Privacy notice

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This notice applies to you, as a user of one or more of the following websites debono.network, Six-Thinking-Hats.com, deBono.com and LateralThinking.com (the Site(s)). The Sites are owned and operated by Edward de Bono Ltd, trading as de Bono (we, our or us). You can find details about us at the “Company Details” section below.

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References to you, your in this privacy notice are to you as an individual.

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We take the privacy of your personal information very seriously. This privacy notice applies to our use of any and all personal information collected by us, or provided by you, in relation to your use of the Site(s) and it explains how we comply with the law on data protection and what your rights are.

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​We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation.  Contact details are set out in the “Contacting Us” section at the end of this privacy notice.

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For the purposes of data protection, we will be the ‘controller’ of any of your personal information.

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In this Privacy Notice, we refer to ‘Instructors’, ‘Trainers’ or ‘Distributors’. If you have paid for a subscription to access content on our Site(s), you will have either have subscribed via an Instructor, Trainer or a Distributor. Instructors and Trainers provide courses in the de Bono thinking techniques. Distributors are authorised by us to sell de Bono courses.

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Personal information we collect

We may collect the following types of personal information about you:

• Contact details: information that allows us to identify and contact you directly such as your name, email address and telephone number.

• Details of your professional life: this may include the industry you work in, the organisation you work for, and country of residence. If you are an Instructor, it will also include your certification in de Bono techniques.

• Details of the correspondence (including e-mail correspondence) you send and receive from us: this includes letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations if you contact us about your use of our Site(s).

• Subscription information: for example, when you subscribe to one of our newsletters or other materials via our Site(s).

• Webforms on our Site(s): information that you provide when you fill out a form on our Site(s) which includes when you provide subscription information, give us your feedback, request information from us, make a request for a de Bono book to be re-published, or if you contact us via the Site(s).

• Online Discussions: any personal information that you include in any online discussion forum that you choose to participate in.

• Information submitted as part of our courses: this includes any personal information you include when completing any of our courses or accessing any of our content via the Site(s) and your score, for example when you take part in a quiz.

• Login information: account details including username and password where you have  registered on the Site(s) to access various content on the Site(s), registered via the organisation that trains you in the de Bono methods to receive access to various areas of the Site(s) or have been given access to the Site(s) as a result of an offline contract that we have with you or your training provider.

• Your provenance as a user of the Site(s): if you have been given access to the Site(s) by an Instructor or Distributor, this includes which Instructor or Distributor you have been given access by and the country that you are located in.

• IP address information: your computer's IP address allows us to track your usage of our Site(s).

• Your use of the Site(s): including a list of URLs starting with a referring site, your activity on a Site, and the site you exit to and the date, times and frequency with which you access the Site(s) and the way you use and interact with its content.

• Responses to surveys: we keep records of any surveys you choose to respond to.

 

Information about your usage of our Site(s) may be collected through cookies and/or log files. For more information about the cookies we use, see our cookies policy.

 

Special categories of personal information

Please note that we do not actively process any special categories of data such as an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs. However, given the nature of the Site(s), you may choose to discuss or disclose this data as part of your experience on our Site(s) or that result from subscription to one of our services, for example during an online discussion you may have. Please be aware it is your choice to disclose this information and should you do so, it will be processed and stored in line with this Privacy Notice.

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Sources we collect your personal information from

We will collect personal information from a number of sources. These may include the following:

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• Directly from you: when you complete a form on our Site(s), contact us by phone, email or communicate with us directly in some other way.

• Our Site(s): provides us with information about how you use it and the devices that you use to connect to our website.

• Providers of information: if you have been given access to the Site(s) by your Instructor or Distributor, this includes which Instructor or Distributor you have been given access by and the country that you are located in.

 

We will also collect additional personal information throughout the period of our relationship with you.

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If you are providing information regarding other individuals to us, it is your responsibility to ensure that you have the right to provide the information to us.

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If you are providing us with details about other individuals they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with them. They also have the same rights as set out in the “Your Rights In Relation To Personal Information” section below

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What we use your personal information for

​The list below describes the main purposes for which we process your personal data, the categories of your information involved and our lawful basis for being able to do this. Which will apply will depend upon the nature of your relationship and interactions with us.

