PRIVACY POLICY


1 Company Address and Registration Details

La Mente PensanteTM is a brand of TheThinkingMind™ Coaching Ltd.

Company number: 10436953
Registered office
2nd Floor Hanover House
30 Charlotte Street
Manchester M1 4EX
United Kingdom


2 Disclaimer

2.1 Liability for Content
We make every effort to keep the information on our website current but accept no liability whatsoever for the content provided. The law limits our responsibility as a service provider to our own content on these webpages.

We are not obligated to monitor third-party information provided or stored on our website. However, we shall promptly remove any content upon becoming aware that it violates the law. Our liability in such an instance shall commence at the time we become aware of the respective violation.

2.2 Liability for Links
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide while visiting such sites and such sites are not governed by this privacy statement. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. You should exercise caution and look at the privacy statement applicable to the website in question.

At the time any third-party websites were linked to, we found no grounds whatsoever of any likely contravention of the law. We shall promptly delete such links upon becoming aware that any of them violate the law.

2.3 Copyrights
The content and works provided on these Web pages are governed by the copyright laws of the United Kingdom. Duplication, processing, distribution, or any form of commercialization of such material beyond the scope of the copyright law shall require the prior written consent of its respective author or creator.


3 Data Protection and Privacy Policy
Our core beliefs regarding user privacy and data protection:

  • User privacy and data protection are human rights.
  • La Mente Pensante has a duty of care to the people within our data.
  • Data is a liability, it should only be collected and processed when necessary.
  • La Mente Pensante will never sell, rent or otherwise distribute or make public your personal information outside our Network.
  • La Mente Pensante Coaching & Mentoring takes its security obligations seriously in respect of your personal data under the EU General Data Protection Regulation (GDPR).

By contacting us through our contact forms and white paper requesting forms on our websites, through a 3rd party website that forwards your information upon your request to us, or through any other form through which your personal information is provided to us, or by visiting our website, you are agreeing to this policy and the procedures stated within.

Your data is accessible only by approved staff members within the La Mente Pensante Network and contracted 3rd party service providers as stated in section 3.5.2.

If you are under 16 years of age you must obtain parental consent before contacting us.

3.1 Relevant Legislation
This website is designed to comply with the following national and international legislation with regards to data protection and user privacy:

This site’s compliance with the above legislation means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact us (details can be found in section 3.10) for clarification.

3.2 Personal information that this website collects and what we do with it
Again, we take your privacy very seriously and are committed to keeping your information safe and secure. We do not sell, license, lease or otherwise disclose your personal information to any third party outside the La Mente Pensante Network for any reason except as noted earlier and as described below:

  • Information may be shared with contracted 3rd parties who assist in providing support for our internal operations.
  • Information that you give us and information about your participation in the Site(s) and our Service may be combined with other personally identifiable information (such as demographic information and past purchase history) available from our records and other sources. This information will be used to make our future marketing efforts more efficient.
  • From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy policy. If our information practices materially change at some time in the future, we will post the policy changes to the Site(s), will note this in section 4 and if requested we will provide you with a copy of the revised privacy policy at the primary email address you provide to us.
  • The information we collect may be disclosed when we are legally required to do so, at the request of governmental authorities conducting an investigation, to verify or enforce compliance with the policies governing our website and applicable laws, or to protect against misuse or unauthorized use of our website.

You have the right to access your data, the right for data portability and the “right to be forgotten”. More details on this can be found in section 3.8. If you would like to request any of this, please contact us via the email stated in section 3.10.

Our databases are being reviewed regularly and private data that is not relevant to us any more will be deleted by us.

3.3 Visiting the website and contacting us

3.3.1 Site visitation tracking and cookies
Necessary, Marketing and Google Analytics Cookies
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you, but Google does not grant us access to this. We consider Google to be a 3rd party data processor (see section 3.6.1 below).

GA makes use of cookies, details of which can be found on Google’s developer guides. FYI our website uses the analytics.js implementation of GA.

