Privacy policy

This privacy policy applies between you, the User of this Website and Dragonfly: Impact Education, the owner and provider of this Website. Dragonfly: Impact Education takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

Definitions and interpretation

  1. In this privacy policy, the following definitions are used:
    Data collectively all information that you submit to Dragonfly: Impact Education via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
    Cookies a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
    Data Protection Laws any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
    GDPR the General Data Protection Regulation (EU) 2016/679;
    Dragonfly: Impact Education,
    we
     or us
    Dragonfly: Impact Education, a company incorporated in England and Wales with registered number 11504105 whose registered office is at 20-22 Wenlock Road, London, England, N1 7GU;
    UK and EU Cookie Law the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
    User or you any third party that accesses the Website and is not either (i) employed by Dragonfly: Impact Education and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Dragonfly: Impact Education and accessing the Website in connection with the provision of such services; and
    Website the website that you are currently using, www.dragonflyimpact.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
  2. In this privacy policy, unless the context requires a different interpretation:
    1. the singular includes the plural and vice versa;
    2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
    3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
    4. “including” is understood to mean “including without limitation”;
    5. reference to any statutory provision includes any modification or amendment of it;
    6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

  1. This privacy policy applies only to the actions of Dragonfly: Impact Education and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
  2. For purposes of the applicable Data Protection Laws, Dragonfly: Impact Education is the “data controller”. This means that Dragonfly: Impact Education determines the purposes for which, and the manner in which, your Data is processed.

Data collected

  1. We may collect the following Data, which includes personal Data, from you:
      1. name;
      2. date of birth;
      3. job title;
      4. profession;
      5. contact Information such as email addresses and telephone numbers;
      6. IP address (automatically collected);
      7. web browser type and version (automatically collected);
      8. operating system (automatically collected);
      9. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

    in each case, in accordance with this privacy policy.

How we collect Data

  1. We collect Data in the following ways:
    1. data is given to us by you; and
    2. data is collected automatically.

Data that is given to us by you

  1. Dragonfly: Impact Education will collect your Data in a number of ways, for example:
      1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
      2. when you elect to receive marketing communications from us;
      3. when you use our services;

    in each case, in accordance with this privacy policy.

Data that is collected automatically

  1. To the extent that you access the Website, we will collect your Data automatically, for example:
    1. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
    2. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

Our use of Data

  1. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
    1. internal record keeping;
    2. improvement of our products / services;
    3. transmission by email of marketing materials that may be of interest to you;
  2. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
  3. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
    1. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
    2. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
    3. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
  4. We may use your Data to show you Dragonfly: Impact Education adverts and other content on other websites. If you do not want us to use your data to show you Dragonfly: Impact Education adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).

Who we share Data with

  1. We may share your Data with the following groups of people for the following reasons:
      1. our employees, agents and/or professional advisors – in order to provide services;
      2. relevant authorities – if necessary, to facilitate the detection of crime;

    in each case, in accordance with this privacy policy.

Keeping Data secure

  1. We will use technical and organisational measures to safeguard your Data, for example:
    1. access to your account is controlled by a password and a user name that is unique to you.
    2. we store your Data on secure servers.
  2. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: info@dragonflyimpact.co.uk.
  3. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

  1. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
  2. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

  1. You have the following rights in relation to your Data:
    1. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    2. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
    3. Right to erase – the right to request that we delete or remove your Data from our systems.
    4. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
    5. Right to data portability – the right to request that we move, copy or transfer your Data.
    6. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
  2. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@dragonflyimpact.co.uk.
  3. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
  4. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

  1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

  1. Dragonfly: Impact Education may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Dragonfly: Impact Education. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
  2. We may also disclose Data to a prospective purchaser of our business or any part of it.
  3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

  1. This Website may place and access certain Cookies on your computer. Dragonfly: Impact Education uses Cookies to improve your experience of using the Website and to improve our range of services. Dragonfly: Impact Education has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
  2. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
  3. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Dragonfly: Impact Education to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
  4. This Website may place the following Cookies:
  5. You can find a list of Cookies that we use in the Cookies Schedule.
  6. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
  7. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
  8. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
  9. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

  1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
  2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
  3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
  4. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

  1. Dragonfly: Impact Education reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. 

    You may contact Dragonfly: Impact Education by email at info@dragonflyimpact.co.uk.

