This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data, and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.
Churchill Leadership Group is pleased to provide the following Privacy Notice:
Personal Data (What it is, How we collect it, What we do with it)
Personal information is data that identifies you or that makes you identifiable. It includes data that could be used to identify, locate, track, or contact you. Your name, emails, and phone numbers are included in your personal information. Information on server logs and cookies may, in some instances and with some effort, identify you; this type of information is included in Personal Information.
Depending on our relationship with you and your consent given to us, Churchill uses the information collected from you to provide our services, quotations, make telephone contact, and/or email you marketing materials or updates on Churchill’s news, events, or offers, which Churchill Leadership Group believes may be of interest to you and your business.
Generally, we collect information about you in the following ways: (1) use of our website, (2) contact us via social media such as LinkedIn, and (3) our client services.
As described below, our website may use certain cookies.
From our client services: When we provide services, we enter into a contract with our clients. Our agreements will address privacy and personal data matters.
For all persons living in the EU, however, we get access to your personal data; our policy is not to store, collect, or use your personal data, including adding you to our CRM, marketing, or promotional emails or notices, unless: (1) you are a client and we need to do so to provide our services to you, or (2) you give us your express consent to do so.
Once you consent to Churchill Leadership Group maintaining a marketing dialogue with you, you can always take it back. You opt out (which you can do at any stage and any time).
Churchill Leadership Group also acts on behalf of its clients in the capacity of a data processor. When working exclusively as a data processor, Churchill Leadership Group will act on its client’s instruction and will work hard to ensure that the client is fully GDPR compliant.
Personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls, and details of your visits to our website, including but not limited to personally-identifying information like Internet Protocol (IP) addresses. Churchill Leadership Group may, from time to time, use such information to identify its visitors. Churchill Leadership Group may also collect statistics about the behavior of visitors to its website.
Churchill Leadership Group will only collect the information needed to provide you with our leadership development and consulting services and/or, if you expressly consent, keep you updated with Churchill’s news, events, or offers. Churchill does not sell or broker your data.
Legal basis for processing any personal data
The legal basis for processing any personal data is to meet Churchill’s contractual obligations to clients and respond to inquiries about our services.
Legitimate interests pursued by Churchill Leadership Group and/or its clients
The legitimate purposes for which we collect Personal Data include:
- To provide our coaching, facilitation, consulting, and training services to our clients
- To maintain relationships with existing or former clients
- To evaluate our business operations [e.g., identify decision-makers in companies we may wish to contact]
Subject to the remainder of this Policy (including obtaining express opt-in and consent), we may also process Personal Data for the following reasons:
- To promote and market our services to prospective and existing clients
- To conduct email, online, and other marketing campaigns
- To send newsletter or educational value or other updates
Churchill may occasionally pass your Personal Information to third parties exclusively to process work on its behalf. Churchill Leadership Group requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.
Churchill does not broker or pass on information gained from your engagement with us without your consent. However, Churchill may disclose your personal data to meet legal obligations, regulations, or valid governmental requests. Churchill may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property, or safety of Churchill, its clients and/or the wider community.
Churchill will process and store personal data:
If we got your information via this website or social media: we will keep your personal data until either (1) you opt out or (2) we cease providing our services and/or sending updates on our news, events, and offers.
If you are a client: we will keep your personal data during the duration of our services under any contract with you. We will continue storing only the personal data needed for five years after the contract has expired to meet legal obligations. After five years, any personal data not required will be deleted.
Churchill Leadership Group, Inc. stores your Personal Data and information from our web server logs and Cookies on a server located in the United States. The current provider of the server is Google LLC, headquartered in Council Bluffs, IA. If different company hosts or maintains the server N/A, a company located in N/A hosts and maintains the server.
Your name, email address, and phone number are stored in third-party CRM, email and marketing platform, a password-protected cloud platform, and password-protected local storage. We have confirmed that these third-party platforms are GDPR compliant.
YOUR RIGHTS AS A DATA SUBJECT:
At any point while Churchill Leadership Group has or processing your data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organization.
- Right to object – you have the right to object to certain types of processing, such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
If Churchill refuses your request under rights of access, we will provide you with a reason, which you have the right to challenge legally.
Churchill Leadership Group, at your request, can confirm what information it holds about you and how it is processed.
You can request the following information:
- Identity and the contact details of the person or organization (Churchill Leadership Group) have determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Churchill Leadership Group or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored, and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (Data Protection Regulator).
- Whether the provision of personal data is a statutory or contractual requirement or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required.
Churchill will accept the following forms of ID when information on your data is requested: a copy of your national ID card, driving license, passport, birth certificate, and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Churchill is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to firstname.lastname@example.org and put “personal data” in the subject line or by phoning or writing to us at the address below.
If you wish to complain about how Churchill Leadership Group or its partners are processing your personal data, you have the right to complain to Churchill Leadership Group’s CEO. If you do not get a response within 30 days, you can complain to the Data Protection Regulator located in the EU.
The details for each of these contacts are:
Churchill Leadership Group, attention of the CEO
411 Walnut Street 15098
Green Cove Springs
Data Protection Regulators
Should you wish to report a complaint or if you feel that Churchill Leadership Group has not addressed your concern satisfactorily, you may contact:
In the EU:
The EU authorities: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
In the UK:
ICO (The UK’s Information Commission Office) at:
In the USA:
Other countries may have their own privacy-related agencies to assist their citizens or residents.
Privacy Policies Of Other Websites
Children Under 13
We do not specifically market to or knowingly collect personal information from children under 13 for marketing or any purpose. Because some information is collected online, it may not appear to be the personal information of a child under 13. If a child under 13 submits personal information to us and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you are under 13, please do not register for any of our services or provide us any information about yourself (such as your name, email address, or phone number).
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