Teavaro Limited (and by extension its subsidiaries, Teavaro GmbH and
Teavaro Spain) (“We” or “Teavaro”) aims to maintain
the security of your Personal Data at all times, and we are committed to
respecting your privacy rights. We pledge to handle
your Personal Data fairly and legally at all times, as well as
transparent about what data we collect about you and how we use it.
This policy, which applies to your
use of our website and elearning facility (or “Teavaro
academy”), provides you with information about:
•
what Personal Data we
collect and why;
•
how we use your
Personal Data;
•
how your Personal
Data is stored and shared;
•
your legal rights
relating to your Personal Data; and
•
other useful privacy
and security related matters.
As a European company, the European
Union’s General Data Protection Regulation (the “GDPR”) provides the framework
with which we approach data processing and data use, and while only legally
applicable to European citizens, we apply the same high standards to all our
website users and their Personal Data.
As part of the requirements of
GDPR, we provide a Data Protection Officer (“DPO”). The DPO is directly contactable for any query or
matter relating to the use of your Personal Data. The details of our DPO are:
Name: Robert Bergmann
Contact (email): privacy@teavaro.com
Contact (post): Data Protection
Officer, Teavaro Limited, 13 The Causeway, Teddington TW11 0JR, United Kingdom
Of course, you may have noticed
that our DPO is our CEO, so we would suggest you copy any email contact to our
Customer Support Team at support@teavaro.com also, as this may
provide you with a quicker response.
You also have the right to lodge a
complaint with the Information Commissioner’s Office. Further information,
including contact details, is available at https://ico.org.uk.
We collect Personal Data about you
when you provide such information directly to us, or when Personal Data about
you is automatically collected in connection with your use of our Services, including without limitation the following:
· First and last name
· Contact Information (email address, telephone number)
· Employment History (company name, position)
· Any Other Information you choose to share publicly on
the Services, for example, anything you post as a comment or part of a form
submission.
We collect this information
directly from you when you submit this information as part of our website
functionality, including Teavaro academy registration, online chat, contact
forms, download forms and blog comments.
Some Personal Data is automatically
collected when you use our website, such as the following:
· IP address
· Device identifiers
· Behavioural data – your activity on the website
· Web browser information
· Cookies and other tracking technologies (For more
information, please review the “Cookie Policy” section below).
· Location information (e.g. IP
address)
· Log data (e.g. access
times, hardware and software information)
In order for us to provide you with our services or for
correspondence purposes we need to collect your personal data. We ensure that the information we collect
and use is confined to this purpose. We always process your personal data for
specific purposes, with the nature of the data collected depending on your
interaction with us. We are committed to transparency in this.
Our legal bases for controlling or
processing personal data are:
• Article 6.1(a) GDPR (Consent): You provide informed
consent to us or have a reasonable expectation that we will use your
information in a certain way – for example, to engage in our elearning platform, Teavaro academy, or to hear about new
services or offers. You can withdraw your consent at any time by request to privacy@teavaro.com;
• Article 6.1(b) GDPR (Contract): Providing our services
and fulfilling our obligations to you, usually relating to a terms
of service or partnership agreement;
• Article 6.1(c) GDPR (Legal Obligation): The necessity to
meet compliance with our legal obligations; and/or
• Article 6.1(f) GDPR (Legitimate Interest): Where it is
in our legitimate interests to do so.
We only rely on ‘legitimate
interests’ as the legal basis for processing by us, or third parties we use,
for these purposes:
• recruitment and induction of new employees, contractors
and other people who work with us;
• emergency contacts for people who work with us, such as
employees and contractors for health and safety purposes;
• business development; or
• providing login systems to users via their existing
social media accounts.
Where we rely on a specific basis
for processing your information and you wish to object to that processing, you
must be aware that it might not be possible for you to continue using our
services.
Teavaro
collects personal data from you when you interact with us. This can be through
our websites, over the phone, in person, including, without limitation, when
you:
• create an individual or
corporate user account;
• request support;
• register for or participate in
an online class, exam, certification, training, webcast or other event;
• request information or
materials;
• participate in surveys or
evaluations;
• participate in promotions,
contests or giveaways;
• apply for employment;
• submit questions or comments;
or
• submit content or posts on our
forums or other interactive webpages.
We process Personal Data to
operate, improve, understand and personalise our
Services.
