Data Processing Agreement and Privacy Policy

EI World Limited are committed to ensuring the confidentiality and privacy of our customers’ and potential customers’ personal information, in accordance with the EU’s General Data Protection Regulation (GDPR) (EU) 2016/679.

This agreement sets out how EI World handles personal information supplied to us, collected and held from individuals and businesses both online (using our websites www.eiworld.org and www.eiworldsurveys.net, or other data collection tools) or offline.

We have endeavoured to meet the requirements of GDPR compliance to the best of our knowledge to protect the security of your Personal Information. We undertake that any personal data collected and stored within our online (or offline) systems is processed in line with this regulation for the protection of individuals. We will only use and disclose your personal information for the primary purposes of our business as described in this privacy policy. If we want to use your personal information for any other purpose we will seek your express consent to do so.

Definitions

  • Customer and potential customer means an individual, business or other entity that either purchases or considers purchasing EI World’s Products or Services.
  • Personal Information means any information, or an opinion about an identified individual, or an individual who is reasonably identifiable, whether that information is true or not and whether recorded in material form or not. This includes: name, email address, mailing address, telephone number, billing information, account information, and other information incidental to providing or receiving Products or Services.
  • Products or Services means the Products or Services promoted, sold or available for sale from the EI World Website or through emails or through direct contact with any member of the EI World team, including, without limitation: (a) books, manuals or other materials; (b) online Assessment services and Assessment Reports; (c) Leadership and Development Coaching and Development Programs; (d) Survey Design and/or Implementation; (e) Accreditation Programs; (f) Webinars; (g) Any other contractual relationship to provide other Products or Services not previously mentioned.

Consent

By using the Website and/or completing the ‘How can we help you?’ form on our website and/or entering into discussions about a contract with us and/or submitting Personal Information to us, you consent to the practices described in this Privacy Policy, and agree that we may collect, use, disclose, store, transmit, or process such Personal Information in accordance with this Privacy Policy or as required by law.

By providing your Personal Information to us, you acknowledge and agree that:

  • You are consenting to its collection and use in accordance with our privacy policy. 
  • You are responsible for providing accurate and complete information.
  • Any information provided about anyone else, such as an address for delivery of resources other than your own, is provided with their permission.
  • Your use and access of the website, when provided with courses, coaching or learning and development programs that have online resource within the Ei World website, will be in a manner that will not disrupt, corrupt, or otherwise damage the website. Accordingly, this website shall not be used in a manner that is prohibited by law. Use of this website is subject to your compliance with all applicable laws and regulations in your location.

How We Collect Your Information

If you complete the ‘How can we help you?’ form on our website, we will collect your name, email and contact number as well as your company name and project requirements that helps us serve you better.

If you register or create an account on the Ei World website, we require that you fill out a form. We collect your name, contact information and may ask you for other optional information that helps us serve you better.

If you purchase a Product or Service (either on our website or via direct contact to a member of our team), we collect your contact information as necessary to fulfil the order (such as name, address, shipping information, email address or telephone number) and optional information if you provide it. If you purchase a Product or Service for delivery to, or use by, another person, we collect your Personal Information as the person initiating the purchase, as well as Personal Information about that other person (such as name, shipping address, telephone number or email address) as necessary to fulfil the order.

By providing another person’s Personal Information, you represent that you have that person’s permission to do so.

If you pay for a Product or Service online, we do not collect or store your payment information ourselves. We use a third party plugin to manage our store and all payments are processed by PayPal. You can review PayPal’s privacy statement here if you would like to find out more about how they keep your payment information secure. When you pay for a product or service we will receive a notice of the receipt of the payment, a confirmation number (for verification purposes), the name and contact information of the recipient of the Product or Service, and the name and contact information of the cardholder if different from the name of the person receiving the Product or Service

If you complete an Assessment or Survey of our, or our third party providers’ online platforms either (1) at our request as part of an Organisational Leadership and Development Program or Coaching Engagement, which has been initiated by your employer or (2) at the request one of our customer’s or (3) on your own initiative, whether online or offline, we collect the name and email address that you provide to us, your responses, and in some cases, your gender. Most of the surveys we use also have the option to provide further demographic information (such as highest level of education attained or occupation amongst others).   

If you sign up to receive an EI World newsletter and/or other marketing collateral we may collect information on the open rate of the newsletter, and whether a specific individual has clicked on a link contained in any edition of our newsletter.

When you connect with us on social media we collect your name and may collect your email address, website and any other personal information you supply.