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Purpose: Enter into and perform contracts, where we are making available content to you

Personal information used: All the personal information we collect

Lawful basis: To enter into and perform contracts with you or the organisation that you represent

We have a legitimate interest to properly perform contracts with you or the organisation you represent.

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Purpose: Deal with your queries or complaints, claims, legal disputes or raise queries, claims, legal disputes or complaints with you or the organisation you work for

​Personal information used: All the personal information we collect

Lawful basis: This may be necessary to perform an obligation under a contract with you or the organisation that you represent. We have a legitimate interest to improve the services and/or products we provide. To defend, bring or establish legal claims

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Purpose: Maintain and improve our services

Personal information used: All the personal information we collect.

Lawful basis: We have a legitimate interest to improve the services and/or products we provide

 

Purpose: Data analytics, statistical analysis and other research to help us improve our online services

Personal information used: How you use our Site(s)

Lawful basis: We have a legitimate interest to:

• ensure that our Site(s) is presented in the most effective manner for you and your device through which you access it, so that we can provide the most positive user experience 

• analyse usage data to learn more about how our Site(s) is used, to help us to provide a positive user experience and improve and increase usage of our Site(s); and

• detect and investigate any potential misuse of our Site(s), to protect ourselves and other users 

 

Purpose: Staff training

Personal information used: All the personal information we collect

Lawful basis: We have a legitimate interest to improve the products and services we provide

 

Purpose: Direct marketing

Personal information used: Contact details and services and products that we have determined may be of interest to you or your organisation and/or which you or your organisation has purchased in the past

Lawful basis: We may ask for your consent to process your data for this purpose, you may revoke your consent at any point. Alternatively, if you or your organisation have purchased similar services from us previously we may market similar products or services as a legitimate interest in developing our business.  You have the right to opt out from such marketing at any time.

Personal information used: If you are an Instructor or Distributor, your Contract details and certification in de Bono techniques.

Lawful basis: To perform contracts with you or the organisation that you represent. We have a legitimate interest to promote your services to users.

Personal information used:

Your name and role.  If you provide us with a testimonial, we will use your name and role to identify by whom the testimonial was made.

Lawful basis: We have a legitimate interest to promote our services and products.

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Purpose: To comply with our legal obligations

Personal information used: All the personal information we collect

Lawful basis: To comply with any legal obligations or requirements

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Purpose: To manage our relationship with you, the organisation you work for or the organisation that trains you in de Bono methods and to operate and manage our business and internal reporting

Personal information used All the personal information we collect

Lawful basis: We have a legitimate interest to operate our business in an efficient way and to expand our business.

To enter into and perform contracts with either you, the organisation that you represent, or the organisation that trains you

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Purpose: Deliver relevant advertising to you

Personal information used: All the personal information we collect

Lawful basis: We have a legitimate interest to deliver advertisements to you for de Bono products and services so that we can generate revenue and continue to deliver the de Bono service to you.

 

Purpose: Storage of records relating to you and also records relating to our business

Personal information used: All the personal information we collect

Lawful basis: To be able to manage and fulfil any contract with you, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records

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For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information.  If you do not provide us with the requested personal information, we may not be able to properly perform our contract with you or the organisation you represent or comply with legal obligations and we may have to terminate our relationship.  For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.

 

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.  We will generally only ask for your consent for direct marketing.

 

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.  Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.

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We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you).  We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and services.

 

Who we share your personal information with

• Your Instructor or Distributor: if you have consented, then we will allow your Instructor or Distributor to see a record of how far you have progressed in your chosen course and your answers to questions raised during the course (but not to information you provide in the My Thoughts service).

• Your Distributor: we will disclose to your Distributor, that you have activated your login to the Site(s). This is so the Distributor knows which of their subscriptions have been activated.  No other personal information that is collected via the Site(s) is disclosed to the Distributor.

• Where you make an enquiry about our products or services: any partners through which we offer those products or services.

• Our professional advisors: such as lawyers, accountants, financial advisors, consultants and other advisors.