We also use Personal Data provided
as part of a contact form to provide relevant information and communication as
part of a user-initiated request, for either contact with our business
services, or to register for our elearning services.
We may need to pass your personal
data on to third-party service providers contracted to Teavaro in the course of dealing with you. We do this because there
are services which will not work unless we are able to make these transfers.
Any third parties we share your data with are obliged to keep your personal
data secure and use it only for necessary service delivery. When your data is
no longer required to fulfil the service, those third parties will be directed
to dispose of your data in accordance with our standard procedures.
We seek to enter into Data
Processing Agreements with our third party service
providers to ensure they only process your data as instructed by us. If you
obtain products or services directly from us on behalf of others
we will ensure you enter into a Data Processing Agreement (DPA) with us.
We share Personal Data with
vendors, third party service providers and agents who work on our behalf and
provide us with services related to the purposes described in this Privacy
Policy or our Terms of Service. These parties include:
·
Analytics service
providers
·
Engineering and
development tools
·
Our elearning partner, The CDP Institute
For the
majority of these events, you are informed of the sharing event
and/or have direct control over the sharing of your personal data, either via a
consent tick box or cookie controls.
Teavaro is committed to keeping
your personal data safe and secure. We seek to protect Personal Data using
appropriate technical and organisational measures based on the type of Personal
Data and applicable processing activity.
We will process (collect, store and
use) the information you provide in a manner compatible with GDPR. We maintain
physical, organisational and technical safeguards for
all personal data we hold. We will endeavour to keep your information accurate
and up to date, and not keep it for longer than is necessary. We are required
to retain certain information in accordance with the law, such as information
needed for income tax and audit purposes. How long certain kinds of personal
data should be kept are governed by specific business sector requirements and
agreed practices. Personal data can be held in addition to these periods
depending on individual business needs.
We will process different forms of
personal data for as long as it is necessary and proportionate for the purpose
for which it has been supplied and we will store the personal data for the
shortest amount of time possible, taking into account
legal and service requirements.
You have certain rights with
respect to your Personal Data, including those set forth below. For more
information about these rights, or to submit a request, please email
privacy@teavaro.com. Please note that in some circumstances, we may not be able
to fully comply with your request, such as if it is frivolous or extremely
impractical, if it jeopardises the rights of others, or if it is not required
by law, but in those circumstances, we will still respond to notify you of such
a decision. In some cases, we may also need to you to provide us with
additional information, which may include Personal Data, if necessary to verify
your identity and the nature of your request.
Access: You can request more information about the
Personal Data we hold about you and request a copy of such Personal Data. You
can also access certain of your Personal Data by emailing privacy@teavaro.com.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or
incomplete, you can request that we correct or supplement such data. You can
also correct some of this information directly by making changes to your
Profile. You can request that we correct or supplement such data by emailing
privacy@teavaro.com.
Erasure: You can request that we erase some or all of your Personal Data from our systems by emailing
privacy@teavaro.com.
Withdrawal of Consent: If we are processing your Personal Data based on
your consent (as indicated at the time of collection of such data), you have
the right to withdraw your consent at any time. Please note, however, that if
you exercise this right, you may have to then provide express consent on a
case-by-case basis for the use or disclosure of certain of your Personal Data,
if such use or disclosure is necessary to enable you to utilise some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a
machine-readable format. You can also request that we transmit the data to
another controller where technically feasible.
Objection: You can contact us to let us know that you object
to the further use or disclosure of your Personal Data for certain purposes,
such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of
your Personal Data.
Right to File Complaint: You have the right to lodge a complaint
about Teavaro’s practices with respect to your Personal Data with the
supervisory authority of your country or EU Member State.
Like most websites, Teavaro’s website
use cookies to collect information. Cookies are tiny data files which are
placed on your computer or other devices (such as smart ‘phones or ‘tablets’)
as you browse this website. They are used to ‘remember’ when your
computer or device accesses our websites. Cookies are essential for the
effective operation of our website.
Below we describe what information
they gather, how we use it and why we sometimes need to store these cookies. We
will also share how you can prevent these cookies from being stored however
this may downgrade or ‘break’ certain elements of the sites functionality.
For more general information on
cookies see the Wikipedia article on HTTP Cookies.