Attribution

  1. This privacy policy was created using a document from Rocket Lawyer (https://www.rocketlawyer.co.uk).

Dragonfly: Impact Education Privacy Notice

Introduction

·        We respect your privacy and are committed to protecting your personal data. 

·        This privacy notice sets out details of the data that we may collect from you and how we may use that information. A separate privacy notice explains how we handle your personal data if you access our website.

·        This privacy notice also tells you about your privacy rights and how the law protects you. We have a legal duty under the Data Protection Act 2018 (“DPA 2018”) and General Data Protection Regulation (Regulation EU 2016/679) (“the GDPR") to handle your information in certain ways. 

·        Please take your time to read this privacy notice carefully.

Definitions

·        In this policy, the ‘client’ is the person to whom we provide services (coaching, mentoring, training, teaching, consultancy).

·        As the nature of our work means we hold data on clients and their families, we use ‘you’/’your’ to refer to the client or, if the client is under 18, to refer to the parents/guardians and/or the client.

About us

·        In this Privacy Policy we use “we" or “us" or “our" or “Dragonfly" to refer to Dragonfly: Impact Education (which is a a private limited company established in 2018 – Company Number 11504105)

Our data protection officer and how to contact us

·        Dragonfly: Impact Education is the data controller for the information we collect about you.

·        The Data Protection Officer (“DPO") Dragonfly: Impact Education is the Operations Director.  If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below:

Email: info@dragonflyimpact.co.uk

Postal address:

18 Ferrers Way

Darley Abbey

Derby

DE22 2AB

Telephone number: 07967 753778

Complaints about how we handle your information

·        You have the right to make a complaint at any time to the Information Commissioner’s Office (“the ICO"), the UK supervisory authority for data protection matters (website: ico.org.uk / address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF / telephone: 0303 123 1113). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.  If you wish to contact us to make a complaint, you can do so by contacting the Directors, whose contact details are as follows:

Email: Claire@dragonflyimpact.co.uk/Rachael@dragonflyimpact.co.uk

Address: as above 

Phone: 07809 626965

Purpose of this Privacy Notice

This privacy notice aims to explain:

·        Why do we collect data about you?

·        What data do we collect about you?

·        How do we collect your information?

·        What are the purposes for which your data is used?

·        Who do we share your data with?

·        How long do we keep your data for?

·        What are your rights?

 Why we collect data about you

·        In general terms, we collect and process your data for the purposes of coaching, mentoring, training, teaching or consultancy. We will collect and process data for other purposes, including those which are incidental to the provision of our services and for research purposes.

What data we collect about you

·        The data that we collect will depend on your relationship with us.

·        If we deem there to be a safeguarding concern, or legal or statutory requirement, we may use “sensitive personal information” (otherwise known as “special categories of data") about you, such as information relating to your physical and mental health.

·        If you provide personal information to us about other individuals you should inform the individual about the content of this privacy notice. We will process such information in accordance with this privacy notice. 

Personal information

The personal information we hold about you may include the following:

·        Name, address, date of birth.

·        Telephone numbers.  

·        Next of kin / emergency contact.

·        Age of child/children  

Sensitive Personal Information

The sensitive personal information we hold about you may include the following:

·        Details of your current or former physical or mental health. This may include information about any health care you have received or need, including about clinic and hospital visits and medicines administered.

·        Details of services you have received from us.

·        Information relevant to your continued care from other people who care for you or know you well, such as other health professionals and relatives.

·        Details of your race and/or ethnicity.  

·        Details about any disabilities.

·        Details about your language preferences. 

·        Details of your religion.  

·        Data concerning your sex life and/or sexual orientation.

The confidentiality of your medical information is of paramount important to Dragonfly.  We therefore make every effort to prevent unauthorised access to and use of information relating to your current or former physical and mental health.  We provide further details about this in our patient privacy notice here

How we collect your information

·        How we collect your information will depend on your relationship with us. In general terms, we will collect personal data from you in a number of different ways as is explained below.  

Directly from you

Information may be collected directly from you when:

·        you submit a query to us including through our website, by email or by social media.

·        you correspond with us by email, telephone or social media.

·        you enrol as a client with Dragonfly for the provision of our services.

·        you or your child use those services.

·        you complete forms (whether in electronic or hard copy form) regarding the provision of our services.

