Privacy policy
Last updated: 7th March 2024
Treehouse Innovation Ltd operates
https://dtassessment.treehouseinnovation.com/,
https://dtassessment.treehouseinnovation.com/org/,
https://dtassessment.treehouseinnovation.com/pbv
(the “Sites”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Sites.
We use your Personal Information only for providing and improving the Sites. We do not distribute, sell or share with any 3rd party any personally identifiable information we hold about you. By using the Sites, you agree to the collection and use of information in accordance with this policy.
Information Collection And Use
The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
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, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account 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, device ID and other technology on the devices you use to access the Sites.
- 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 interact with and use the Sites, 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 which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our websites to help improve the Sites and our service offering.
We do not knowingly collect data relating to children.
How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of 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.
| Purpose/Use | Type of data | Legal basis |
|---|---|---|
| To register you as a new customer | (a) Identity (b)Contact |
Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(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 notice (b) Dealing with your requests, complaints and queries |
(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 manage our relationship with you |
| To administer and protect our business and the Sites (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 online 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 the Sites, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Sites updated and relevant, to develop our business and to inform our marketing strategy) |
| To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Consent, having obtained your prior consent to receiving direct marketing communications |
| To carry out market research through your voluntary participation in surveys | Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). |
Marketing
We use Brevo as our marketing platform. If you choose to subscribe to our newsletter, you acknowledge that your information will be transferred to Brevo for processing. Learn more about Brevo’s privacy practices here.
Opting Out
You have the right, at any time, to ask us to remove all personally identifiable information that we hold about you on the system. If you do this, we will remove your user account and associated personal data, but be aware that this information is required to access the system, so removing it will prevent you from accessing any data or services provided.
You also have the right, at any time, to opt in or out of marketing emails using the 'Unsubscribe' link at the bottom of each email – unsubscribing from marketing emails will not affect in any way your access to the Sites;
Log Data
Like many site operators, we collect information that your browser sends whenever you visit our Sites.
Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Sites that you visit, the time and date of your visit, the time spent on those pages and other statistics.
In addition, we use the following third party services to collect, monitor and analyze this data in order to assist us to identify application issues:
- Google Analytics
- Brevo
Support & Guidance
We use Zendesk to provide email support and in-app guidance functionality. We do not store, use or share any personal information with these providers (other than your name and email address if you explicitly chose to submit a support ticket).
Cookies
Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.
Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Sites.
Disclosures of your personal data
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
External Third Parties as set out below
| Name of Subcontractor | Address | Services provided |
|---|---|---|
| Google G Suite - https://www.dataprivacyframework.gov/participant/5780 | USA, EU | Google products, email, Docs, Analytics, etc |
| DigitalOcean - EU Adequacy regulation from October 2023 | EU, UK | Data centre |
| Zendesk Inc. - https://www.dataprivacyframework.gov/participant/5304 | USA | Help desk support (Ticketing) |
| HubSpot Inc. - https://www.dataprivacyframework.gov/participant/5812 | USA, EU | Customer CRM |
| Stripe, Inc. - https://www.dataprivacyframework.gov/participant/6436 | EU, USA | Payment portal |
| PayPal UK Ltd - EU adequacy regulation from October 2023 | UK | Payment portal |
| Brevo - EU adequacy regulation from October 2023 | EU | Email marketing |
Third parties to whom we may choose to 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 notice.
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.
International transfers
Whenever we transfer your personal data out of the UK to countries whose laws do not provide the same level of data protection as the UK, we always use appropriate safeguards to ensure that your data is protected. In particular, we use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact us using our contact details below.
Data security
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.
Data Retention
We guarantee to retain your Assessment data for at least one year after the completion of your subscription. In the case where multiple people are subscribed, the retention period will be based on the subscription date for the owning account.
After one year of inactivity, we reserve the right to remove your Assessment data from the system. If we receive an authorized request to remove Assessment data at any point either during or after the retention period has elapsed, we will remove all the data requested.
Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "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 in certain circumstances. 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 where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing’ in 4 for details of how to object to receiving direct marketing communications).
- 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 (see the table in section 4 for details of when we do so). 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.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data's accuracy;
- 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; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us using our contact details below.
Changes To This Privacy Policy
This Privacy Policy is effective as of 7th March 2024 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.
If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.
Contact Us
If you have any questions about this Privacy Policy, please contact us.