PRIVACY STATEMENT and DISCLAIMER

Privacy Statement and Disclaimer

Effective Date: January 1, 2025
Last Updated: December 23, 2024

For transparency purposes, this is our privacy statement and disclaimer.

Clarendon Wallace  (“CW”, “we,” “our,” “us”) is committed to protecting your personal information in accordance with applicable data protection laws, including Bermuda’s Personal Information Protection Act 2016 (PIPA), the General Data Protection Regulation (GDPR), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), The Freedom of Information and Protection of Privacy Act (FOIPOP)  in Nova Scotia  and the UK Data Protection Act 2018 (DPA).

We may have other notices which may apply to you depending on how you choose to interact with us.

You can find any of our notices here CW PRIVACY NOTICE.

1.  Who we are

Clarendon Wallace is a global speaking, training, and executive coaching firm with expertise in providing customized solutions for public and private-sector clients. We offer over 30 years of expertise in several areas including: keynote speaking, training, facilitation, executive coaching, and leadership development. Our recurring clients experience results tied to their mission and values and consistently remark that working with us has a profound impact on performance and productivity.



2. What Personal Information we collect
While we endeavour to limit the amount of personal information that we may collect to the necessary information relevant for the services we may offer to you. The following types of information may be collected by operation:

For Marketing purposes:

  • Full Name(s)

  • Photos

  • Videos

  • Email address(es)

  • Place of work

  • Job title

  • Job address



From our website and/or Apps

  • URL address(es)

  • Cookies/Preferences

  • IP Address(es)

  • browser type

  • device identifiers

  • log-in data



For Sales and Solicitation purposes

  • Full Name(s)

  • Email address(es)

  • Place of work

  • Job title

  • Job address

  • Telephone number(s)

  • Banking details

Financial

  • Name(s)

  • Photo(s)

  • Email address

  • Telephone number(s)

  • Banking payment details

  • Credit card payment details

Other Information

  • Any information you provide to us with your consent, through correspondence, surveys, or forms, etc.

3. How we collect Personal Information

We mainly collect your personal information in the following ways:

  • Directly from you when you sign up for our services, contact us or complete a form. This may be through our sales representatives, website forms, service requests, emails, telephone calls, meetings and mobile device.

  • From third parties, such as business partners, public databases such as Google and Microsoft Internet Explorer and through LinkedIn.

  • When you visit our offices

  • When we install or provide our products and service within your physical office location or your physical premise.

For a full list of third parties, business partners, vendors please see section 5. How we share your personal information.

4. How we use your Personal Information

We mainly process your personal information for the following purposes and reasons:

  • To provide and manage our products and services and to understand how you use our services.

  • To communicate with you, including sending service updates, completing service requests and/or marketing communications (where permitted with consent) and marketing analysis including trends in product offerings.

  • To comply with legal and/or regulatory obligations, which may be amended from time to time requiring us to change terms and conditions including how we use, protect and retain your information.

  • To improve our services and enhance user and customer experiences, through feedback loops and surveys.

  • To prevent fraud, breaches and ensure security of information and data through data analytics, audit, testing and monitoring.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.

5. How we share your Personal Information

We may share your personal information with the following third parties that Clarendon Wallace have determined as material third parties. This table may be amended periodically and will be posted on our website with the updated effective date.

Where a change, acquisition, removal or addition to any of our third parties is made which may change how, who or where we may share your information, we will provide notification through our website and contractually through our terms and conditions, where necessary and relevant.

Where necessary, we will obtain your consent prior to the change or new use of your personal information. We ensure all third parties with whom we share data and information adhere to data protection laws and implement adequate safeguards.

We contractually ensure through our terms and conditions with our third parties that there is:

  • a legal basis for joint processing;

  • a clause to honour your legal rights in respect of your data and personal information;

  • a process of security of joint processing;

  • a method to review compliance with these terms and conditions.

Current Third Parties and Business Partners

6. International Data Transfers

If your personal information is transferred outside of Bermuda to either the UK, the USA, Canada or the European Economic Area (EEA), we will ensure adequate safeguards are in place, such as standard contractual clauses and/or other approved mechanisms.

Our current geographic regions where information may be transferred include:

▪     Canada

▪     United Kingdom

▪     United States of America

▪     European Economic Area (EEA)

▪     Mexico

Any changes or updates to this list will be provided by notification through our website.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal and regulatory obligations and in line with our internal Data Retention Policy. If you would like further information in relation to how long we may keep information, including personal information, please contact our privacy officer at privacy@clarendonwallace.com

8. Know your rights

Under global data privacy and protection laws you have the following rights:

  • Access: You can request access to your personal information.

  • Correction: You can request corrections to inaccurate or incomplete data.

  • Deletion/Erasure: You can request deletion of your personal information under certain conditions, where we do not have any legal or regulatory obligation to continue to hold the information.

  • Objection: You may elect to object to processing your information based on legitimate reasons[1].

  • Portability: You may request transfer of your data to another entity in a structured, machine-readable format.

  • Withdraw Consent: You may withdraw consent at any time, for processing based on original consent.

  • Lodge Complaints: You may file a complaint with a supervisory authority if you believe your rights are being violated.

How to submit a request:

You may submit a request from the categories above and in relation to your personal information by emailing privacy@clarendonwallace.com. You will have to complete our verification of identity process, and we must verify the request for authenticity in order to prevent fraud or a fraudulent request. This is to protect you, your information, us and our customers.

Once your identity is verified, you can complete and submit the Data Subject Request Form. Once the form has been received by us, between the hours of Monday – Friday 9:00am AST to 5:00pm AST, we will provide you with a confirmation of receipt and an assigned ticket number within 24 to 48 hours.

We will complete the request in line with the Bermuda PIPA Act 2016 requirement of 45 business days.

[1] Legitimate reasons may only include reasons that are outside obligations to hold information and will not impact our operations, risks, liabilities, products and/or services and where there are no legal and/or regulatory requirement to use or retain information.

9. Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

We use both session and persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: CW

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: CW

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: CW

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

10. Security and Protection of your Personal Information

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, use, transfer, loss, alteration, or misuse.

We also require our material third parties, vendors, suppliers and business partners to meet our standards and to ensure they are at minimum in line with our internal Privacy and Data Protection Policy.

We may use your information to help protect you, our customers, our third parties and ourselves against fraud, cyber crime and to generally protect information.

11. Changes to this Privacy Statement

We may update this Privacy Statement and Disclaimer periodically. Any changes will be posted on our website with the updated effective date.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/clarendonwallacebda/, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy