PRIVACY POLICY FOR ONLINE TRAINING PARTICIPANTS
We, at Development Pathways Ltd., respect your right to privacy.
This Privacy Policy applies to your use of Development Pathways’ online training course site and any relevant sites on www.developmentpathways.co.uk you may use during the training course. It tells you what to expect when we collect personally identifiable information about you, and what your rights are concerning the collection of your information.  It is provided in accordance with our obligations under the UK Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR). 
We will not collect any personally identifiable information about you unless it is in response to you using our website or actively registering for one of our online training products. The security of your personally identifiable information is extremely important to us. We care about how your personal data is used and want to assure you that your personal information is collected responsibly and carefully.  
This Privacy Policy will explain what personal data is collected, the reason we collect it and how we use it.
Please be assured that Development Pathways does not sell, rent or otherwise distribute any user’s personal data to third parties.
Please review this Privacy Policy carefully.  This should be read alongside the Cookies Policy and the Terms and Conditions. Unless otherwise defined, the terms used have the same meaning as the Terms.
By agreeing to take part in the online training course and on first usage of our training site, you are accepting our Privacy Policy and agreeing with the lawful use of your personal data.
If you do not accept and agree with this Privacy Policy, then you must refrain from using our site immediately.
1	INFORMATION ABOUT US
In the Privacy Policy, references to ‘we’ or ‘us’ are to Development Pathways Limited, a company incorporated in England and Wales, Company number 07408331, whose registered office is at First Floor, Marlesfield House, 114-116, Main Road, Sidcup, DA14 6NG, United Kingdom.
2	DEFINITIONS AND INTERPRETATION
2.1	“Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via our site and registration form. This definition shall, where applicable, incorporate the definitions provided in the UK Data Protection Act 2018 and EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
2.2	“We/Us/Our” refers to Development Pathways Limited. 

3	WHAT DOES THIS POLICY COVER?
3.1	This Privacy Policy applies to your use of Development Pathways’ online training course. It tells you what to expect when we collect personally identifiable information about you, and what your rights are concerning the collection of your information. It is provided in accordance with our obligations under the UK Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR).
3.2	Our online training site may contain links to other websites. Please note that we may have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies and cookie policies of any such websites, before providing your personal data to them.

4	COLLECTION AND USE OF DATA
When you register and purchase an online training course with Development Pathways, we are required to collect information from you.  This information will never be published or shared with third parties. We will make you aware of the Privacy Policy and Cookies Policy, as part of the Terms and Conditions, to which you will be asked to agree. 

4.1.	Personal information:
Data Collected 1: Contact information: name and email address	
How we use the data:
•	It will only be used for our own communication and statistical purposes. 
•	It will be used to send email notifications and updates related to the online training. 
•	We may also contact you to share your opinions and experiences of the course and well as for marketing future courses. 
•	Internal marketing research purposes.
•	Providing and managing your access to our site.
Data collected 2: Photos or videos
How we use the data:
	•	As part of the communication of Development Pathways’ work, we may use imagery and videos in which some individuals may be identifiable. 
•	You would have given explicit consent for this by accepting the terms and conditions of this course. 
•	Any videos in which participants of the course are identifiable will not be used for future commercial endeavours.
Data collected 3: Data relating to your use of our website and enrolment on the online course	
How we use the data:
•	Business or company or organisation name; country of operations; job title could be provided which could be used for personalising and tailoring our products and services to you.
•	This information collected will be dependent on how you use the site, such as the information you provide when signing up for an e-coaching session with a trainer, when you write a direct question to the trainers or when you participate in the discussion forum. This information will only be used to ensure your participation in the course.
Data collected 4: Information provided for correspondence	
How we use the data:
•	Such as telephone, address, country of residence, post code and email address.  
•	Only internal staff involved with the training will use this information and only when necessary.  
•	With your permission and/or, where permitted by law, we may also use your data for marketing purposes which may include contacting you by email or telephone or text message or post with information, news and offers on our products and services. 
•	We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
•	Providing the training courses and certificates for the online courses.
Data collected 5:  Financial Information: credit/debit card information	
How we use the data:
•	Required for the purposes of payment/transaction  for the purchase of the course.

4.2.	 Non-personally identifiable information: when you access the training site, analytical or performance cookies collect certain information related to you, such as the Internet Protocol address used, your navigation through the site and device and browser used. Similarly, our registration platform, Wufoo, uses web beacons to produce reports on behaviour, in relation to the registrations forms we provide, including the IP address. This information does not identify you and will be used for internal use only, including but not limited to the analysis of location to determine taxing regulation applicable to the ticket price of the course.


5	LAWFUL BASIS FOR PROCESSING YOUR DATA
The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the product you have paid for or to improve our services.
Activity 1 requiring your data:	
Use of your personal information 	
Lawful basis for activity 1:
•	Necessary to perform our obligations under our contract with you, which includes providing you with access to the online training course for which you have registered and/or made a purchase. 
•	Also necessary in order to ensure we deliver a high level of customer service through ongoing customer communications and responses to customer queries.
•	Track and ensure completion of contractual obligations.
•	Carry out internal market research and business development.
Activity 2 requiring your data:
Sending marketing and promotional communications from Development Pathways only.	
Lawful basis for activity 2:
•	Only where we have explicit consent to collect, store, and use your information for this purpose.
Activity 3 requiring your data:
Use of financial information
Lawful basis for activity 3:	
•	Payment to be carried out in order to receive a service, which is part of the contract.

