Thought Axis, Inc (“we,” “our,” or “us”) is committed to providing a superior learning experience for everyone we work with. We know that our users are committed to their success, and we are equally committed to ensuring that each interaction that someone has with our content is optimized for maximum educational potential. To enable us to do this, Thought Axis, Inc needs to gather and use certain information about individuals.
We gather information from customers, affiliates, business contacts, employees, and other people the organization has a relationship with or may need to contact.
This policy describes how this personal data is collected, handled, and stored to meet the company’s data protection standards — and to comply with the law.
Why This Policy Exists
This data protection policy provides guidance regarding how Thought Axis, Inc:
- Complies with data protection law and follows industry best practices;
- Protects the rights of staff, customers, affiliates, and partners;
- Stores and processes individuals’ data and provides transparency regarding same; and
- Reduces the risk of suffering a security incident.
EU General Data Protection Regulation (GDPR) Protection Law
The GDPR (General Data Protection Regulation) describes how organizations who conduct business with individuals or entities located in EU (European Union) nations — including Thought Axis, Inc — must collect, handle, and store the personal data of information related to individuals in the EU (EU Personal Data). These rules apply regardless of whether data is stored electronically, on paper, or in any other manner. To comply with the law, EU Personal Data must be collected and used fairly, stored safely, and not disclosed unlawfully.
The EU GDPR is underpinned by eight core principles. These state that EU Personal Data must:
1. Be processed fairly and lawfully.
2. Be obtained only for specific, lawful purposes.
3. Be adequate, relevant, and not excessive.
4. Be accurate and kept up to date.
5. Not be held for any longer than necessary.
6. Be processed in accordance with the rights of data subjects.
7. Be protected in appropriate ways.
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection or is pursuant to some other lawful basis for transfer.
1. Policy Statement
Every day our business will receive, use, and store personal information about our customers, affiliates, partners, and colleagues. It is important that this information is handled lawfully and appropriately, in line with the requirements of the Data Protection Act of 2018, the GDPR, and any other local or foreign data protection, data security, and privacy laws and regulations (collectively referred to as the ‘Data Protection Requirements’).
We take our data protection duties seriously because we respect the trust that is being placed in us to use personal information appropriately and responsibly.
2. About This Policy
This policy and any other documents referred to in it sets out the basis on which we will process any personal data that we collect or process. This policy does not form part of any employee’s contract of employment and may be amended at any time. The company as a whole is responsible for ensuring compliance with the Data Protection Requirements and with this policy.
3. What is Personal Data?
For purposes of this policy, personal data is defined as data, whether stored electronically or on paper, relating to an identified or identifiable individual who can be identified directly or indirectly from reference to an identifier, such as a name, number, location data, online identifier, or other factors specific to the physical, genetic, mental, economic, cultural, or social identity of that individual.
Processing is any activity that involves personal data, including obtaining, recording, holding, structuring, storing, organizing, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring personal data to third parties.
4. Data Protection Principles
We will process personal data in compliance with the GDPR, including providing that EU Personal Data is:
- Processed fairly, lawfully, and in a transparent manner.
- Collected for specified, explicit, and legitimate purposes and any further processing is completed for a compatible purpose.
- Adequate, relevant, and limited to what is necessary for the intended purposes.
- Accurate and, where necessary, kept up to date.
- Kept in a form that permits identification for no longer than necessary for the intended purposes.
- Processed in line with the individual’s rights and in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
- Not transferred to people or organizations situated in countries without adequate protection or other lawful basis.
5. Fair and Lawful Processing
The Data Protection Requirements are not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the individual.
In accordance with the GDPR, we will only process personal data for a lawful purpose. The lawful purposes include (amongst others): pursuant to the consent of the individual, as necessary for the performance of a contract, for compliance with a legal obligation, or for the legitimate interest of the business. When sensitive personal data is being processed, additional conditions must be met.
HOW WE COLLECT INFORMATION
When you interact with our website, products, and services, we may collect information you voluntarily provide to us in a variety of ways:
- When you visit our website or use our service.
- When you participate in surveys or marketing promotions.
- When you provide reviews or ratings or taste preferences.
- When you set preferences in Your Profile/Account.
This information may include your name; email address; mailing address or postal code; payment method; telephone number; details regarding your interactions with customer service, such as the date, time and reason for contacting us; transcripts of any chat conversations that you initiate on our platforms; and other account and profile information and preferences.
We also collect technical information, including but not limited to your browser type, IP address, pages visited, course progress and search queries, and other activities regarding you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service.
HOW WE USE INFORMATION
We may keep and use the information we collect from you in the following ways:
- To provide, analyze, administer, enhance, and personalize our services and marketing efforts, to process your registration, orders, payments, and communication on these and other topics.
- To enhance the user experience by, for example, analyzing any difficulties you’re facing within the platform and creating additional content geared toward our users’ needs and personal preferences.
- To provide you with access to this website or other Thought Axis, Inc products or services;
- To personalize your experience and to allow us to deliver the type of content and offerings in which you are most interested;
- To respond to your requests;
- To bill you for products/services you purchased;
- To provide ongoing service and support;
- To communicate with you by mail, email, or telephone;
- To research, develop, and improve programs, products, services, and content;
- To protect our rights or property or to protect someone’s health, safety, or welfare; and
- To comply with a law or regulation, court order, or other legal process.
- Strictly Necessary Cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
- Functionality and Preference Cookies. These are cookies the primary purpose of which is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you register with us, a cookie helps Thought Axis, Inc to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Thought Axis, Inc website, the information you previously provided can be retrieved, so you can easily use the features that you customized.
