Data Protection Policy in accordance with the EU General Data Protection Regulation (GDPR)

This privacy policy sets out the privacy practices for Limitless Group Limited, a company incorporated in England & Wales with company number 12156751 and having its registered office at Golden Cross House, 456 – 459 Strand, London, United Kingdom WC2R 0RG.

Our website is www.angelamiddleton.com  and all associated sub-domains.

We are committed to protecting the privacy and security of your personal information, in accordance with the applicable data protection laws, including the General Data Protection Regulation, together the “Data Protection Laws”. This privacy policy describes how we collect and use personal information about you during and after our relationship with you and your employer or the Rewards Partner (as defined in paragraph 1 below), as appropriate.

If you have any questions at all about this policy or the Website, or about how we use and process your personal information, please do not hesitate to contact us by e-mail at contact@angelamiddleton.com or, alternatively, in writing to Limitless Group Limited, Golden Cross House, 456 – 459 Strand, London, United Kingdom WC2R 0RG

If we change our privacy policy we will post the changes on this page, and may place notices on other pages of the Website, so that you may be aware of the information we collect and how we use it at all times. Continued use of the Website will constitute your agreement to any such changes.

Our Role

Limitless Group are committed to protecting the privacy and security of your personal information, in accordance with the applicable data protection laws, including the General Data Protection Regulation, together the “Data Protection Laws”. This privacy policy describes how we collect and use personal information about you during and after our relationship with you and your employer is committed to a policy of protecting the rights and privacy of individuals (includes learners, staff and others) in accordance with the Data Protection Act.

What information we collect

Limitless Group needs to process certain information about its staff, learners and other individuals it has dealings with for administrative purposes (e.g. to recruit and pay staff, to administer programs of study, to record progress, to agree awards, to collect fees, and to comply with legal obligations to funding bodies and government). To comply with the law, information about individuals must be collected and used fairly, stored safely and securely and not disclosed to any third party unlawfully.

Contact Name :          We will use this to service your enquiry and to ensure we are speaking to the correct person when we make contact.

Contact Number:             We will use this to service your enquiry, we will call you so we can discuss your enquiry with yourself.

Contact Email :                  We will use this to service your enquiry, we will email details of the product or service you have enquired about.

Services Interested In : We will use this to service your enquiry, we will use this so the relevant person can deal with your enquiry ensuring you receive the best level of service

Time & Date Stamp Of Enquiry :We will use this to service your order and for compliance to ensure we can provide proof of enquiry made.

The personal data we collect will be used for the following purposes:

• We will use your data to help us service your enquiry.
• We will use your data to help us manage any service you take out with us.
• If you opted in for marketing in the future regarding new products or services we offer we will only contact you on your preferred method with details of new products or news from MiddletonMurray’s such as a newsletter.

Our legal basis for processing for the personal data:

If you decided to enter into a business agreement with Limitless Group under the contract we will need to process your details to service your order.

We collect information about you so that we can:

• identify you and manage your account on our Website;
• liaise with your employer
• improve our services;
• promote our business and market our services;
• manage our business, including for accounting and auditing purposes;
• conduct our regular group reporting activities on the performance of our company, in the context of a business reorganisation or group restructure;
• maintain our IT systems and manage hosting of our data;
• deal with legal disputes involving  you, your employer, or our suppliers;
• prevent fraud; and
• comply with our regulatory obligations.

We will only use your personal information when the law allows us to, i.e. when it is necessary to:

• perform our contractual obligations towards you and/or your employer or, as set out in our End User terms and conditions and our contract with your employer.
• comply with our legal and regulatory obligations;
• pursue our legitimate interests (e.g. conducting our business in an efficient, compliant and profitable manner and the overall promotion of the business), and where your interests and fundamental rights do not override these interests. It may also become necessary to process your personal data for a legitimate interest of a third party, such as your employer or the Rewards Partner. We will also rely on our legitimate interests for the proper administration of our Website, and to manage our operations (for example, maintaining appropriate records and databases).

If you have provided us with your individual contact details (for example, your personal email address), we will rely on your consent to send you electronic communications such as our newsletters and emails with information about our products and/or services.  If we hold your business contact details (for example, your work email address), we will rely on legitimate interests of the business to send you electronic communications, but we will always provide you with an option to opt out from future communications of this kind. See the “Direct mailings” section below for more details.

Some of the above grounds and purposes for processing will overlap and there may be several grounds which justify our use of your personal information.

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Purposes of processing your personal information 

We will use the information we receive from you to:

1. communicate with you in response to a specific action performed by you on our Website, for example when you buy or redeem a benefit;
2. to provide you with support in using our Website;
3. to provide you, or enable selected third parties to provide you, with information about goods or services we or they offer. For more details see “Direct Mailings” section;
4. to notify you about changes to our services, our terms and conditions of use of the Website or this privacy policy; and
5. to ensure that content from our Website is presented in the most effective manner for you and for your computer and/or your mobile device.

We will use the information we collect about your use of our Website:

1. to administer our Website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
2. to improve our Website to ensure that content is presented in the most effective manner for you and for your computer and/or your mobile device;
3. to help us improve and personalise our services;
4. to allow you to participate in interactive features of our Website when you choose to do so;
5. as part of our efforts to keep our Website safe and secure;
6. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
7. to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.

We do not sell or share your personal data with third parties for them to use for marketing purposes.

We may allow our staff, consultants and/or external service providers acting on our behalf, and our provider of payment services, to access and use your personal data for the activities we have described above.  We only permit them to use it to deliver the relevant service, and if they apply an appropriate level of security protection.

