1. About Us

www.essentic.com, together with the Point Positive and 1Self Assessments run through the website (collectively the “Site”) are owned and operated by ESSENTIC LIMITED, registered in England and Wales under company number 08634404 and with registered office at 4 Clayton Road, Buckinghamshire, HP14 3GA (“we”, “us”, “our”).

We are committed to protecting and respecting your privacy. This privacy policy (“Policy”) (together with our Terms of Use  and any other documents referred to) sets out how we process the Personal Data of each visitor and customer to our Site, where such Personal Data is provided to us through the Site or via email communication.

PLEASE READ THE FOLLOWING CAREFULLY TO UNDERSTAND OUR VIEWS AND PRACTICES REGARDING YOUR PERSONAL DATA AND HOW WE WILL TREAT IT.

Our data controller registration number is ZA015965.

By clicking on the log in box where indicated on the Site, submitting your Personal Data to us, and using our services you agree to the terms and practices described in this Policy.

If you have any questions about this Policy, please contact Essentic. We may amend this Policy at any time. Any changes we may make will be posted on this page, so please check back frequently.

2. What is Personal Data?

Personal data or PII means any information relating to a person who can be identified either directly or indirectly by that information; it may include name, address, email address, phone number, credit / debit card number, IP address, location data, purchase history (“Personal Data”).  

3. Information we may collect from you

We may collect and process the following information about you:

Information you provide to us - You may provide us with information by answering questions or filling in forms on our Site, by corresponding with us by e-mail or otherwise, when you “Contact us”, on making enquiries or requesting further services from us, when you report a problem with our Site, raise a query regarding the services provided by us, or when we ask you to complete surveys that we use for research purposes, although you do not have to respond to them. As a Participant you will also provide us with information on completing Self-assessments as part of our Point Positive or 1Self Assessments or adding Contributors or Feedbackers for the External Assessment part of our Point Positive or 1Self Assessments. As a Contributor or Feedbacker you will also provide us with information on completing the External Assessment for the Participant. The information you give us may include your first name, last name, e-mail address, relationship, preferred language and “stories” about the Participant in completing the “Assessments”.

Information we collect about you - When you visit the Site we may automatically collect information about your computer or device, including your IP address, information about your visit, your browsing history, and how you use the Site. This information may be combined with other information you provide to us, as described above.  We may collect this information for system administration, to collect aggregate information or otherwise in accordance with this Policy. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

Information we receive from other sources - We work closely with third parties (including, for example, business partners and educational establishments) and, if you are a Participant, have received certain information about you from them in order to start the Point Positive or 1Self processes. Such information includes but is not limited to your first name, last name and email address which were required to send you an email containing your username and password for you to access the relevant areas of our Site. Please note that we will always keep information received from such third parties strictly confidential and will not use it for any purpose other than to contact you in relation to the services on our Site.

4. Purposes for which we process Personal Data 

We will only process your Personal Data, in accordance with applicable law, for the following purposes:

• creating and maintaining your account, if you become a registered user with us;
• handling and fulfilling your requests where you request services from us, in order to provide you with information about the services offered on our Site and related information about the Point Positive and/or 1Self process you are involved in (including but not limited to prompt emails where you have not completed the Assessment within the required time period, as specified in your account);
• resolving any disputes, if you lawfully exercise your rights or if you wish to dispute any part of our service offering;
• ensuring the security of your account and our business, preventing or detecting fraud or abuses of our website, for example, by requesting verification information in order to reset your account password (if applicable);
• developing and improving our products and services, for example, by reviewing visits to the Site and its various subpages, demand for specific products and services and user comments;
• to administer our Site and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to improve our Site to ensure that content is presented in the most effective manner for you and your device;
• to notify you about changes to our services and to send you service emails relating to the activities you have asked us to undertake on your behalf;
• as part of our efforts to keep our Site safe and secure; and
• to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.