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website. The website does not track unless you have explicitly agreed to it.

A summary of all the necessary cookies can be found in 3.3.7.

WPML
We might use a WPML cookie on our website to determine your configured browser language to deliver a better website experience in your preferred language.

3.3.2 Google Adwords Remarketing
At La Mente Pensante, our website makes use of a variety of advertising technologies including Google AdWords Remarketing.

This technology is used to trigger tailored advertising across the internet to individuals who have shown interest in our business and visited our website. Google Adwords Remarketing functions by serving relevant ads that are tailored to you based upon the specific pages you have visited whilst on the ERA website, by placing a cookie onto your computer or device.

This cookie will not give us any type of access or control of your computer or device, nor will it provide us with any personally identifiable information.

These cookies are used by Google Adwords Remarketing to tag an individual who has visited a specific page on our website and to display ads on third-party websites (including Google) related to that page, the purpose being to help us deliver a tailored experience and related marketing materials to more accurately fit your needs, essentially ensuring you only see ads that are relevant to you.

These ads can appear in places such as Google search results, or a site that’s part of the Google Display Network. Any data collected will be done so in line with our own privacy policy.

If you do not want to have a tailored experience and would prefer not to receive these ads from us, you can opt-out. In order to opt-out, you will need to visit Google’s Ads Preferences Manager here. You can also choose to opt-out of any third party use of cookies here.

3.3.3 Enquiries through the website or to an individual within the ERA Network
Should you choose to contact us using the contact form or by requesting for white papers or any collaterals to be sent to you, or by sending an email directly to one of our employees’ emails that are stated on the website, none of the data that you supply will be stored by this website or passed to / be processed by any of the third-party data processors defined in section 3.6.1.

Instead, the data will be collated into an email and sent over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.

If you reach out to us, your information may be stored on one of our 3rd party CRM platforms as stated in section 3.6.2 and/or may be forwarded via email within our La Mente Pensante Network to the relevant person to answer your query.

Your information may also be passed to other 3rd party data processors who provide the La Mente Pensante Network with necessary operational services (e.g. to send information about our service in form of a newsletter to you).

However, we never give or sell your data to anyone outside the La Mente Pensante Network or pass it to any unauthorized 3rd party that is not contracted by us or does not adhere to the data protection laws stated within this policy.

3.3.4 Email newsletter
If you contact us, you consent to receive specific marketing emails from us that fit to your enquiry. The email address and information that you submit to us will be forwarded to contracted 3rd parties, who provide us with marketing and software services.

You can opt-out of receiving automated emails from us by clicking on “unsubscribe” on the bottom of one of the emails.

We consider these providers to be 3rd party data processors (see section 3.6 below). The email address and further information that you submit will not be stored within this website’s own database.

Your data will remain within these parties’ database for as long as we continue to use their services or until you specifically request removal. You can do this by requesting removal via email. When requesting removal via email, please send your email to the person who contacted you and using the email account that you have contacted us through.

3.3.5 LinkedIn Conversion Tracking and Insight Tag
The La Mente Pensante website makes use of the LinkedIn Conversion Tracking tool and Insight Tag. These tools are part of an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this website. These features track visitor data through the use of cookies by collecting data regarding LinkedIn members’ visits to our website, including the URL, referrer, IP address, device and browser characteristics, timestamp, and page views.

This data is encrypted, then de-identified within seven days and the de-identified data is deleted within ninety (90) days. LinkedIn does not share the personal data with La Mente Pensante, it only provides aggregated reports about the website audience and ad performance. LinkedIn also provides retargeting for website visitors, enabling the website owner to show personalized ads off its website by using this data, but without identifying the member.

Simply put, none of the information gathered is personally identifiable and is used for the specific purpose of providing more personalised ad content.

LinkedIn members can control the use of their personal data for advertising purposes through their account settings.

3.3.6 Twitter Ads Conversion Tracking and Tailored Audiences (Twitter, Inc.)
The La Mente Pensante website utilises Twitter Ads Conversion Tracking in order to provide anonymised performance data analysis and to deliver personalised advertising to users who have shown interest in our website by visiting before.

Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this website.

None of the information gathered is personally identifiable and is used for the specific purpose of providing more personalised ad content.

The specific details of Twitter’s privacy policy and how you can control the data you share in relation to tracking and tailored advertising can be found here.

3.3.7 Summary of all necessary Cookies used on our website

Cookie Name Description
_cfduid Set by Cloudflare to redirect all insecure traffic to secure https and to teach Cloudflare if that user is a suspicious source or not. Expires after 30 days.
_icl_current_language Set by WPML to remember the user’s language selection. Removed when the browser closed.
_icl_current_language_admin_language Set by WPML to remember Admin’s language setting. Removed when the browser closed.
moove_gdpr_popup Set by the cookie banner to remember the user’s cookie preferences.
wp-settings-23 & wp-settings-time-23 WordPress functional cookies to set the user’s localization, customisation and set the timezone. Removed when the browser closed.

3.4 Our 3rd party data processors
The third parties mentioned in this section have been carefully chosen and all of them comply with the legislation set out in section 3.1. All of the third parties that are based in the USA are EU-U.S. Privacy Shield compliant.

3.4.1 Visiting our website
We use third parties to process personal data on our behalf when you visit our website.

3.4.2 Contacting us
When you submit your information in one of our contact forms your information might be stored and processed on a 3rd CRM.

On top of that, your information may be passed to a relevant person within the La Mente Pensante Network to answer your query and they may reach out to you via email or phone, or by trying to connect with you on a social media platform like LinkedIn.

Some of your information may also be stored with other contracted 3rd parties of the La Mente PensanteNetwork that provide operational services to us so that we are able to answer to your queries or to send you relevant information via a newsletter.

3.5 Data Breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our 3rd party data processors to any and all relevant persons and authorities within seventy-two (72) hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

3.6 Your right as a data subject
As a data subject (this can be a member of the La Mente Pensante whose data is held by us or any subject outside the La Mente Pensante) whose personal information is held by any member of the La Mente Pensante Network, you have certain rights.

If you wish to exercise any of these rights, please email antonio@thethinkingmind.org or use the information supplied you by La Mente Pensante.

In order to process your request, we will ask you to provide valid forms of identification for verification purposes.

Your rights are as follows:

3.6.1 The right to be informed
As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.

3.6.2 The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
a) The purposes of the processing
b) The categories of personal data concerned
c) The recipients to whom the personal data has been disclosed
d) The retention period or envisioned retention period for that personal data
e) When personal data has been collected from a third party, the source of the personal data
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.

3.6.3 The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

3.6.4 The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

3.6.5 The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
a) The accuracy of the personal data is contested
b) Processing of the personal data is unlawful
c) We no longer need the personal data for processing, but the personal data is required for part of a legal process
d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing

3.6.6 The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.

3.6.7 The right to object
You have the right to object to our processing of your data where
• Processing is based on legitimate interest;
• Processing is for the purpose of direct marketing;
• Processing is for the purposes of scientific or historic research;
• Processing involves automated decision-making and profiling.

3.7 Data Controller
The data controller of this website is:
TheThinkingMind™ Coaching LTD
Company number: 10436953
Registered office
2nd Floor Hanover House
30 Charlotte Street
Manchester M1 4EX
United Kingdom

3.8 Data Protection Officer & Contact
We are not a public authority and our core activities do not;

  • require large scale, regular and systematic monitoring of individuals (for example, online behavior tracking); or
  • consist of large scale processing of special categories of data or data relating to criminal convictions and offences,

and therefore, are not obligated to appoint a Data Protection Officer (DPO).

If you have questions about our data privacy or your personal data, you can contact us here:
antonio@thethinkingmind.org.


4 Changes to our Policies

This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes.

We will only reach out to you and inform you about changes to this privacy policy if the changes are significant.

Last Update 21th October 2020

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