Above Difference (“Above Difference”, “us” or “we”) understand that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy describes how we handle and protect your personal data in connection with Above Difference’s business activities, like masterclasses and coaching, and client services, and on our website, applications, and communications that post a link to this Privacy Policy in our capacity as data controllers. Please see our Terms of Use for more information about our online terms and policies in general.

Information we collect

Above Difference collects personal data in the course of its business activities, including in connection with some client services. We also collect personal data on certain areas of the Site when you register to attend a Masterclass, through the Above Difference Programmes section, create a user profile, register for Above Difference newsletters and alerts, sign up for webinars and events, and/or participate in public user posting areas (such as bulletin boards, discussion forums and surveys). The personal data collected varies and may include information that you provide, such as your name, mailing address, e-mail address, telephone number, fax number, and background information.

We may also automatically collect information about the devices you use to interact with our Website. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Site. We may also automatically collect information about how you use the Site, such as what you have searched for and viewed on the Site. The information automatically collected may be associated with a unique identifier as well as with any other personal data you have provided.

Above Difference may also collect personal data about you from third parties, such as data brokers or aggregators, in the course of its business activities including in connection with some client services. This includes demographic, professional and other information that is publicly available online, including information you choose to make public through social media platforms and other public online forums. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities (e.g., analysis of recruiting practices across an industry, detecting fraud patterns in connection with financial transactions, online traffic). We will always seek to confirm that the third party has provided transparent information about its use of this data, including its disclosure to third parties like Above Difference, in compliance with applicable law.

Use of information

Above Difference uses your personal data to fulfil your requests for information, process your requests to participate in masterclasses and events, personalise content that you view or receive on the Website, evaluate and improve our services, distribute newsletters and alerts to you, analyse the Website performance and functioning, publish your comments, enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce Above Difference agreements, and accomplish other purposes you may initiate or request. In some situations, the collection of personal data may be required for the operation of the Site, or we may use it in the course of our business activities, including in connection with some client services, for example, to provide certain services or products such as our surveys reports. We may combine and/or analyse personal data to evaluate and offer content and services most relevant to you. We may keep any of your personal data on file and use it to contact you.

Above Difference and its service providers may use first and third party Cookies and Other Tracking Technologies, including web beacons, to manage our Website and our services and collect analytics about how you use them. Above Difference and its service providers may collect information about whether you open or click any links in the Cultural Intelligence, Programmes or event communications that we send to you. The information provided throughout this Privacy Policy about cookies also applies to these other tracking technologies. Please refer to our Cookie Policy for more details regarding our use of Cookies and Other Tracking Technologies.

Our Website does not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.

Use of information collected via mobile devices

In connection with our mobile applications, Above Difference may use third party service providers to analyse user activity to fix errors, monitor usage, and improve the performance of the mobile applications. For example, above Difference receives reports on some of our mobile applications’ aggregate usage and browsing patterns, including information about the type of device used, articles accessed, and other events occurring within our apps. Above Difference also receives reports on certain errors occurring within mobile applications.

The legal basis by which we process your personal data

Our processing of your personal data for the purposes mentioned above is based:

• in part, on our legitimate interests in promoting and protecting Above Difference, building and maintaining relationships and providing our services;
  
• in part, on your consent, for example if you create a user profile, or register for our newsletters or alerts, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our website;
  
• in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.
  

Disclosure of personal data: data recipients and international data transfers

Personal data collected in the course of Above Difference business activities, including in connection with some client services, as well as on the Website, may be transferred from time to time to Above Difference partners and affiliates and their personnel across the global, as well as to our third-party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Website may be viewed and hosted by Above Difference and our third-party service providers anywhere in the world.

Above Difference will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorised or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows. Above Difference may provide access to your personal data to third party service providers engaged by Above Difference to provide services related to the Website as well as related to Above Difference’s business activities, including in connection with some client services, in the manner agreed upon in our client services agreements. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing programme / materials, administering surveys or contests, or communicating with you.

In addition, we may disclose information about you:

• If we are required to do so by law or legal process;
• To law enforcement authorities or other government officials;
• When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
• If disclosure is necessary to protect the vital interests of a person;
• To enforce our Terms of use
• To protect our property, services and legal rights;
• To prevent fraud against Above Difference, our subsidiaries, affiliates and/or business partners;
• To support auditing, compliance, and corporate governance functions; or
  To comply with any and all applicable laws.

In addition, we may disclose or transfer your personal data in the event of a re-organisation, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

User forums

You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. Above Difference is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Site.

Link to third party sites

Above Difference may provide links to third party websites or information as a service to our users. If you use these links, you will leave the Site. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by Above Difference of the third party, the third-party website, or the information contained therein, and Above Difference shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

Social Networking

The Site may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with Above Difference. The Site also may allow you to log in to an Above Difference account using certain social network account credentials.

By associating your social network account with Above Difference or logging in to a Above Difference account using your social network account credentials, you give us permission to access information that you have made available in your public profile for that social network account. The information available in your public profile varies based on the social network and your settings, but may include your email address, real name, profile picture, gender, and location. We use the information we receive from your social network account in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with Above Difference and other connected applications and to manage the data that is shared through your account, including information about your activities using our Website.

If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.

Security

Above Difference has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorised Above Difference personnel and third-party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, Above Difference cannot guarantee that unauthorised persons will not obtain access to your personal data.

Data retention

Above Difference retains personal data, as necessary, for the duration of the relevant business relationship.

We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our information management policies and schedules. If you request that we delete your personal data, Above Difference will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Privacy Policy.

Children

The Website are not designed for or directed at children 16 years of age or younger, and Above Difference does not intentionally collect or maintain personal data about anyone under this age.

Your rights

Where granted by applicable law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.

If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at admin@abovedifference.com To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.

In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.

Unsubscribe

If you have registered for Above Difference newsletter or alerts, or you receive invitations to programmes or events from Above Difference and you prefer not to receive future email communications from us, please review the communications settings in your profile on abovedifference.com, follow the instructions on the page of the Site where you have provided such information, subscribed or registered or write to admin@abovedifference.com to unsubscribe from all Above Difference communications.

Consent; Changes to Privacy Policy

By using the Website, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Website. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Website.

Download Above Difference’s Data Protection Policy

Contact us

If you have any questions about our Privacy Policy, please contact us at:

4th Floor, Victoria House
Victoria Road
Chelmsford, Essex CM1 1JR
United Kingdom

admin@abovedifference.com