Privacy policy.

EmPower Growth Ltd (EmPower, we, us, our) is committed to respecting and protecting the security and protection of the personal information that we process and to provide a compliant and consistent approach to data protection to ensure compliance with the General Data Protection Regulations, 2018.

This privacy notice tells you what to expect us to do with your personal information.

OUR CONTACT DETAILS

Post: Inchnacardoch Lodge Hotel, Fort Augustus, Inverness-shire, PH32 4BL, Scotland

Email: connection@em-po.com


WHAT INFORMATION WE COLLECT, USE, AND WHY

We collect or use the following information to provide services and goods including:

  • Names and contact details

  • Addresses

  • Date of birth

  • Payment details (including card or bank information for booking processing)

  • Health information (including dietary requirements, allergies and health conditions)

  • Website user information (including user journeys and cookie tracking)

  • Records of meetings and decisions

  • Schwartz Survey inputs

  • Programme questionnaires

  • Personal app information and inputs

We collect or use the following information for service updates or marketing purposes:

  • Names and contact details

  • Marketing preferences

  • Website and app user journey information

  • Records of consent, where appropriate

 

LAWFUL BASES

Our lawful bases for collecting or using personal information to provide services and goods are:

·   Consent

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

·   ·Legitimate Interest

In compliance with data protection regulations, the data collected is primarily utilised for the purpose of qualifying and enrolling individuals into their selected programmes. Additionally, it is utilised to maintain communication, provide ongoing support, and ensure a seamless experience throughout the duration of their programme participation. Further details regarding the purpose of processing are outlined below:


WHERE WE GET PERSONAL INFORMATION FROM

EmPower collects personal data through various channels, primarily through the application process, programme administration, and associated activities, including relevant notifications. Individuals directly provide this information through multiple means, including phone, email, verbal and input of information into our website forms, questionnaires, trackers and surveys. By utilising these channels, EmPower ensures that individuals have multiple options to provide their personal data in a manner that is convenient and accessible to them. We are committed to handling this data responsibly and in accordance with applicable data protection laws and regulations. If you have any questions or concerns about the collection and use of your personal data, please do not hesitate to contact us.


HOW PERSONAL DATA IS STORED

Personal data collected by EmPower is stored electronically in a secure manner. We utilise cloud-based, fully encrypted software to ensure the confidentiality, integrity, and availability of personal data. Access to personal data is restricted to authorised personnel who have a legitimate need to access such information for the purposes outlined in our privacy policy. We regularly review and update our security practices ensuring that our data storage systems remain robust and resilient against potential security risks. If you have any questions or concerns about the security of your personal data, please feel free to contact us.


PURPOSE OF PROCESSING

EmPower processes personal data to deliver our programme to people/organsiation employees.

We will not use any form of automated decision making to process programme applications.

EmPower will, on some occasions, process data for internal reporting and research purposes such as reviewing the number of clients who have successfully completed a programme, collation of Schwatrz survey scores and tracker data analysis. These reports will not be shared with third parties but anonymised reports may be discussed and shared, including our marketing purposes exclusively (not including any specific personal data).

We will also use the testimonials and case studies for marketing purposes only with written consent by the individual/organsiation concerned.

EmPower occasionally processes data for internal reporting and research purposes, which includes reviewing programme completion rates, aggregating feedback from Schwartz surveys, and analysing data from personal trackers to evaluate programme outcomes. These reports are strictly for internal use and will not be shared with third parties. However, anonymised reports may be discussed and shared exclusively for marketing purposes, without including any specific personal data. Additionally, testimonials and case studies may be used for marketing purposes only with the written consent of the individuals or organisations concerned. EmPower also processes data to communicate with programme participants and individuals who have opted to receive marketing communications, informing them of relevant updates and events related to our business and purpose. We are committed to handling personal data responsibly and in compliance with applicable data protection laws and regulations. If you have any questions or concerns about the processing of your data, please contact us.


HOW LONG WE KEEP INFORMATION

EmPower will retain your personal data only as long as is necessary to fulfill the above objectives.


WHO WE SHARE INFORMATION WITH

EmPower will not share your data with any third parties other than those with whom we have signed a formal data-sharing agreement. These parties include extended personnel who are part of the EmPower team or those who host or manage the software/platforms used to securely store your electronic data – our third-party data processors.

 

Third-party processors: We utilise various third-party supplier plug-ins and applications including but not limited to PayPal for payment processing, Zoom for online seminar hosting, Squarespace for website management, and WhatsApp for communication purposes. By accepting our terms, you agree to abide by the terms and conditions of these third-party suppliers as applicable to your interactions with them. We are not responsible for their privacy statements nor liable for any issues or disputes arising from your use of these third-party services.


SECURITY OF YOUR PERSONAL INFORMATION

EmPower stores your electronic data on secured platforms. Encrypted database backups are held off-site in a secure location and are subject to a regular cleardown schedule. All the software used to process and store your data is password protected and accessible only by authorised personnel.

SHARING INFORMATION OUTSIDE THE UK

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR by ensuring appropriate safeguards are in place. Please contact us for more information.

YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights including:

  • Your right of access - You have the right to ask us for copies of your personal data.

  • Your right to rectification - You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

  • Your right to erasure - You have the right to ask us to erase your personal data in certain circumstances.

  • Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal data in certain circumstances.

  • Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.

  • Your right to data portability - You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.

  • Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.

You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.

To make a data protection rights request or contact us about any issues relating to you data please email us at connection@em-po.com

HOW TO COMPLAIN

If you have any concerns about our use of your personal data, you can make a complaint to us by contacting connection@em-po.com or use the contact details at the top of this privacy notice. This will be reviewed by our leadership team and we will respond within 48

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the Information Commissioners Office complaints helpline on 0303 123 1113.

 

LAST UPDATED: 21 May 2024