When we wish to send you information about our services, and you do not currently use our services, we may collect your contact details, for example, your name, email address and job title.   This information may be provided directly by you, when you express interest in our website.

We use cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you use the Website and also allows us to improve our Website. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy (insert link to cookies policy)

Your rights

It is important that the personal information we hold about you is accurate and current. Please let your employer and/or us know if your personal information changes during your relationship with us as it is your duty to inform us of changes.

Under certain circumstances, by law, you have the right to:

1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it.
2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
3. Request erasure of your personal information (often referred to as “the right to be forgotten”). This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
4. Object to processing of your personal information 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.
5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.
6. Request the transfer of your personal information to another party.

If you would like to exercise any of the above rights, please:

• email, call or write to us (see our contact details below);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill). This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and
• let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.

Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services and we may need to deactivate your account on our Website.

You also have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at: contact@angelamiddleton.com. You can also contact the Information Commissioner’s Office on 0303 123 1113.

For more details about your rights under the Act, the rules we have to adhere to in collecting and storing your information, and how you can check your data records, please visit https://www.gov.uk/data-protection  

You can always unsubscribe from our email communications at any time by following the unsubscribe link in our email communications, or by updating your email preferences on your profile on our Website.

Security of Data

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us (see our contact details below).

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Retention and Disposal of Data

Limitless Group discourages the retention of personal data for longer than they are required. Considerable amounts of data are collected on current staff and learners. However, once a member of staff or learner has left the institution, it will not be necessary to retain all the information held on them. Some data will be kept for longer periods than others.

Learner data is collected by Limitless Group in accordance with the terms and conditions of funding imposed by the ESFA (Education & Skills Funding Agency). The data collected from learners is processed by Limitless Group, as explained in the Privacy Notice issued by providers to each learner.

The data is primarily used by the ESFA and the DfE to perform statutory functions on behalf of the Secretary of State as set out in the Apprenticeships, Skills, Children and Learning Act 2009 and for the exercise of functions of the Crown, a Minister of the Crown or that government department.

Information provided by learners may be shared with other organisations for purposes of administration, the provision of career and other guidance and statistical and research purposes, relating to education, training, employment and well-being. Other organisations include the Department for Works and Pensions, Local and Combined Authorities in England, the Greater London Authority, the Higher Education Statistics Agency, the Higher Education Funding Council for England, educational institutions and organisations performing research and 3 of 5 statistical work on behalf of the Department for Education, or partners of those organisations.

The learner data processed by the ESFA is known as the Individualised Learner Record (ILR). The specification and standards for the ILR are published for each academic year (1 August – 31 July) by the ESFA.

Learner data is also collected and supplied to the Learning Records Service, a part of the ESFA. This personal data is used by the ESFA to issue learners with a Unique Learner Number (ULN), and to create and maintain the Personal Learning Record. Information held in the Personal Learning Record is shared with third parties such as providers of learning.

Further details of how this personal data is processed for these purposes are published for the Learning Records Service.

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer our customer, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

Disclosures of your Data

We will share your personal information with the following third parties:

• our agents and service providers;
• your employer or the relevant apprenticeship provider;
• our regulators, including the Financial Conduct Authority;
• law enforcement agencies in connection with any investigation to help prevent unlawful activity; and
• in the context of the possible sale or restructuring of our business.

We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We also reserve the right to disclose the information collected about you to our professional advisors and/or if we, in good faith, believe it necessary to protect the personal safety of users or the public.

These parties are not allowed to use any personally identifiable information except for the purpose of providing these services. We may also use such aggregated information and statistics for monitoring the Website usage in order to help us develop the Website and our services and may provide such aggregate anonymous information to third parties.

Direct mailings

We may occasionally send out newsletters, offers or alerts to our members and to other business contacts. We may also wish to provide you with information about special features of our Website or any other service or products we think may be of interest to you.

Where required by the Data Protection Laws (for example, if you have provided your personal contact information) we will send you such information only if you have specifically elected to receive it. You can opt-out from receiving such communications at any time.

Limitless Group Cookies Policy

Limitless Group uses cookies on our sites www.angelamiddleton.com (our site, or our sites) for a number of purposes. They help us to provide you with a good experience when you browse our website, and also allow us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies.

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of the e-billing services.

• Analytical/performance cookies.

They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.

• Functionality cookies.

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies.

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them below.

First-party Limitless Group cookies

This website will set some cookies that are essential for the website to operate correctly. These cookies, none of which capture personally identifiable information, are as follows:

• Visitor ID – this cookie is a numeric value that identifies unique visitors and provides coherence and consistency to a site visit;
• Page Number – this cookie identifies the page you are on;
• Session ID – this cookie identifies your website session;
• Test – this cookie checks whether or not your browser supports cookies;
• Order – this cookie ensures that your shopping basket works correctly.

Third-party cookies

Our websites will set several types of third-party cookie, and we do not control the operation of any of them. The third-party cookies which may be set include:

• Google Analytics – we use Google Analytics to collect data about website usage. This data does not include personally identifiable information. You can view the Google Privacy Policy here: google.com/policies/privacy
• Google Remarketing – we use Google’s Remarketing cookie to market products and services we think may be of interest to you. You may see our adverts on Google’s Display Advertising Network of partner websites and Google’s own search results pages. We aim to carefully select the products and services we remarket to you, and do so based on the pages you have visited on our website. To opt out of Google Remarketing, set your Google Ad Settings.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.