Privacy Policy Sunny Heart Academy of Excellence

Privacy Notice

1. Statement

Thomas Cook GmbH (“We”), trading on website  Sunnyheartacademy.com are committed to protecting and respecting your privacy.

This Privacy Notice (together with any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The Company will comply with the data protection principles set out in the law when handling your personal information.

This notice is non-contractual and can be amended at any time.

The data controller is Thomas Cook.

The information that we hold:

  • “Personal data”: this means any information about an individual from which that person can be identified.  It does not include data where the individual’s identity has been removed (anonymous data).
  • “Special category data”: this means any data about an individual of a more sensitive nature and which requires a higher level of protection.

2. The basis for processing your information

We will only use your personal information when permitted by the law. Most commonly, we will use your personal information in the following circumstances:

  • If you make a request for training & consulting services or use any service that we provide on our official website  In the membership area we offer personalized services with the aim to support you in raising the quality of your respective business; for Learning & Development purposes such as e-learning, webinars, 1-2-1 coaching, performance dashboard (with quality key performance indicators) as well as an exchange via the community and the blog area..
  • Where we need to comply with a legal obligation (**).
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (***). Our legitimate interests are to recruit the best candidate for any vacancy and we believe that this is not incompatible with your rights and freedoms. 

We have indicated by asterisks in section 3 below the purpose or purposes for which we process your personal information.  Some of the grounds for processing will overlap and there may be several grounds which justify our use of your personal information. 

3. Information we collect from you

We may collect and process the following data about you:

  • Name, title, Hotel name, address,and contact details;(* and ** and ***);
  • Information you provide in our questionaire;

We may collect additional information from publicly available sources such as social media sites.

4. Uses made of the information

We use information held about you in the following ways (this list is not exhaustive):

  • To ensure the fulfilment of the services you have ordered
  • To manage your relationship with us;
  • To provide you with information on suitable job opportunities with the Thomas Cook Group, where you have consented to be contacted for such purposes;
  • To carry out our obligations arising from any contracts entered into between you and us;
  • To allow you to participate in interactive features of our service, when you choose to do so;
  • To ensure compliance with legal requirements and obligations to third parties.
  • If you actively sign up to receive email newsletters from us, (although you will be given the option to opt-out of such use).

5. Website

IP addresses
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to understand aggregate information. We do this to understand our user’s browsing actions and patterns in a way that does not identify individuals.

Cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

We use Cookies to set users’ preferences. This information allows us to personalise the user experience and improve the quality of Our Site navigation. Cookies do not reveal the identity of the individual user; they only identify the computer utilized by that user.

Some of these cookies are essential to make this Site work properly, to allow you to make your request or use any service that we provide

The table below explains the cookies we use and why.

Cookie

Name

Purpose

More Info

Google Analytics

__utma
__utmb
__utmc
__utmv
__utmz

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where vistors have come to the site from and the pages they visited.

Google Privacy Overview
– For More Info see the link below:

RequestVerificationToken: This is an anti forgery token (prevent CSRF attack). It guarantees that the poster is the one who gets the form.

ASP.NET_SessionId: It is created the first time your application is accessed over the browser.

Google Privacy Overview:

http://www.google.co.uk/intl/en/analytics/privacyoverview.html

6. Automated decision making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless we have a lawful basis for doing so (such as explicit consent) and have notified you.  An example of this is our use of cookies.

7. Where we store personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services. Where your personal data is transferred outside the EEA, we will ensure that an adequate level of protection is provided in accordance with the data protection legislation. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of Our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

8. Access to and disclosure of your information

Your personal information will be accessed by authorised staff who need to have access to that information.

If Thomas Cook Group GmbH or substantially all of its assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets.

We will disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or to protect the rights, property, or safety of Thomas Cook Group GmbH, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

9. Retention of information

We retain your personal data for as long as is necessary for us to use your data as set out in this Privacy Policy or such other time that may be required for our legal and audit purposes or that is required by law.

10. Your rights

Under certain circumstances, you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”).
  • Request correction of the personal information that we hold about you.
  • Request the erasure of your personal information.
  • Request the restriction of and objection to processing of your personal information.
  • Request the transfer of your personal information to a third party.
  • Request for your data not to be used for marketing purposes.
     
    In addition, in the limited circumstances where you may have provided your consent to the processing of your personal information, you have the right to withdraw your consent at any time. To withdraw your consent, please contact our Data Protection Officer using the following details:
     
    Thomas Cook GmbH
    Datenschutzbeauftragter
    Thomas-Cook-Platz 1
    D 61440 Oberursel
     
    Email:    Datenschutz@thomascook.de
     

Some of these rights are not automatic, and we reserve the right to discuss with you why it might not comply with a request.

If you want to exercise any of the above rights, please contact our Data Protection Officer using the details set out in this section.

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

11. Changes to our privacy policy

Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail.

12. Contact

Questions, comments and requests regarding this Privacy Notice or our management of your personal data should be addressed to the above mentioned address.

You retain the right at all times to lodge a complaint about our management of your personal data with the Hessischer Datenschutzbeauftragter.

Thomas Cook GmbH

Thomas-Cook-Platz 1

D 61440 Oberursel