Privacy Policy

Introduction

Welcome to Metaspeech Limited’s privacy policy. Metaspeech Limited (“we”/“our”/“us”) (Registered Company Number 08904863) respects your privacy and is committed to protecting your personal data. We are registered with the ICO (registered number ZA820479).

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy. This policy has been designed with reference to the following legislation:

EU General Data Protection Regulation as retained under UK law after 31 December 2020 (“GDPR”/”UK GDPR”); and
UK Data Protection Act 2018.

We have also divided this privacy notice for various categories of third parties. Please click on the relevant link below to access the applicable privacy policy.

Website Users
Clients
Advisors (including solicitors and financial advisors)

General Provisions

For each type of privacy notice set out above, the below will apply to all types of data subject.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data, including any data you may provide through this website when you sign up to our newsletter or submit your information as a client. This privacy policy will tell you about your privacy rights and how the law protects you.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Metaspeech Ltd is a controller of your data and responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Metaspeech Limited

Email address: [email protected]

Postal address: 100 Clements Road

London

SE16 4DG

Data subjects based in the UK have the right to make a complaint at any time to the Information Commissioner's Office (the “ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. We reserve the right to amend this policy from time to time consistent with applicable legislation (including the GDPR and Data Protection Act 2018).

This version was last updated in January 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Your Legal Rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a "data subject access request").
Request correction of the personal data that we hold about you.
Request erasure of your personal data in certain circumstances. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data.
Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated, but we may have the legal right to extend the time limit for responding.

Automated Decision Making

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 and we have notified you.

We do not envisage that any decisions will be taken about you using automated means.

Glossary

LAWFUL BASIS

We are obliged to have a lawful basis for processing your personal data. Other than consent, the most commonly used lawful bases for processing are the following:

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties include:

Service providers acting as processors who provide IT and system administration services.
Our web services used to host our website.
The website platforms we use to upload your content and us provide our services, including teachable.com and pitcherific.com
Professional advisers acting as processors or joint controllers or controllers in their own right including lawyers, bankers, auditors and insurers based in the U.K. who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers or controllers in their own right based in the United Kingdom.
The other types of third parties listed at the start of this notice.

WEBSITE USERS

1. THE DATA WE COLLECT ABOUT YOU

2. HOW IS YOUR PERSONAL DATA COLLECTED?

3. HOW WE USE YOUR PERSONAL DATA

4. DISCLOSURES OF YOUR PERSONAL DATA

5. INTERNATIONAL TRANSFERS

6. DATA SECURITY

7. DATA RETENTION

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you via our website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our services and submit further details;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

analytics providers such as Google based outside the EU; and
Identity and Contact Data from publicly available sources such as Companies House, business websites and the Electoral Register based inside the EU or the UK.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you (and/or our suppliers, which involves a contract with you).
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.
Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so (these are set out in brackets). Our legitimate interests include to keep our records updated and to study how clients use our services, develop and grow our business, analyse market trends and inform our marketing strategy and provision of administration and IT services and network security.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below:

To register you as a new client or client (performance of a contract with you).
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy and asking you to leave a review or leave a survey (performance of a contract with you, necessary to comply with a legal obligation and/or necessary for our legitimate interests).
To enable you to partake in a prize draw, competition or complete a survey (performance of a contract with you and/or necessary for our legitimate interests).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (necessary for our legitimate interests and/or necessary to comply with a legal obligation).
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (necessary for our legitimate interests).
To use data analytics to improve our website, products/services, marketing, client relationships and experiences (necessary for our legitimate interests).
To make suggestions and recommendations to you about services that may be of interest to you (necessary for our legitimate interests).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or used services from us and you have not opted out of receiving that marketing. You will always be given the opportunity each time you receive marketing communications from us to unsubscribe from future communications of that nature.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in “Purposes for which we will use your personal data” above.

External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Unless you access our website from outside the European Economic Area (EEA) or United Kingdom, we will not transfer your personal data outside the EEA or United Kingdom. However, if this changes (or you access our services from outside the EEA and /or UK), whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where applicable, we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-prote....
Through the use of Standard Contractual Clauses, subject to appropriate safeguards being in place.
In the absence of an adequacy decision or Standard Contractual Clauses and where transfers of your data are limited and occasional, through use of a derogation, such as
- You explicitly consent to the transfer having been informed of the possible risks of that transfer that arise from the absence of an adequacy decision or appropriate safeguards.
- Where the transfer is necessary to perform a contract between us, or the implementation of pre-contractual measures taken at your request.
- To perform a contract that is concluded in your interests.
- For the purposes of establishing, exercising or defending legal claims.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

For website users, we will generally keep the types of personal data set out above for six months from your last visit to our website.

In some circumstances you can ask us to delete your data: see your legal rights for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research, analytical or statistical purposes, in which case we may use this information indefinitely without further notice to you.

CLIENTS

This section covers individual and commercial clients who use our services.

1. THE DATA WE COLLECT ABOUT YOU

2. HOW IS YOUR PERSONAL DATA COLLECTED?

3. HOW WE USE YOUR PERSONAL DATA

4. DISCLOSURES OF YOUR PERSONAL DATA

5. INTERNATIONAL TRANSFERS

6. DATA SECURITY

7. DATA RETENTION

The data we collect about you

For those clients whose details remain on third party sites (including third party websites used to upload and host video recordings for us to provide the services such as pitcherific.com and/or teachable.com) but do not engage our services, the processing activities are minimal because their details are never put on to our systems.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

The information you provide us, or our suppliers hosting the external websites to upload your videos and engage our services (such as teachable.com and pitcherific.com).
Services you have contracted with us for, and any feedback provided and presentation development plans provided to you as part of our services.

