Consulthon Ltd. ("We") are committed to protecting and respecting your privacy.
This policy (together with our Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting consulthon.com you are accepting and consenting to transfer, storing and processing of your personal data as described in this policy. If you do not agree to these terms, please refrain from using the site or the services we provide.
For the purpose of the Data Protection Act 2018 and of EU 2016/679, art.13/14, alias General Data Protection Regulation, from time to time, including any replacement law or regulation (the Act), the data controller is Consulthon Ltd. of a limited company registered in England and Wales under company number 10682705 and with our registered office at Kemp House, 152 City Road, London EC1V 2NX.
1. Information we may collect from you
We may collect and process the following data about you:
1.1. Information you give us. You may give us information about you by auto filling in the log-in Linkedin form on our Platform www.consulthon.com (our Platform) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Platform, subscribe to our service, post a challenge, give an answer in a challenge, read challenges and answers, connect in the inbox message with another Member and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information (STRIPE) and personal description.
1.2. Information we collect about you. With regard to each of your visits to our platform we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); challenges you viewed or searched for; 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 and any phone number/email used to contact our customer service number.
3. Uses made of the information
We use information held about you in the following ways:
3.1. Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- to communicate with you about any challenge you create/participate in or any services we provide to you;
- to undertake any security checks that may be required in relations to any services you request from us;
- to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous challenge participation of you. If you are a new member, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please contact us;
- to notify you about changes to our service;
- to resolve complaints and dealing with disputes;
- for preventing and detecting fraudulent or criminal activity; and
- to ensure that content from our platform is presented in the most effective manner for you and for your computer.
3.2. Information we collect about you. We will use this information:
- to administer our platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our platform to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our platform safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other members of our platform about goods or services that may interest you or them.
4. Disclosure of your information
We will not transfer, disclose, sell or distribute your personal data to third parties other than as set out in this policy or to our group entities, unless we have your permission or are otherwise required or permitted to do so by law.
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
4.1. We may share your information with selected third parties including:
Business partners, suppliers, service providers, and sub-contractors for the performance of any contract we enter into with them or you.
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
Analytics and search engine providers that assist us in the improvement and optimisation of our platform.
4.2. We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Consulthon Ltd. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its members will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of Consulthon Ltd., our members, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. Where we store your personal data
5.1. We store your data for 3 years.
5.2. The data that we collect from you may be transferred to, and stored at, a destination within or outside the European Economic Area ("EEA").
5.3. All information you provide to us is stored securely. Any payment transactions will be facilitated through third parties. Currently, we only use Stripe Payments Europe, Ltd. Where you have chosen a password (LinkedIn) which enables you to access our platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
5.4. 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 data transmitted to our platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
6. Applicability of broader protection standards
While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.
Such broader protection standards apply when the processing:
- is performed by an Owner based within the EU;
- concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
- concerns the Personal Data of Users who are in the EU and allows Consulthon to monitor such Users’ behavior taking place in the EU.
7. Your rights
You, as user of our services, may exercise certain rights regarding their Data processed by Consulthon.
Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with Consulthon to find out which rights apply to them.
In particular, Users have the right to do the following:
You can always contact us at firstname.lastname@example.org if you want to stop analysing your data.
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by Consulthon, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, Consulthon will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from Consulthon.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Consulthon or for the purposes of the legitimate interests pursued by Consulthon, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether Consulthon is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights:
Any requests to exercise User rights can be directed to Consulthon through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Consulthon as early as possible and always within one month.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation) and Data Protection Act.