Privacy Policy

THRIVE IN MIND LTD takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website, email mailing list (if you subscribe to this) and the ‘Psychological Resilience when Overwhelmed’ programme;

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data	collectively all information that you submit to THRIVE IN MIND LTD via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Data Protection Laws	any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPR	the UK General Data Protection Regulation;
THRIVE IN MIND LTD, we or us	THRIVE IN MIND LTD, a company incorporated in England and Wales with registered number 13187536 whose registered office is at Apt 2 Waverley, 18 Edgerton Rd, HD3 3AD;
User or you	any third party that accesses the Website and is not either (i) employed by THRIVE IN MIND LTD and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to THRIVE IN MIND LTD and accessing the Website in connection with the provision of such services; and
Website	the website that you are currently using, www.thriveinmind.org, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
‘Psychological Resilience when Overwhelmed’ programme	Is a digital programme owned by Thrive in Mind Ltd.  It is an interactive training programme.
Programme Allocation Page	Refers to the dashboard available to purchasers of ‘Psychological Resilience when Overwhelmed’ which allows them to distribute the programme.
‘Active’ and ‘Inactive’ status	Refers to whether a user of the ‘Psychological Resilience when Overwhelmed’ programme has, or has not, started to use the programme

2. In this privacy policy, unless the context requires a different interpretation:
   • the singular includes the plural and vice versa;
   • references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

Keeping Data secure

3. We will use technical and organisational measures to safeguard your Data, for example:
   • access to your account is controlled by a password and user name that is unique to that user.
   • we store your Data on secure servers.
4. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: contactus@thriveinmind.org
5. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Your rights

6. You have the following rights in relation to your Data:
   • Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally
     permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
   • Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
   • Right to erase – the right to request that we delete or remove your Data from our systems.
   • Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
   • Right to data portability – the right to request that we move, copy or transfer your Data.
   • Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
7. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: contactus@thriveinmind.org
8. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found below;

The ICO’s address:           

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

9. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

10. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

11. THRIVE IN MIND LTD may, from time to time, expand or reduce our business and this may involve the sale and /or the transfer of control of all or part of THRIVE IN MIND LTD. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
12. We may also disclose Data to a prospective purchaser of our business or any part of it.
13. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Data retention

14. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
15. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
16. As part of the registration process for the ‘Psychological Resilience when Overwhelmed’ programme, Programme allocation page (which is part of the digital programme) and various mailing lists, Thrive in Mind Ltd will collect your first and last name, email address and employer’s/company’s name.  
17. If you are subscribing to our mailing list, Thrive in Mind Ltd will also ask if you are an employer and if you are an existing customer. This is to help us send the right information to the right person.
18. If you submit a ‘Contact Us’ form with us, Thrive in Mind Ltd will collect your first and last name, email address and contact telephone number.
19. The ‘Psychological Resilience when Overwhelmed’ programme collects anonymised data extracted from Session 1 module 4 and Session 4 module 8. This can only be seen by Thrive In Mind Ltd and cannot be linked to specific users.

How your data is used

20. Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails or using the ‘Psychological Resilience when Overwhelmed’ programme), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
21. Providing and managing your access to the ‘Programme Allocation’ Page and ‘Psychological Resilience when Overwhelmed’ programme;
22. Supplying our products and services to you (please note that we require your personal data in order to enter into a contract with you);
23. Replying to emails from you;
24. Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by replying to the Unsubscribe link on each email).
25. Quality assurance, such as, assessing the effectiveness of the ‘Psychological Resilience when Overwhelmed’ programme. 
26. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases): As required by law, and for no more than three years after the end of our business together, whichever is longest.

Data which is visible

27. If users of the ‘Psychological Resilience when Overwhelmed’ programme tick the permission box, their written answer to Session 4 module 8 question 11 may be displayed on the Thrive in Mind Ltd website (www.thriveinmind.org).
28. Users with access to the ‘Programme Allocation’ page will be able to view the ‘active’ or ‘Inactive’ status of any of the users they have assigned to the ‘Psychological Resilience when Overwhelmed’ programme. They will not be able to see any other data about that individual.

Data which is not collected

29. With the exception of the anonymised questions collected from Session 1 module 4 and Session 4 module 8, no other answers from the ‘Psychological Resilience when Overwhelmed’ programme are stored or made visible to others by Thrive in Mind Ltd.

General

30. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
31. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
32. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
33. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

34. THRIVE IN MIND LTD reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact THRIVE IN MIND LTD by email at contactus@thriveinmind.org