Your consent, as the “Data Subject”, to the processing as specified in this Policy is the primary legal ground for our processing of your Personal Data. However, there may be circumstances where we may also rely on other valid legal grounds for the processing of your Personal Data, such as:

• your request for content or services necessitating steps including processing of your Personal Data to be taken prior to entering into contract with you and any processing that is necessary for the performance of such contract;
• legitimate interests we pursue as a business, except where such interests are overridden by your interests and fundamental rights; and
• compliance with any legal obligation to which we are subject, such as, for example, the processing for the purposes of complying with applicable law.

 
5. Disclosure of your information

• As a Participant, we will only use the information you submit in your Self-assessment and the information your chosen Contributors or Feedbackers have submitted in the External Assessment to generate a report (“Report”). This Report can remain strictly confidential, for your use and information only, or, for Point Positive assessments, you can elect (when adding Contributors and within your account settings) to share the Reports within your Point Positive network of Contributors (or selected members thereof) (your Report will only be shared with the Contributors you select and the shared Report will only include content from Contributors who have agreed to have their contributions shared).
• As a Feedbacker, as part of 1Self, your contributions will only be made available to the Participant as part of their Report.
• As a Contributor, as part of Point Positive, you can elect (when submitting your contributions and within your Point Positive account settings) to share your contributions with the Participant and their other Contributors (your contributions will only be shared with the Contributors that the Participant also selects). 

There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure to:

• our subsidiaries, branches or associated offices;
• our outsourced service providers or suppliers to facilitate the provision of our services to you, for example, the disclosure to our data centre provider for the safe keeping of your Personal Data, webhosting provider through which your Personal Data may be collected, identity verification partners in order to verify your identity against public databases;
• our carefully selected third party suppliers who enable us to deliver the Reports to the Participants;
• analytics and search engine providers that assist us in the improvement and optimisation of the Site. Your Personal Data is generally shared in a form that does not directly identify you;
• third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
• another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor company;
• public authorities where we are required by law to do so;
• if required, in order to receive legal advice; and
• any other third party where you have provided your consent.

6. International transfer of Personal Data

We may transfer your Personal Data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. In particular, your Personal Data may be transferred throughout our group and to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means.  Please contact contact Essentic for a copy of the safeguards which we have put in place to protect your Personal Data and privacy rights in these circumstances.

7. Retention of Personal Data 

Your Personal Data will be retained until your last use of our services and normally for a period of 12 months thereafter, unless longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so. However, we will not retain beyond this period any of your Personal Data that is no longer required for the purposes set out in this Policy. The retention of your Personal Data will be subject to periodic review.

We may keep an anonymised form of your Personal Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

Please contact us at contact Essentic if you would further details about our data retention periods.

8. Data subject rights 

Data protection law provides Data Subjects with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, their Personal Data.  Data Subjects also have the right to lodge a complaint with the relevant data protection authority if they believe that their Personal Data is not being processed in accordance with applicable data protection law.

Right to make subject access request (SAR). Data Subjects may, where permitted by applicable law, request copies of their Personal Data.  If you would like to make a SAR, i.e. a request for copies of the Personal Data we hold about you, you may do so by writing to contact Essentic whose contact details are above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and a fee.

Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete Personal Data. 

Right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your Personal Data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your Personal Data is essential.

Right to object to processing, including automated processing and profiling. You may, as permitted by applicable law, request that we stop processing your Personal Data. In relation to automated processing and profiling, you may object to the processing and you will have the right to obtain human intervention.

Right to erasure. You may request that we erase your Personal Data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your Personal Data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.

Right to data portability. In certain circumstances, you may request that we provide your Personal Data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services. We will comply with such transfer as far as it is technically feasible. Please note that a transfer to another provider does not imply erasure of your Personal Data which may still be required for legitimate and lawful purposes.

Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your Personal Data. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.

9. Links

The Site may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates and other third parties. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites..

Last updated: 10 June 2018.