6	RETENTION PERIODS
We retain personal data we collect from you where we have an ongoing legitimate business need to do so, e.g., accounting requirements. We do not keep your personal data for any longer than is necessary, in relation to 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.
•	As long as you remain on any mailing lists.
When we have no ongoing legitimate business need to process your personal information or you have requested to be taken off the mailing list, we will delete your personal data.
7	STORAGE AND SECURITY OF DATA
All stored data is safeguarded using our organisation’s secure server. We use technical and organisational measures including using accounts and a server that is protected through strong passwords and multi-factor authentication. We will hold your data only for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the data be deleted. In relation to images, these will be retained for as long as is necessary to communicate the project to which they relate, only with the consent of any individuals who may be identifiable. 
8	EMAILS AND PERSONAL DATA
In relation to emails to and from Development Pathways, if you receive any confidential information accidentally or you have reason to believe that there has been a breach of personal data, please contact the  Data Compliance Officer.
9	MORE INFORMATION AND YOUR RIGHTS
You may have the following data protection rights:
•	To access, correct, update or request deletion of your Personal Information. Development Pathways takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, or altering your data, by emailing us at admin@developmentpathways.co.uk. We will consider your request in accordance with applicable laws.
•	In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at admin@developmentpathways.co.uk.
•	You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
•	You may access our site without providing any data at all. However, to use all features and functions available on our site you may be required to submit or allow for the collection of certain data.
•	In addition, you can choose to disable Cookies in your Internet browser, by changing the default settings in your Internet browser. For further details, please consult the help menu in your Internet browser and/or refer to aboutcookies.org, which also provides more information generally on Cookies.
•	And if you no longer wish to be contacted by email, please contact us directly to update or delete your data, by email at admin@developmentpathways.co.uk, by telephone at +44 (0)20 4526 6267, or by post at First Floor, Marlesfield House, 114-116, Main Road, Sidcup, DA14 6NG, United Kingdom.
10	UPDATING THIS PRIVACY POLICY
We may update or amend this Privacy Policy from time to time, to comply with the law, in accordance with best practice in our industry, or to meet our changing business requirements. Any updates or amendments will be posted on our site. By continuing to access our site, use the online courses and/or content , you will be deemed to have accepted the Privacy Policy as amended at the time of your access and use. We, therefore, recommend you check this page regularly.
This Privacy Policy was last updated on 1 March 2021.

Terms and Conditions

The terms and conditions set out below and our Privacy and Cookies Policies together constitute the legal agreement between you and Development Pathways Ltd relating to the provision of this training course.
1.	Course Fee, Payment & Registration
1.1.	The course fee must be paid in full before the start date of the course (1 March 2020), unless prior written agreement has been provided by Development Pathways Ltd.
1.2.	Development Pathways has the right to refuse entry to the course and use of course materials if the course fee is not paid before the course date, unless prior written agreement has been provided by Development Pathways Ltd.
1.3.	Participants will only be considered registered on the course once the course fee has been paid in full.
2.	Participant Cancellation
2.1.	The customer must advise Development Pathways Ltd of a cancellation in writing.
2.2.	If a customer does not advise of a cancellation in writing before the start date of the course the full course fees will not be refundable.
2.3.	If a customer advises of a cancellation 7 days or more before the start date of the course fee will be fully refundable.
2.4.	If a customer advises of a cancellation 7 days or less before the start date of the course 50% of the course fee will be refundable.
3.	Development Pathways Cancellation
3.1.	Development Pathways Ltd has the right to cancel the course after the acceptance of registrations. In this event Development Pathways Ltd will reimburse in full any course fees paid and Development Pathways Ltd.’s liability will be limited to the value of the course fees paid.
4.	Intellectual Property
4.1.	All intellectual property rights (including copyright) over any materials used as part of the course belongs to Development Pathways Ltd.
4.2.	Development Pathways Ltd allows the use of all applicable study materials in a personal capacity or professional capacity, providing due credit is given to Development Pathways Ltd and as long as the materials are not used in a commercial capacity for profit.
4.3.	By registering for the course participants agree that they will not copy, make available, transmit, reproduce, sell, licence, distribute, publish or broadcast or otherwise share the course materials provided as their own intellectual property.
4.4.	Participants agree to not record any elements of the course lectures in any way without authorisation from Development Pathways Ltd.
4.5.	Only registered and admitted participants may access and participate in the course.










5.	Personal Data & Privacy
5.1.	Any personal data supplied by the customer can be processed by Development Pathways Ltd on the legal basis and for the purposes set out in the Privacy Policy and in line with GDPR requirements.
5.2.	All lectures provided as part of the course will be recorded. By participating in this course, you agree to being recorded and for these recordings to be shared to all participants of the course and internally within Development Pathways Ltd.
5.3.	By agreeing to these terms and conditions, you are agreeing that you understand that there will be filming and recording. Your participation in photography at the training is voluntary, and you can choose not to participate in part or all. You have the right to withdraw your consent at any time by emailing Development Pathways at inclusivesp@developmentpathways.co.uk.
5.4.	By agreeing to these terms and conditions, you are agreeing to being contacted regarding future training course offered by Development Pathways. If you do not wish to be contacted, please opt out by emailing Development Pathways at inclusivesp@developmentpathways.co.uk.
6.	Agreement to the terms and conditions
6.1.	By starting participation in the course, it is noted that the participant has agreed to these terms and conditions.