• Other service providers and advisors to us: such as companies that support our IT, help us analyse the data we hold, send communications to our customers, provide us with legal, property or financial advice and generally help us deliver our services to you or the organisation that you represent.

• A prospective seller or buyer: of any business or assets in the event that we sell or buy any business or assets

• Law enforcement authorities:  in connection with any suspected misuse of the Site(s) or other suspected illegal activity

• Marketing and public relations: to help us to develop, carry out and assess marketing and PR campaigns, so for example, if you provide us with a testimonial, we will disclose your name publically, in connection with your testimonial. We also use third party providers such as Mailchimp to deliver our marketing messages.

 

We do not disclose personal information to anyone else except as set out above unless we have your consent, or we are legally obliged to do so.  We do not sell, rent or trade your data.

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Collection of your personal data outstide of the Site(s)

You may, as part of your course be trained by an Instructor. Training may take place in person or via (video) calls outside of the Site(s). Where that happens, any personal data you disclose during that training will be collated by your Instructor, not us. You are advised to read the privacy notice of your Instructor prior to the training taking place to understand how they treat your personal data.

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Direct Marketing

​Email marketing: from time to time, we may contact you by email, with information about products or services we believe you may be interested in.

 

We will only send marketing messages to you in accordance with the marketing preferences you set when you create your account or that you tell us afterwards you are happy to receive or where you or the organisation you represent has purchased similar services or goods from us previously.

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You can then let us know at any time that you do not wish to receive marketing messages by. You can withdraw your consent at any time at this URL: https://debono.us19.list-manage.com/unsubscribe?u=62b730d5e8630693444a5fb1c&id=dd1a7b07a2 or by using the details set out in the “Contacting us” section below.  You can also unsubscribe from our marketing by clicking on the unsubscribe link in any marketing messages we send to you.

If you have subscribed to content on the Site(s) via your Instructor or Distributor, we do not provide your contact data to your Instructor or Distributor for marketing purposes. Your Instructor or Distributor will however have collated your contact data from you independently and may market to you using the personal data that they hold. If you no longer wish to receive marketing communications from your Instructor or Distributor, please advise them directly.

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How long do we keep personal information for

We will keep your personal information for as long as is necessary for the purpose for which it has been obtained and then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim.  We have set out below the main retention periods which will apply: 

• For marketing contacts it will generally be a period of 1 year after we were last in contact with you.

• For visits to our Site(s) it will generally be a period of year after you used the Site(s).

• For information submitted as part of a course that you are subscribed to, the information will be retained during the course of your subscription (including any renewal) and for one month following expiry or cancellation of your subscription

• For individuals seeking information, making complaints, or otherwise corresponding with us via email or post it will be up to 3 years.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address. you can contact us by using the details set out in the “Contacting Us” section below.

 

Security

We have numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as usernames and passwords, we store your personal information on secure servers and use firewalls. We use Hypertext Transfer Protocol Secure (https) for our sites. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you. 

 

You should take all reasonable steps to keep your personal information secure, including taking care about what personal information you send us, choosing a secure password for your email account and not disclosing your passwords to anybody else. You should use a unique password for every account.  If you suspect any misuse or loss or unauthorised access to your personal information, please let us know immediately by contacting us via this e-mail address: info@debono.com.

 

Transfers outside the European Economic Area

The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union, for example, this could occur if our servers or one of our service providers are located in a country outside the UK or European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third party processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws.  For further details please contact us by using the details set out in the "Contacting Us" section below.

 

Your rights in relation to your personal information

You have the following rights in relation to your personal information:

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• the right to be informed about how your personal information is being used;

• the right to access the personal information we hold about you;

• the right to request the correction of inaccurate personal information we hold about you;

• the right to request the erasure of your personal information in certain limited circumstances;

• the right to restrict processing of your personal information where certain requirements are met;

• the right to object to the processing of your personal information;

• the right to request that we transfer elements of your data either to you or another service provider; and

• the right to object to certain automated decision making processes using your personal information.

 

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.  For example, we do not use automated decision making in relation to your personal data.  However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

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We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

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Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

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To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting Us" section below.