- Analytical/Performance Cookies. They allow us to recognize and count the number of visitors to the web pages on the web site or to monitor how our users navigate the web site and in email messages to count how many email messages sent were actually opened, acted upon or forwarded.
- You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you choose to use your browser settings to block all cookies, you may not be able to access or fully experience the interactive features of the Thought Axis, Inc websites you visit.
6. Processing for Limited Purposes
We process personal information with your consent (e.g., when we process personal information to provide services you request). On other occasions, we may process personal information when we need to do so to fulfill a contract (for example, to deliver the services) or where required to do so by law.
If necessary, we may also process personal information when it is in our legitimate interests to do so (e.g., providing our services and customer service) and when these interests are not overridden by your data protection rights.
7. Notifying Individuals
If we collect personal data directly from an individual in the EU, we will inform them about:
- The purpose or purposes for which we intend to process that personal data, as well as the legal basis for the processing.
- Where we rely upon the legitimate interests of the business to process personal data, the legitimate interests pursued.
- The types of third parties, if any, with which we will share or disclose that personal data.
- The fact that the business intends to transfer personal data to a non-EEA country or international organization and the appropriate and suitable safeguards in place.
- How individuals can limit our use and disclosure of their personal data.
- Information about the period that their information will be stored or the criteria used to determine that period.
- Their right to request from us as the controller access to and rectification or erasure of personal data or restriction of processing.
- Their right to object to processing and their right to data portability.
- Their right to withdraw their consent at any time (if consent was given) without affecting the lawfulness of the processing before the consent was withdrawn.
- Whether the provision of the personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the individual is obliged to provide the personal data and any consequences of failure to provide the data.
- The existence of automated decision-making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the individual.
- That we are the data controller with regard to the data we process and our contact detail is firstname.lastname@example.org
We may not be able to afford these rights to data subjects under certain circumstances, such as when we are legally prevented from doing so.
8. Adequate, Relevant, and Non-Excessive Processing
We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.
9. Accurate Data
We have mechanisms in place to help ensure that personal data is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
10. Timely Processing
We will not keep personal data longer than necessary for the purpose or purposes for which it was collected. We will take all reasonable steps to destroy or erase from our systems all data that is no longer required.
11. Processing in line with Data Subject’s Rights
We will process all personal data in line with data subjects’ rights, in particular their right to:
- Confirmation as to whether or not personal data concerning them is being processed.
- Request access to personal data held about them by a data controller.
- Request rectification, erasure, or restriction on processing of their personal data.
- Lodge a complaint with a supervisory authority.
- Data portability.
- Object to processing, including for direct marketing.
- Not be subject to automated decision making, including profiling in certain circumstances.
12. Data Security
We will take appropriate security measures against unlawful or unauthorized processing of personal data and against the accidental or unlawful destruction, damage, loss, alteration, or unauthorized disclosure of or access to personal data transmitted, stored, or otherwise processed.
We will put in place procedures and technologies to maintain the security of personal data. Personal data will only be transferred by us to a data processor under an agreement that the processor comply with those procedures and policies or has other adequate measures in place.
We will maintain data security by protecting the confidentiality, integrity, and availability of the personal data. We have implemented physical, technical, and administrative safeguards to help protect personal data.
Transferring Personal Data Outside of the EEA: We may transfer any personal data we hold to a country outside the European Economic Area (‘EEA’) or to an international organization, provided that one of the following conditions applies:
- The country to which the personal data is transferred ensures an adequate level of protection for the data subjects’ rights and freedoms.
- The data subject has given his consent.
- The transfer is necessary for one of the reasons set out in the GDPR, including the performance of a contract between us and the data subject, or to protect the vital interests of the data subject.
- The transfer is legally required on important public interest grounds or for the establishment, exercise, or defense of legal claims.
- The transfer is authorized by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.
Subject to the requirements above, personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Those staff may be engaged in, among other things, the fulfilment of contracts with the data subject, the processing of payment details, and the provision of support services.
13. Disclosure and Sharing of Personal Data
We share personal information with third parties, including the following:
- Third parties that perform services or functions on our behalf, such as those that provide website operation services, email services, and payment processing services;
- As part of a corporate sale, merger, dissolution, or acquisition;
- Pursuant to a court order, subpoena, search warrant, or other legal process or as otherwise required or requested by law, regulation, or government authority programs, or to protect our rights or property, protect someone’s health, safety, or welfare;
- With your consent or as otherwise disclosed at the time of data collection or sharing; or
- With any member of our group, which means our subsidiaries and our ultimate holding company and its subsidiaries, as defined in: https://www.legislation.gov.uk/ukpga/2006/46/section/1159.
14. Subject Access Requests
Individuals may make a formal request to access information we hold about them. Employees and affiliates who receive a request should forward it to the data department immediately.
When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:
- We will check the caller’s identity to make sure that information is only given to a person who is entitled to it.
- We will suggest that the caller put their request in writing if we are not sure about the caller’s identity and if their identity cannot be checked.
- Where a request is made electronically, data will be provided electronically when possible.
Our support team will refer a request to the data processing department or the Data Protection Compliance Manager for assistance in difficult situations.
15. Changes to this Policy
We may modify this policy at any time. Any changes to this policy will be listed in this section, and if such changes are material, a notice will be posted through the services, posted on our websites, or sent to you in an email to provide you the opportunity to review the changes and choose whether to continue using the services.
16. Contact Us
If you have any questions, please contact us here. For detailed information on GDPR, please visit https://www.eugdpr.org/