As your data is uploaded to and held by the external websites (such as teachable.com and pitcherific.com), we do not hold or store recordings of any video content you upload to these websites, although we will be able to access these from our accounts while we provide the services to you. We will delete these videos when they are no longer required for the purposes we process the data. Please see “Data Retention” below for more information.

We do not envisage that we will collect, store and use more sensitive personal information (known as special category data), including information about your race or ethnicity, religious beliefs, sexual orientation and political opinions; your health, including any medical condition, health and sickness records or information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, or the contract you have with our clients and third parties. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

You.
External Third Parties, who forward the necessary information for us to perform our services to you.

How we use your personal data

We will use the personal information we collect about you to:

Carry out our services to you.
Provide information on further services we believe may be of interest.
Analyse our enquiries and feedback received.

It is in our legitimate interests to carry out the services to you and to analyse business to further improve our services. We also need to process your personal information to carry out our contractual obligations with you and our contractors further to any contract you enter with them.

Once you are no longer an active client, we will retain your personal data in line with our criteria set out below.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out at “How we use your data” above.

External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

Unless you utilise our services from outside the European Economic Area (EEA) or United Kingdom, we will not transfer your personal data outside the EEA or United Kingdom.

Please note that for the external websites you upload content to when using our services, pitcherific.com is based in Denmark (a member of the EEA) and Teachable is based in the US. Please refer to their separate privacy policies.

However, if this changes (or you access our services from outside the EEA and /or UK), whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where applicable, we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-prote....
Through the use of Standard Contractual Clauses, subject to appropriate safeguards being in place.
In the absence of an adequacy decision or Standard Contractual Clauses and where transfers of your data are limited and occasional, through use of a derogation, such as
- You explicitly consenting to the transfer having been informed of the possible risks of that transfer that arise from the absence of an adequacy decision or appropriate safeguards.
- Where the transfer is necessary to perform a contract between us, or the implementation of pre-contractual measures taken at your request. For example, your information uploaded onto Teachable (such as email address) will be necessary to transfer to us to provide the services to you once you upload your videos to Teachable so we can provide the services.
- To perform a contract that is concluded in your interests (for example through us providing you the services).
- For the purposes of establishing, exercising or defending legal claims.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and the EEA.

Data security

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will generally keep personal data for a period of six years from the date of our last services (such retention period being necessary in the event of a legal dispute or if we reasonably believe there is a prospect of litigation). Videos uploaded to pitcherific will generally be stored for six months from when we last provided services to you.

In some circumstances you can ask us to delete your data: see your legal rights for further information.

ADVISORS (INCLUDING SOLICITORS AND FINANCIAL ADVISORS)

1. THE DATA WE COLLECT ABOUT YOU

2. HOW IS YOUR PERSONAL DATA COLLECTED?

3. HOW WE USE YOUR PERSONAL DATA

4. DISCLOSURES OF YOUR PERSONAL DATA

5. INTERNATIONAL TRANSFERS

6. DATA SECURITY

7. DATA RETENTION

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

The information you have provided to us in enquiry forms.
The information you provide us in any contract for us to provide services or for us to seek advice.
The information you have provided in communications with us, including name, title, employer, job title, address, telephone number, email address, gender.

We do not anticipate that we will collect any types of special category data from you (such as race, religion, trade union membership or criminal convictions).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, or use your advisory services. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

You.
Data from third parties in a publicly accessible source such as your LinkedIn details, business website and information disclosed within.

How we use your personal data

We will use the personal information we collect about you to:

Conduct our services with our clients.
Seek our own advice (legal, financial, tax or otherwise).
Administer and fulfil our obligations under the contract of services we have with you.
Obtain feedback on services we have provided in the past.
Communicate with you about our services process.
Provide you with our latest marketing.
Record your preferences in receiving marketing from us and our third parties and your communication preferences.

It is in our legitimate interests to correspond with you to provide services to our client, and seek our own advice where needed. We also wish to ensure our services meet the needs within our contract with you. We also need to process your personal information to decide whether to enter into a contract with you.

It is also in our legitimate interests to provide you with marketing updates.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out above at “How we use your personal data”.

External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

Unless we are seeking advice for outside the European Economic Area (EEA) or United Kingdom, we will not transfer your personal data outside the EEA or United Kingdom. However, if this changes (or you access our services from outside the EEA and/or UK or provide advisory services outside the EEA and/or UK), whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where applicable, we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-prote....
Through the use of Standard Contractual Clauses, subject to appropriate safeguards being in place.
In the absence of an adequacy decision or Standard Contractual Clauses and where transfers of your data are limited and occasional, through use of a derogation, such as
- You explicitly consenting to the transfer having been informed of the possible risks of that transfer that arise from the absence of an adequacy decision or appropriate safeguards.
- Where the transfer is necessary to perform a contract between us, or the implementation of pre-contractual measures taken at your request.
- To perform a contract that is concluded in your interests.
- For the purposes of establishing, exercising or defending legal claims.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and the EEA.

Data security

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will generally keep personal data for a period of six years from the date of our last services with you (such retention period being necessary in the event of a legal dispute or if we reasonably believe there is a prospect of litigation).

In some circumstances you can ask us to delete your data: see your legal rights for further information.