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If you are unhappy with the way in which we are using your personal information you can also complain to the Information Commissioner’s Office.   Please see https://ico.org.uk/make-a-complaint/ for more information.  We are here to help and encourage you to contact us to resolve your complaint first.

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Links to third party websites

Our Site(s) may, from time to time, provide links to other websites, for example links to de Bono books on Amazon or Lulu which you may choose to purchase or to other de Bono content hosted on YouTube. We have no control over such websites and this privacy notice does not extend to your use of such websites. You are advised to read the privacy notice and terms of conditions of any third party websites prior to using them to understand how they treat your personal data.

 

​Cookie Policy

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In this policy, you will find information on what cookies may be set when you visit this Site and how to reject or delete those cookies for this Site.  For further detailed information about the Site(s), please see our Terms of Use and our Privacy Notice above.

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What are cookies?

• A cookie is a small data file that is placed on your computer or other device to allow a website to recognise you as a user when you return to the website using the same computer and web browser, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (a ‘persistent cookie’). Other similar files work in the same way and we use the word ‘cookie’ in this policy to refer to all files that collect information in this way.

• Cookies are an extremely common technology for remembering certain information about a visitor to a website. The vast majority of websites currently make use of cookies and they are commonly used for a wide range of tasks. We use cookies for the following purposes:

• as necessary for Site(s) operation, for example to enable you to login to your account;

• to analyse the use of the Site(s) by, for example, recognising and counting the number of visitors and how they move around the Site(s).This helps us to see what parts of the Site(s) are popular and which sections need improving to make the experience better for users;

• to recognise you when you return to the Site(s) so that content can be personalised for you, for example, by remembering your country and site preferences; and

• to record your visit to the Site(s) and the pages you have visited and links you have followed. We will use this to make the Site(s) more relevant to your interests.

• More detailed information is provided below on the specific cookies used on this Site.

 

The cookies we use and how to control and delete them

• When you accessed the Site, you were presented with a message that notified you of our use of cookies. We had to use a cookie to present you with that notice (you can see details of this cookie under ‘Cookie consent’ ). If you continue to use the Site, more cookies and other tracking technologies will be placed on your computer as described in this Cookie Policy in order to enhance your user experience whilst on the Site.

• We will not use cookies to collect personally identifiable information about you. However, if you wish to restrict or block the cookies which are set by the Site, (or indeed, on any other site) you can do this through your browser settings.The ‘Help’ function within your browser should tell you how.

• You can find more information about the individual cookies we use, the purposes for which we use them, and how to control them by following the instructions provided in the Cookie Schedule.

• Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains comprehensive information on how to do this on a wide variety of browsers.You will also find details on how to delete cookies from your device, as well as more general information about cookies. Please note that, as these websites are not owned or operated by us, we are not responsible for any of the content on them.

• Please be aware that restricting cookies may mean that you will not be able to take full advantage of all the features or services available on the Site(s).

 

Email Tracking

Some of the emails we send to you may contain a ‘web beacon pixel’ or tracked links which allows us to identify when you have opened the email and to verify which links contained in the email you have accessed. We use this information to determine which parts of our emails are of most interest to you. You can delete the pixel by deleting the email. If you do not wish to download the pixel to your computer or other device, you can ensure this by selecting to receive emails from us in plain text rather than HTML. Alternatively you can unsubscribe from our mailing list by contacting us at info@debono.com

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We may make changes to this Cookie Policy at any time by sending you an e-mail with the modified Terms or by posting a copy of them on the site.  Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the site, whichever is the earlier.   

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Changes to this notice

We may update this privacy notice and cookie policy from time to time. When we change this notice in a material way, we will update the version date at the bottom of this notice. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

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Contacting us

If you have a query or complaint in connection with the information we hold about you, please email us at info@debono.com or write to us at First Floor, Templeback, 10 Temple Back, Bristol, BS1 6FL, United Kingdom.

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Company Details

Our registered office address is: Edward de Bono Ltd, First Floor, Templeback, 10 Temple Back, Bristol, BS1 6FL, United Kingdom. We are registered in England with company number is 11433091.

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This Privacy Notice and Cookie Policy was published on 30 December 2020.

 

 

Cookie Schedule

 

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.