If you are a Customer or other business contact, or if you are an employee or agent of a Customer or business contact, we may collect your email address, telephone number, contact information and correspondence in the regular course of our interaction with you.

If you are an Associate of Ei World or a Supplier to Ei World, or if you are an employee or agent of an Associate or Supplier to Ei World, we may collect your email address, telephone number, contact information and correspondence in the regular course of our interaction with you.

If you participate in our blogs or forums, or if you write to us, we may collect the Personal Information that you provide in your correspondence and communications with us, or through your participation in blogs and forums.

We may receive Personal Information about you from third parties, such as from Customers or Associates of EI World, EI World distributors, websites where we advertise, business partners and service providers. Some of this information pertains to a specific individual or business; other information can only be linked to an access point or a device.

If you become certified or qualified in our Products or Services, we collect information about you and regarding the details of your certification or qualification, such as your name, email address, address for correspondence, telephone number, the instruments in which you are certified/qualified, the date of your certification/qualification with us, and the current status of your certification/qualification.

Cookies and Other Tracking Technologies

When someone visits our websites www.eiworld.org and www.eiworldsurveys.net,  we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the sites. This information is processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our websites.

Cookies are small text files that are placed on your machine to help our websites (www.eiworld.org and www.eiworldsurveys.net) provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymised tracking data to third party applications such as Google Analytics (see paragraph above).

As a rule, cookies will make your browsing experience better, however you may prefer to disable cookies on our website and on others. The most effective way to do this is to disable cookies on your browser.

We suggest consulting the help section on your browser or taking a look at The About Cookies Website which offers guidance for all modern browsers.

How We Use Personal Information

To provide our Products or Services – the Personal Information collected from purchase order forms is used to send orders or provide services to our Customers. The limited payment information that we receive from our payment processors is used to verify that a Product or Service has been paid for. If you purchase a Product or Service in relation to which we act as an agent for a third party, we will send the information you provide to us to that third party. The third parties for whom we act as agent are not subject to this Privacy Policy. We recommend that you read the privacy policies and statements that are posted on the relevant third parties’ websites to understand their procedures for collecting, using, storing and disclosing Personal Information.

In connection with Assessments and Surveys – we use the responses to an Assessment to score the Assessment and prepare the related Report about the Assessment Taker. We retain a copy of your responses and the related Report in accordance with our data retention policy. detailed below. 

To research and/or facilitate the use of our website – we may use aggregated session data such as cookies (see the section above regarding collecting data) to better understand how our Site is navigated, how many visitors arrive at specific pages, which pages or content attract more viewers, the length and frequency of stays at our Site, the different types of searches of our Site content and databases, the types of browsers and computer operating systems that our visitors use, and the IP addresses from which visitors connect to our Site, in order to improve our Site and enhance our content. We may use IP addresses to gather broad demographic information – this information is not associated with any individual and is therefore anonymous. The IP addresses are then disposed of in accordance with our record retention policy. We may also use IP addresses and session data to diagnose problems with our server and to administer our Site.

For marketing purposes – for business customers we may use your email address or other contact information to send occasional mailings, newsletters and other marketing collateral regarding product information and releases which we feel may be of interest to you as someone working within the organisational and leadership development field.

For survey analysis – the information that we collect through our surveys (including surveys administered by our customers, related companies and other publishers) is not used other than to garner survey results and statistical analysis, including using aggregated, anonymised data to gain an understanding at an organisational level about employees in a particular sector, division or industry. This will not contain identifiable individuals.

To Whom We Disclose Personal Information

From time to time, we may disclose Personal Information to someone other than the individual who provided this information, as follows:

Our Customers – if you are taking an Assessment at either our direction or the direction of one of our Customers, the protocol surrounding report delivery is dependent on the situation that applies:

  • Selection Process Assessments – the Assessment report will be shared with the commissioning company, together with best practices as to how to share the information with the person who has taken the Assessment.
  • Development Assessments – the Assessment report will be shared with the coach who is providing coaching to the person taking the Assessment for development purposes.
  • Ei World customer commissioned Assessments – that Customer will receive from EI World a Report on the Assessment that you took, so that he or she may properly counsel or advise you or provide you with other services.
  • Aggregated industry/company data – the Assessment report is used with other Assessment reports as aggregated, anonymised data to gain an understanding at an organisational level about employees in a particular sector, division or industry. This will not contain identifiable individuals.

Service providers – we may engage certain third parties to perform functions and provide services to us, including, without limitation, customer relationship management, contract management, shipment, scheduling, order fulfilment, payment credit card processing, mass mailing, hosting and maintenance, database storage and management, business analytics, fraud prevention, direct marketing campaigns and survey administration.

