Site may be printed out for the sole purposes of enabling the person printing the page to retain a copy for their own personal records. Any other type of use (and, in particular, any copying or distribution of material from the Site for any commercial or business purpose) requires the prior written agreement of CFL.
Intellectual Property and Copyright
The names, images and logos identifying CFL or third parties and their products and services, are the proprietary marks of CFL, and/or may be the proprietary marks of third parties. Any use made of these marks may be an infringement of rights in those marks and CFL reserves all rights to enforce such rights that it might have. All content on this Site, except where otherwise accredited, is the exclusive property of CFL and is protected by UK and international copyright laws.
Liabilities
CFL cannot guarantee that your use of the Site will be free from error and/or uninterrupted. CFL shall not be liable for any indirect, incidental, consequential, or punitive damages or for lost revenues or profits, whether or not advised of the possibility of such damages or losses and regardless of the theory of liability arising out of, or in connection with, any information on the Site or the use thereof.
Links
Some of the pages on the Site include links to external websites. These links are included to give you the opportunity to access other pages that it is felt may be of interest to you. CFL is not responsible for the content of these Internet sites.
Viruses
Whilst effort has been taken to ensure that the pages of the Site are free from viruses, CFL gives no warranties that they are indeed free from viruses and users are responsible for ensuring that they have installed adequate virus checking software.
Variations
These terms may be varied from time to time. Please ensure that you review these terms and conditions regularly as you will be deemed to have accepted a variation if you continue to use the Site after any variation has been posted.