This privacy notice explains how we use any personal data we collect about you when you use this website or enquire about any of our services via another method, such as telephone, email or in person.

Data Controller and contact details

Spirit Studios is the trading name of Spirit SSR Ltd. Spirit SSR Ltd is the data controller of any personal data collected from an enquiry or by this website. Please use the following contact details if you have any questions about our privacy notice or the personal data we hold about you:

• By email: dpo@spiritstudios.ac.uk
• Or write to us at: Data Protection Officer, Spirit SSR Ltd, 65-69 Downing Street, Manchester, M1 7JE, UK

If you wish to opt-out of all marketing, please click here or email opt-out@spiritstudios.ac.uk

What personal data do we collect about you?

Personal data refers to any data which relates to or identifies you as an individual. We collect personal data about you when you make an enquiry, register for an event, make an online application for one of our courses or subscribe to our E-Newsletter from our website. We only collect the personal data necessary to provide the services that you request.

Our website server logs limited information about visitors to our website, such as date/time of visit, IP address, browser and operating system.

We use technologies, such as cookies, to personalise content and advertising, to provide social media features and to analyse traffic to the site. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.

When visiting our site, you have the choice to opt-in and allow the use of these cookies or opt-out and reject them. You can change your choice at any time. Please note that certain features of our website will only function if you opt-in to using cookies, such as embedded audio and video players.

It is possible to adjust your browser or device controls to block cookies or limit ad tracking. It is also possible to browse websites, including our website, anonymously. Please consult the documentation of your web browser and/or device for more information. The cookies used on our site are:

Functional:

  • Functional cookies are necessary for the operation of our website.  Such cookies keep track of which cookies you have opted-in to use whilst using our website.

Analytical:

  • Google Analytics is a service offered by Google that tracks and reports website traffic. Google’s Google Analytics privacy notice can be viewed here.
  • Hotjar combines analysis and feedback tools to give us a picture of how to improve our website’s user experience and performance. Hotjar’s privacy notice can be viewed here.

Social Media:

  • Facebook Pixel is an analytics tool that allows us to measure the effectiveness of our Facebook advertising by understanding the actions users take on our website. It allows us to ensure adverts are being shown to the right people and build advertising audiences. Facebook’s privacy notice can be viewed here.
  • Twitter Conversion Tracking allows us track the actions users take after viewing or engaging with our adverts on Twitter. Twitter’s privacy notice can be viewed here.

Advertising:

  • No cookies are currently used for advertising purposes.

Other:

  • No cookies are currently used for other purposes.

How will we use your personal data?

We collect personal data about you to contact you regarding your enquiry. If you register for an event, we’ll create an attendance register contact you close to the event with a reminder. If you agree, we will also send you information and updates on news, courses and events, as well as any special offers and marketing content we feel will be of interest to you. This can be by phone, SMS, email and post. Our lawful basis for such processing is by consent. Consent means you have given clear consent for us to process your personal data for a specific purpose. You have the right to withdraw consent for such processing.

Details from an online application are used to secure you a place on the course. We will contact you regarding the course start date and time, and induction information, if applicable. If a payment was made with the application, an account will be made for you in our accounts software. The lawful basis for processing online applications is by contract. This is because the processing of your personal data is necessary to assess your application with a view to creating a contractual relationship with you in the future (i.e. enrolling you on a course as a student). In processing an online application, we may send data to, and use information from, fraud prevention agencies.

Our website server logs personal data about you purely for technical purposes, such as troubleshooting and ascertaining performance of our systems. The lawful basis for this processing is by legitimate interests. The processing is for a legitimate purpose, is necessary and has been balanced against your interests, rights and freedoms.

The information logged during your visit to our website by cookies is used to learn about our visitors as a group, not about you as an individual. This information helps us identify overall usage patterns and trends. The lawful basis for such processing is by consent. Consent means you have given clear consent for us to process your personal data. You have the right to withdraw consent for such processing.

Details of transfers to a third country and safeguards

Base CRM
Spirit SSR Ltd utilises Future Simple Inc.’s Base (https://getbase.com) as its customer relationship management (CRM) service. When we collect information about you, it is transferred to Future Simple Inc.’s systems in the U.S. Future Simple Inc. participate in and has certified its compliance with the EU – U.S Privacy Shield Framework and the Swiss – U.S Privacy Shield Framework. Future Simple Inc. is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland to the Framework’s applicable Principles. To learn more about the Privacy Shield Network, please visit https://www.privacyshield.gov.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Future Simple Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Future Simple Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Mailchimp
Spirit utilises Mailchimp to send emails to website users and enquiriers. Such emails could be information and updates on news, courses and events, as well as any special offers and marketing content we feel will be of interest. Information stored in Mailchimp is limited to First Name, Last Name, Email Address, Phone Number and an identifier, such as a specific event they attended or course they applied for. MailChimp has certified its compliance with the EU-U.S and Swiss-U.S Privacy Shield frameworks. Mailchimp’s privacy notice can be viewed here: https://mailchimp.com/legal/privacy/

How long do we keep your personal data?

All personal data collected about you when you make an enquiry, register for an event or agree to any marketing will be processed indefinitely or until we receive notification that you wish us to erase your data. Personal data collected when subscribing to our E-Newsletter will be processed until you unsubscribe from the service or we receive notification that you wish us to erase your data.

Personal data collected when you make an online application for one of our courses will be kept indefinitely. If your application is unsuccessful or you decide not to study with us for any reason, you may request we erase your personal data. If you enrol on one of our courses, some information collected may need to be processed throughout your studies and cannot be erased.

Personal data logged by our website server will be stored for 30 days.

Personal data logged from your visits to our website by cookies will be stored for 38 months.

Your rights

Right to be informed – This privacy notice outlines how we process your personal data.

Right of access – You have the right to obtain confirmation that your personal data is being processed by us, as well as request a copy of the personal data we have on you. We may make a small charge for requests that are considered unfounded or excessive.

Right to rectification – We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

Right to erasure – You can request that the deletion or removal of personal data where there is no compelling reason for its continued processing.

Right to restrict processing – You have the right to block the processing of personal data under certain circumstances. This would allow us to continue to store your personal data but not further process it.

Right to data portability – You have the right to obtain and reuse the personal data we store on you for your own purposes across different services.

Right to object – You have the right to object to us processing your personal data for direct marketing and we will stop such processing when receive an objection from you.  You also have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority. You must have an objection on grounds relating to your particular situation. We will stop such processing unless we can demonstrate legitimate grounds for the processing, or that the processing is for the establishment, exercise or defence of legal claims.

Rights related to automated decision making – We do not process any of your personal data with any wholly automated decision-making systems, nor do we carry out any profiling.

Children’s personal data

Consent needs to be obtained from a parent or guardian to process the personal data of a child aged 16 or under for any information society service or for the purposes of marketing.

Changes to our privacy notice

We keep our privacy notice under regular review and we will place any updates on this webpage. This privacy notice was last updated in November 2018.

Supervisory Authority

If you believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO): https://ico.org.uk