Authorised Associates of EI World – Personal Data is shared with EI World Associates as strictly necessary for the performance, management and delivery of contracts we have in place.

The public – if you are or become certified or qualified in the tools that we provide, we may share information regarding your certification such as your name, the instruments in which you are certified/qualified, the date of your certification/qualification, its scope, and the current status of your certification/qualification, with the public, if you hereby authorise us to do so.

Public forums – EI World may offer publicly accessible blogs or community forums. Any Personal Information that you provide on these blogs or forums may be read, collected and used by others who access them.

To defend or enforce our rights – EI World may use Personal Information to protect itself, to respond to a breach of its terms and conditions, to prevent fraudulent activity, or where it is necessary to pursue available remedies. If a Customer neglects to pay amounts due and owing to EI World, EI World may send that customer’s name, contact information, and account information to a third-party service provider for collection of overdue payments.

Merger, acquisition or bankruptcy – if any or all the EI World assets are acquired by, or merged with those of another entity, or in the unlikely event of a bankruptcy, we may disclose, share or transfer some or all our users’ Personal Information to or with this entity in preparation of the transaction, as part of the due diligence, or after the transaction has been consummated, so that the successor entity can continue providing services to our users. If the recipient of the Personal Information has personal information practices that do not meet the substance of this Privacy Policy, you will be given the opportunity to exercise your rights with respect to your Personal Information.

Law enforcement and litigation – certain federal, state, local, overseas or other government regulations may require that we disclose information that we hold. In such cases, we will use reasonable efforts to disclose only the Personal Information required under applicable law, such as in response to a facially valid court order, warrant or subpoena issued or made by a court, person or body. We may use or disclose Personal Information: (a) if we believe in good faith that a law, regulation, rule or guideline requires it; (b) to a person who needs the information because of an emergency that threatens the life, health or security of an identified group or person; or (c) in other circumstances where we are permitted to do so by law.

Aggregated data – other than as stated above, if EI World provides a third party with Personal Information, it will be in the form of aggregated data and used for product development, research or statistical analysis. Aggregated data is created from records that are stripped of all personal identifiers, such as a combination of multiple answers to survey questions and instrument responses.

How We Deal with any International Transfers Needed with Your Data

Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. As these countries outside of the European Economic Area (EEA) they are not required to offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of security of data by making sure that at least one of the following safeguards is implemented: 

  • The third party that we are using has voluntarily complied with GDPR legislation in order to maintain a safe a secure transfer of data.
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us using the details in the Contact Us section below if you would like further information on any transfers of your personal data which occur outside of the EEA.

How Long We Keep Your Data For

In general, we retain all Assessments, Reports, Surveys, Coaching Notes, Correspondence, Team Action Plans and Meeting Notes that are stored electronically for a minimum of six (6) years from the end of any given Customer Contract. Thereafter, we retain the same information for as long as necessary to ensure we can provide appropriate continuity for client relationships and for our research, statistical analysis or product development. Information is stored within our encrypted cloud-based storage system.

Exceptions to the above retention policy are detailed below:

Personal Data obtained from our learning portal at /www.eiworldsurveys.net is securely stored electronically on permanent media, securely and off-site for a period of 3 years (this may be reduced in the event of a specific request or separate client agreement which overrides this).

From time to time we conduct Customer debriefs and various client meetings by means of video conference. These video calls are recorded to enable our client relations and assessment processes to run in the most efficient manner. The recordings are kept on our service provider’s secure video conferencing portal or downloaded to our secure cloud-based storage facility, for either of the following:

  • In the case of qualified practitioner debriefs these links are shared with the practitioners and internally within Ei World for ongoing training and quality assurance purposes and are then deleted after 2 weeks.
  • In the case of any other client meetings which take place over video conferencing to scope or discuss projects, the videos are deleted 2 years from either the date the project was scoped, but did not go ahead, or the date our project contract with the customer ceases.
  • From time to time it may be deemed necessary to retain video recordings for future training purposes, either internally or externally, or marketing purposes, however, when used these videos will be kept on an anonymous basis with no personal information shared.