We use cookies for a variety of
reasons detailed below (in “The Cookies We Set”). For example, when you submit
data to us through a form, such as those found on contact pages or comment
forms, cookies may be set to remember your user details for future correspondence. Unfortunately in most cases there are no industry
standard options for disabling cookies without completely disabling the
functionality and features they add to this site. It is recommended that you
leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.
Some cookies collect information
about browsing behaviour when you access this website via the same computer or
device. This includes information about pages viewed and your journey
around a website, and includes personal
information including IP address (pseudonymised) and location data. We do
not use cookies to collect or record information on your name, address or other contact details in any database, but if you
provide this information within some of our third-party services (social media
functionality, online chat), the service provider may collect this information
directly based on that interaction. Unless you agree to it directly with that
service provider, they will not use your personal data for any other purpose
than the function they perform on our website.
We set a limited number of cookies
to ensure that our website is functional and to optimise your user experience.
These are:
Essential Cookies
These cookies are core to the
functionality of the site. Many of these cookies reference our website hosting
platform WordPress but contain no personal data, as our website is available to
all visitors without need for a login.
Third Party Cookies
In some special cases we also use
cookies provided by trusted third parties. The following section details which
third party cookies you might encounter through this site.
Functionality Cookies
Third-party providers of certain
capabilities may require cookies to provide that functionality. At present, the
following providers are allowed cookies on the Teavaro website:
|
Provider |
Function |
Description |
|
Zopim |
Live Online Chat (Zendesk) |
Uses personal data including name and email to provide
customer support services |
|
Facebook |
Social Media Graph |
Uses personal data as data controller to provide social
media sharing |
Web Analytics Cookies
Third party analytics are used to
track and measure usage of this site so that we can continue to produce
engaging content. These cookies may track things such as how long you spend on
the site or pages you visit which helps us to understand how we can improve the
site for you:
|
Provider |
Function |
Description |
|
Google Analytics (Google Tag Manager) |
Analytics |
One of the most widespread and trusted analytics solution on
the web; helps us to understand how you use the site and ways that we can
improve your experience |
|
Hubspot |
Analytics, CRM & Tracking |
Another analytics tool to analyse user journeys and optimise
our website |
Marketing / Advertising Cookies
At present, we DO NOT USE cookies
for marketing / advertising purposes and we
will NOT share your data with companies who provide these services. This
section and our cookie management tool will be updated in
the event that this situation changes.
Other Cookies
From time to time, we test new
features and make subtle changes to the way that the site is delivered. When we
are still testing new features, cookies may be used to ensure that you receive
a consistent experience whilst on the site whilst ensuring we understand which
optimisations our users appreciate the most. Once we are sure that the feature
and any relevant cookie are a permanent inclusion, we will update our cookie
policy to reflect the changes.
Teavaro provides means by which to
select your cookie preferences upon first entry to our website (via banner
message) and means to update these preferences at any other time (via the icon
on the bottom left of the browser window).
Within this application, you will
find a clear explanation of the cookie types you are enabling or disabling and
the impact of that action.
This depends on which cookies you
disable, but in general the website may not operate properly if cookies are
switched off. We advise that all cookies are enabled to ensure you get the best
possible experience – you can always delete them afterwards.
If you are unsatisfied with the
cookie management provided on our website and you want to disable cookies, you
need to change your website browser settings to reject cookies. How you
can do this will depend on the browser you use. Further details on
how to disable cookies for the most popular browsers are set out below:
For Microsoft Internet Explorer:
1. Choose the menu “tools” then “Internet Options”
2. Click on the “privacy” tab
3. Select the setting the appropriate setting
For Google Chrome:
1. Choose Settings> Advanced
2. Under “Privacy and security,” click “Content settings”.
3. Click “Cookies”
For Safari:
1. Choose Preferences > Privacy
2. Click on “Remove all Website Data”
For Mozilla Firefox:
1. Choose the menu “tools” then “Options”
2. Click on the icon “privacy”
3. Find the menu “cookie” and select the relevant options
For Opera:
1. Choose the menu Files”> “Preferences”
2. Find “Privacy”
If you require further information on this, or how to clear your browser
cookies, please consult the browser help guides themselves.
Hopefully that has clarified things
for you and as was previously mentioned if there is something that you aren’t
sure whether you need or not it’s usually safer to leave cookies enabled in
case it does interact with one of the features you use on our site. However if you are still looking for more
information then you can contact us through
one of our preferred contact methods.
Contact: privacy@teavaro.com
Last updated: September 2022