From your use of our website

·        Please see our Digital Privacy Notice here

From third parties

Information may be collected from third parties as follows:

·        You are referred to us for the provision of services

·        We liaise with your current or former family, school, employer, health professional or other treatment or benefit provider.

·        We deal with experts (including medical experts) and other service providers about services you have received or are receiving from us

·        Government bodies, including local authorities and the police.

How we will communicate with you

·       In order to communicate with you, we are likely to do this by telephone, SMS, email or post.

·       If we contact you using the telephone numbers which you have provided (landline/mobile) and you are not available which results in the call being directed to a voicemail and/or answering service, we may leave a voice message on your voicemail or answering service as appropriate.

·       However, to ensure we provide you with timely reminders and updates we in relation to our services (including basic administration and appointment information) we may communicate with you via SMS and/or unencrypted email.

·       To provide you with invoicing information, we may communicate with you via email.

·       Please note, providing your email address and/or telephone numbers will be taken as affirmative confirmation that you are happy for us to contact you in that manner, we are not relying on your consent to process your personal data in order to correspond with you about services with us. As set out below, processing your personal data for those purposes is justified on the basis that it is necessary to provide you with Dragonfly services.

Surveys

·       We may contact you to ask you to participate in surveys regarding your experience with Dragonfly.

·       This is not a form of marketing and we will not try to sell you any further products or services.

·       It is solely for the purposes of improving the quality of the services we offer for future clients.

·       It is necessary for us to process your personal data in order for us to contact you with these surveys on the basis of our appropriate business needs and to improve the quality of the services we offer.

·       Participation in the surveys is entirely voluntary and you may decide not to complete the surveys and you will have the option to unsubscribe from receiving further survey invitations.

Marketing we carry out

Please refer to Our Use of Data in our Digital Privacy Policy here

From publicly available sources

·        Information may be collected from publicly available sources including information obtained through internet search engines results and social media sites.

 

Purposes for which your data is used

In general, we may process your data for a number of different purposes. For each purpose we must have a legal ground for such processing.  When the information that we process is classed as a special category of personal data, which is the most sensitive form of personal data from a legal perspective, we must have a specific additional legal ground for such processing.

Generally we will rely on the following legal grounds:

·        Taking steps at your request so that you can enrol as a Dragonfly client in order to receive services from us.

·        For the purposes of providing you with support. We will rely on this for activities such as supporting other education or healthcare professionals and providing other services to you.

·        We have a legitimate interest to process your personal data and this interest is not overridden by your privacy rights. We will rely on this for activities such as quality assurance, maintaining our business records and developing and improving our products and services. More detailed information about our legitimate interests is set out below.

·        We have a safeguarding, legal or regulatory obligation to process your data.

·        We need to use your personal data to establish, exercise or defend our legal rights.

·        It is in the public interest, in line with any laws that apply.

·        You have provided your consent to our use of your personal data. Ordinarily, we will only ask you for permission to process your personal information if there is no other legal reason to process it. You have the right to withdraw your consent at any time.

 

Legitimate interests

We may process your data for a number of legitimate interests in circumstances where these interests are not overridden by your privacy rights.  We will rely on this for activities such as quality assurance, maintaining our business records and developing and improving our products and services.  Taking into account your privacy rights, our legitimate interests include:

·        To manage our relationship with you.

·        To keep our records up to date.

·        To monitor how well we are meeting your performance expectations.

 

You will find details of our legal grounds for each of our processing purposes below.  

Purpose 1: to set you up as a client on our systems

Legal grounds:

·        Taking the necessary steps so that you can enrol as an Dragonfly client for the delivery of our services.

Purpose 2: to provide you with coaching, mentoring, training, teaching or consultancy

Legal grounds:

·        You have provided your consent or applied for our services

Additional legal ground for sensitive personal data:

·        Fulfilling any contractual obligations for the delivery of Dragonfly packages and related services to you.

Purpose 3: Communicating with you and resolving any queries or complaints that you might have.  Communicating with any other individual that you ask us to update.

Legal grounds:

·        We have a legitimate interest to use your data which does not overly prejudice you.

Additional legal ground for sensitive personal data:

·        The use is necessary in order for us to establish, exercise or defend our legal rights.

Purpose 4: Complying with our legal or regulatory obligations

Legal grounds:

·        The use is necessary in order for us to comply with our legal obligations.