From time to time we create videos of Workshops, Accreditations and Testimonials from our clients. These videos are stored as follows:

  • Workshops – these videos are stored as unlisted files (non-searchable) on YouTube and shared solely within client organisations only. Videos are maintained for a minimum of 6 years, and this is increased should the need arise because the relationship with the Client remains. No personal information is shared within these videos.
  • Accreditations – these videos provide a marketing tool to promote Ei World accreditation programs on our website. Videos are maintained for a minimum of 6 years, and this is increased should the content remain relevant to the existing accreditation. Images of delegates with no other personal information may be shared within these videos, which are located on the Ei World website.
  • Testimonials – these videos provide a marketing tool for Ei World and are created with the express permission of the testimonial givers. Videos are maintained for a minimum of 6 years, and this is increased should the content remain relevant to the existing product or service. Videos of testimonial givers, together with their name and other personal information is included and these videos are shared within the Ei World website and Ei World YouTube page.

Any personal information that is physically held by us on paper is destroyed within 6 months of the close of the relevant contract/project, or in the case of potential contracts/projects within 6 months of the end of scoping.

How We Protect Personal Information

We undertake to take appropriate administrative, physical, and technical measures in view of the risks inherent in the processing and handling of Personal Data, with the aim of preventing any unauthorised access, alternation, disclosure, misuse, loss or destruction of the data.

Any data collected by EI World is protected by encryption. This means we keep data in an unreadable state unless a user or process presents the appropriate key. This ensures that your personal data is restricted only for authorized use and ensures that when using our online platforms users can access no data other than those to which their access right refers. Our data is encrypted at rest and in transit, ensuring that during communication of personal data and transport of any storage media the data cannot be read, copied or erased without authorisation. EI World’s use of encryption together with our access controls provides users with confidence in their data’s integrity.

We also undertake to ensure that our obligations in matters of data protection are adhered to by any third-parties or sub-contractors. The applicable law for the obligation of confidentiality and security is under UK law where the processing takes place.

Identity theft and the practice currently known as ‘phishing’ are of great concern to us. For more information about protecting yourself from these practices, you can visit www.ncsc.gov.uk/phishing.

Please understand that you also have a responsibility in protecting your information. The only time when an EI World Associate may contact you (via electronic communication, postal mail, telephone, etc.) about your payment information is in connection with a transaction that you have initiated. Otherwise, no one from EI World is permitted to contact anyone to request your credit card information, national identification number, or other identifier or sensitive information in a non-secure or unsolicited email or telephone communication.

Data Accuracy

We will exercise reasonable efforts to keep your Personal Information accurate. However, we need your help in making sure that your Personal Information is correct in our systems. Please notify us of changes to information that you have previously provided by contacting us as indicated in the Contact Us section below.

Your Rights

Right to access information – you have the right to access details of Personal Information we hold and to correct or update the Personal Information that you have provided to EI World. If you wish to do so, please contact us (using the information provided in the Contact Us section below) with proof of identity. You can expect a response to your request within 30 days.

If you are an Assessment or Survey Taker and you wish to have access to a copy of your responses to an Assessment or Survey, or a copy of the Assessment Report that EI World prepared from the evaluation of your responses, please contact us using the information provided in the Contact Us section below.

Right to be forgotten – if you wish to cancel your account or request that we no longer use your information to provide you with services, please contact us (using the information provided in the Contact Us section below) with proof of identity. We will accommodate your request within 30 days to the extent practicable, and to the extent that it does not otherwise conflict any of our other obligations. Please note that sometimes we may not be able to remove your personal information in order to comply with our legal obligations, resolve disputes and enforce our agreements in which case we will let you know this and explain why.

Right to opt-out of Newsletters – you may unsubscribe from receiving a newsletter by contacting us as set out in the Contact Us section below or clicking on the unsubscribe link provided in the newsletter. Although this will remove you from our mailing list, we will continue to hold data about you in accordance with our Privacy Policy.

Complaints and Disputes

If you have questions or complaints regarding our privacy policy or practices, you should first contact EI World as indicated in the Contact Us section (below).

If we are unable to satisfactorily resolve your concerns about the privacy or handling of your Personal Information, you can contact the UK’s Information Commissioners Office (www.ico.org.uk/global/contact-us/).

Changes to this Privacy Policy

From time to time we will revise and change this Privacy Policy. If we make material changes, we will place a prominent notice on our website or will send you a notice to the email address that you provided to us. Non-material changes will only be updated on our website.

Contact Us

If you have any questions about (a) this Privacy Policy, (b) the collection, use, management, or disclosure of your Personal Information, (c) which personal information we are holding in relation to you or (d) accessing or modifying your Personal Information please contact us as indicated below.

We will aim to respond to your questions or concerns within a timely manner.

By email:       info@eiworld.org

By phone:      +44-(0)20-3507-0270

By Mail:          Ei World Limited, 1 Cornhill, London, EC3V 3ND

Privacy Policy v1 – 23rd May 2018

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