Privacy Policy
READ MORE ABOUT UNLEASH GROUP LTD’S PRIVACY POLICY
UNLEASH Group Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. What is the purpose of the policy and who are we?
This privacy policy aims to give you information on how UNLEASH Group Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up as a registered user to our website and/or when you access third party content accessible through our website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller: This site is owned and operated by UNLEASH Group Ltd, part of a number of companies which make up the UNLEASH group of companies. The UNLEASH group of companies is made up of different legal entities each of whom act as data controllers, including UNLEASH Group Ltd (incorporated in the United Kingdom with company number 12249873), UNLEASH America Ltd (incorporated in the United Kingdom with company number 14748859), UNLEASH World Ltd (incorporated in the United Kingdom with company number 14748927) and UNLEASH Group Kft (incorporated in Hungary).
This privacy policy is issued on behalf of the UNLEASH Group so when we mention “UNLEASH” “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the UNLEASH Group responsible for processing your data.
UNLEASH Group Ltd is the controller and responsible for this website, they will be the controller for your data for any products or services purchased through this website.
We have appointed a data protection representative who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the representative using the details set out below.
Full name of legal entity: UNLEASH Group Ltd
Email address: privacy@unleash.ai
Postal address: Data Protection Team, UNLEASH Group Ltd, 180 Borough High Street, FORA, London, SE1 1LB, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 8th July 2024. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
3. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy policy of every website you visit.
4. What data do we collect about you?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, employer or company name, work address, job title, role, delivery address, email address and telephone numbers.
- Financial Data includes bank account, control over budget at your company/employer, and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
6. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services (including purchasing tickets or passes for our webinars and events);
- create an account on our website;
- subscribe to our service or publications (including newsletters);
- enquire about our events;
- enquire about our sponsorship opportunities;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- At events. We host events throughout the year at which we may record or take photos of attendees. Such recordings are likely to feature the likeness of individuals who attended the events as well as Identity Data and, in some instances, Contact Data.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks; and
- search information providers.
- Technical Data from the following parties:
- Identity and Contact Data from data brokers or aggregators such as Lead Forensics or ZeroBounce based inside and outside the EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside and outside the EU.
- Identity and Contact Data from mailing lists purchased from third parties, social networks, and recruitment agencies.
7. How we use your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing
communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please make sure you are contacting us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose / Activity | Type of Data | Lawful basis for processing (including basis of legitimate interest) |
To register you as a new customer (for example, your data will be stored and processed by us in the software platform which control access to different parts of our website and your membership, and our customer relationship management software platform) | (a) Identity (b) Contact | Performance of a contract with you |
To process and deliver your order of a product of the deliver of a service including: (a) Manage payments, fees and charges (for example your data will be stored and processed by us in the software platform used to deliver webinar services) (b) Collect and recover money owed to us (c) Delivery of a webinar | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (for example your data will be stored and processed by us within our email automation software) | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
When you choose to take part in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
Taking photos/videos at events | (a) Identity (b) images | Necessary for our legitimate interests (to create content relating to our events for future reference and to allow us to better market our products/services) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
To provide our third-party Sponsors (as part of a sponsorship package they purchase) who may make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Your consent and necessary for our legitimate interests in sharing contacts with our Sponsors in order to build and deepen our relationships with our Sponsors |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
An example of this is where you access certain sponsored content, to access such parts of our website, you will have to consent to the sharing of your personal data with third parties so that they can directly market to you.
Opting out
You can ask us to stop sending you marketing messages at any time by various methods:
- by following the opt-out links on any marketing message sent to you; or
- by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, product/service experience or other transactions.
You can ask third parties to stop sending you marketing messages in similar ways, for example:
- by following the opt-out links on any third-party marketing messages sent to you by them; or
- by contacting the third party at any time; or
- by accessing the website of the third party and obtaining the contact details of the individual or department responsible for processing your data (this should be found in those parties’ privacy policies).
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
8. How, and to whom do, we disclose your personal data?
We may share your personal data with the parties set out below for the purposes set out in the table headed ‘Purposes’ for which we will use your personal data above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Specific third parties such as our Sponsors as set out in the Glossary, which may include data being sold to our Sponsors as part of a package of benefits.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9. Do we transfer your data internationally?
We share your personal data within certain members of the UNLEASH Group situated within the European Economic Area (EEA).
Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- European Commission/UK ICO: Adequacy of the protection of personal data in non-EU countries.
- European Commission/UK ICO: Model contracts for the transfer of personal data to third countries, such as the Standard Contractual Clauses or a UK Data Protection Addendum (“Appropriate Safeguards”).
Please make sure you are contacting us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Many of our External Third Parties, and the third parties we share your data with, are based outside the UK/EEA so their processing of your personal data will involve a transfer of data outside the UK/EEA. Where we transfer your personal data to such third parties it will be made either subject to an adequacy decision or the Appropriate Safeguards referred to above.
10. How do we secure your data?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. How de we retain your data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see “What are your legal rights” below for further information.
In some circumstances we will anonymise 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.
12. What are your legal rights?
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data;
- Request correction of the personal data that we hold about you;
- Request erasure of your personal data;
- Object to processing of your personal data;
- Request restriction of processing of your personal data;
- Request the transfer of your personal data to you or to a third party; and
- Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us at privacy@unleash.ai.
You will not 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 could 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 try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
13. Glossary – What do all these terms mean?
A) LAWFUL BASIS
‘Legitimate interest’ means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
‘Performance of a contract’ means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
‘Comply with a legal obligation’ means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
B) THIRD PARTIES
Internal Third Parties:
- Other companies in the UNLEASH Group acting as joint controllers or processors and who are based in Hungary and provide IT and system administration services and undertake leadership reporting.
External Third Parties
- Service providers acting as processors who provide IT, system administration, sales management and engagement systems, electronic signature providers, website developers and providers of CRM systems and services.
- Sub-contractors, such as events service providers and webinar hosting services who assist us in delivering our events.
- Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and Hungary who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Sponsors / Partners: Certain sponsors and commercial partners of our physical and online events who include certain HR IT service providers, recruitment firms, training service providers and others, further details of whom may be listed on our website under each event listing. Such transfers typically take place as part of a package which is sold to the relevant sponsor/partner.
C) YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data. (Commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data. For example, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
- In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.