·        We have a legitimate interest to use your data which does not overly prejudice you.

Additional legal ground for sensitive personal data:

·        The use is necessary in order for us to establish, exercise or defend our legal rights.

Purpose 5: Providing improved quality and training

Legal grounds:

·        We have a legitimate interest to use your data which does not overly prejudice you.

Additional legal ground for sensitive personal data:

·        The use is necessary in order for us to establish, exercise or defend our legal rights.

Purpose 6: Managing our business operations such as maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice (for example, tax or legal advice)

Legal grounds:

·        We have a legitimate interest to use your data which does not overly prejudice you.

Purpose 7: For educational research purposes 

Legal grounds:

·        We have a legitimate interest in helping with mental health and educational research and have put appropriate safeguards in place to protect your privacy.

Additional legal grounds for sensitive personal information:

·        The processing is necessary in the public interest for statistical and scientific research purposes.

·        You have provided your consent.

Purpose 8: For account settlement purposes

Legal grounds:

·        Providing you with Dragonfly services

·        Fulfilling our contract with you for the delivery of our services.

·        We have a legitimate interest to use your information which does not overly prejudice you.

 

Who we share your data with

We may disclose your information to the third parties listed below for the purposes described in this privacy notice.

·        A doctor, nurse, carer, teacher or any other education or healthcare professional involved in your welfare.

·        Anyone that you ask us to communicate with or provide as an emergency contact, for example your next of kin, parent, or carer.

·        Your GP or those GPs involved with your care.

·        Schools and other educational providers in connection with welfare related matters.

·        Emergency services, including police forces.

·        HM Prison Service and the National Probation Service.

·        The police and other third parties where reasonably necessary for the prevention or detection of crime.

·        Our third party services providers such as, auditors, lawyers and document management providers.

·        Selected third parties in connection with any transfer or termination of our functions.

In some circumstances we may also anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

How long we keep your data for

·        We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this privacy notice and in order to comply with our legal and regulatory obligations.

·        If you are a client of Dragonfly, information relating to your current or former work with us will be retained for 7 years for adults and for children until their 26th birthday (at which point we will review whether there is any requirement to retain).

·        Where your records are stored electronically Dragonfly has ensured that the storage facilities are secure and password protected.

·        Where we store hand-written notes about clients these will be held in fireproof, lockable boxes only accessible to the practitioner who worked directly with the client subject to this privacy notice.

 

Your rights

Under certain circumstances, you have rights under data protection law in relation to your personal data.  These are:

·        To be informed why, where and how we use your information – this is detailed in this privacy notice statement.

·        To ask for access to your information – You can request a copy of the information we hold about you by emailing info@dragonflyimpact.co.uk. The information will be assessed and may have information provided by third parties or about third parties removed before it is given to you.

·        To ask for your information to be corrected if it is inaccurate or incomplete. – If you think any information about you held by Dragonfly is incorrect, please discuss this with us in person or by contacting the Data Protection Officer. We will discuss the changes with you and write to you to explain our decision.

·        To ask for your information to be deleted (also known as the right to be erasure) or removed where there is no need for us to continue processing it. In some circumstances, we must delete your personal information if you ask us to but in many other circumstances where we have a valid legal reason to retain your personal information, we do not have to comply with requests to delete personal information.

·        To ask us to restrict the use of your information. In some circumstances, we must “pause" our use of your personal data if you ask us to. We do not have to comply with all requests to restrict our use of your personal information.  For example, we do not have to comply if we need to use your personal information to defend a legal claim against us.

·        To ask us to copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information. In some circumstances, we must transfer personal information that you have provided to us to you or, if this is technically feasible, another individual or organisation of your choice. The information must be transferred in an electronic format. 

·        To object to how your information is used. Where your information is used for research or statistical purposes you can object to it being processed for this purpose. Please make requests in writing to the Data Protection Officer advising what changes you would like. Dragonfly will never pass your information to anyone for the purpose of direct marketing.

·        To withdraw consent where Dragonfly has relied on this as a condition for processing.

If you wish to exercise any of the rights set out above, please contact us using the details at the beginning of the policy.

Fee

·        You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

·        We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We are obliged by law to respond to all legitimate requests within one month unless your request is particularly complex or you have made a number of requests. In this case, we can take an extra two months to respond to the request and consider charging a fee. If this is the case we will notify you and keep you updated.