Last updated: 01 November 2018
When this policy mentions "CITP," "we," "us," or "our," it refers to the "Data Controller", CITP Ltd.
1. Information We Collect
There are three general categories of information we collect.
1.1 Information You Give to Us
We ask for and collect the following personal information about you when providing you the service(s) you have requested. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested service(s).
- Contact Details. When you first call us, register your interest for a specific service or begin filling out an online application form, we require certain information such as your title, first name, last name, email address and phone number.
- Service Related Information. Depending on the requested service(s) we may require additional information that is necessary for us to be able to provide your request. This may include information such as your date of birth, national insurance number, current occupation, disabilities, learning difficulties, home address, qualifications, passport-sized photograph and your current employer.
- Payment Information. To purchase our services, we require you to provide certain financial information (like your debit or credit card information and billing address) in order to facilitate the processing of payments.
- Communications with CITP. When you communicate with CITP, we collect information about your communication and any information you choose to provide.
We Automatically Collect When you visit our website(s), register interest in one of our services and/or purchase one of our services, we automatically collect information, including personal information. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve our services.
- Usage Information. We collect information about your interactions with our websites such as the pages or content you view, or the actions you may take.
- Log Data and Device Information. We automatically collect log data and device information when you access and our websites, even if you have not entered any details. That information includes, among other things: details about how you’ve used our websites, IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using our websites.
- Payment Transaction Information. CITP collects information related to your payment transactions, including date and time, payment amount, and billing address and other related transaction details. This information is necessary for the adequate performance of the contract between you and CITP.
1.3 Information We Collect from Third Parties
Construction Support may collect information, including personal information, that others provide about you, or obtain information from other sources and combine that with information we collect through. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
We collect information about your qualifications, achieved CSCS and affiliated cards, health & safety test results, and course results. This information helps us to verify if you are eligible for certain services you have requested and helps us provide the services more efficiently. CITB makes this information is publicly available on their Online Card Checker as long as we have your surname, national insurance number, date of birth and/or individual ID/registration number.
- From your Employer.
If your employer purchases one of our services in your behalf, they will provide the required information to provide our services with your consent.
- Other Sources.
To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you.
2. How We Use Information We Collect
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the services provided by CITP, create and maintain a trusted and safer environment and comply with our legal obligations.
2.1 Provide, Improve, and Develop Construction Support services
- Enable you to request and purchase services provided by CITP
- Operate, protect, improve, and optimize the services provided by CITP and experience, such as by performing analytics and conducting research.
- Provide customer service.
- Send you service or support messages, updates, security alerts, and account notifications.
- To operate, protect, improve, and optimize the services provided by CITP and experience, and personalize and customize your experience, we conduct profiling based on your interactions with CITP, your personal information, and other content you submit to CITP. We process this information given our legitimate interest in improving the services provided by CITP and our customer’s experience with them, and where it is necessary for the adequate performance of the contract with you.
2.2 Create and Maintain a Trusted and Safer Environment
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Verify or authenticate information or identifications provided by you
- Conduct checks against databases and other information sources, to the extent permitted by applicable laws and with your consent where required.
- Comply with our legal obligations.
- Resolve any disputes with any of our customers and enforce our agreements with third parties.
- Enforce our Terms and Conditions and other policies.
- In connection with the activities above, we may conduct profiling based on your interactions with CITP, your personal information and other content you submit to CITP, and information obtained from third parties. We process this information given our legitimate interest in protecting the services provided by CITP, to measure the adequate performance of our contract with you, and to comply with applicable laws.
2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing
- Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences and social media advertising through social media platforms such as Facebook or Google.
- Personalize, measure, and improve our advertising.
- Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by CITP or its third party partners.
- Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with CITP, information obtained from third parties) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you. We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.
2.4 How we use the Information Collected for Payment Processing
- Enable you to make payments for your required services.
- Detect and prevent fraud, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Conduct checks against databases and other information sources.
- Comply with legal obligations (such as anti-money laundering regulations).
- Enforce our Terms and Conditions.
- With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences. The Data Controller processes this information given its legitimate interest in improving the payment services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
3. Sharing & Disclosure
3.1 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights
CITP may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against CITP, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms and Conditions, or (v) to protect the rights, property or personal safety of CITP, its employees, its customers, or members of the public.
Where appropriate, we may notify customers about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon CITP’s property, its customers and our websites. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that customer about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
3.2 Service Providers
3.3 Social Media Platforms
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.
The social media platforms with which we may share your personal data are not controlled or supervised by Construction Support. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider. Please note that you may, at any time ask CITP to cease processing your data for these direct marketing purposes by sending an email to email@example.com.
3.4 Business Transfers
3.5 Aggregated Data
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. Other Important Information
4.1 Analyzing your Communications
We may review, scan, or analyze your communications with CITP for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
These activities are carried out based on CITP’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
4.2 Google Maps/Earth
5. Third Party Partners & Integrations
CITP may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services ("Third Party Partners"). CITP doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, CITP, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. Your Rights
You may exercise any of the rights described in this section by sending an email to firstname.lastname@example.org. Please note that we may ask you to verify your identity before taking further action on your request.
6.1 Managing Your Information
You may request and update some of your information by contacting us. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
6.3 Data Access and Portability
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide our services, you can request that we erase your personal information. Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain certain information from that account to prevent that individual from opening a new account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, CITP may keep some of your information for tax, legal reporting and auditing obligations.
Because we maintain our platforms to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.5 Withdrawing Consent and Restriction of Processing
Where you have provided your consent to the processing of your personal information by CITP you may withdraw your consent at any time by sending a communication to CITP specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of CITP override your own.
6.6 Objection to Processing
In some jurisdictions, applicable law may entitle you to require Construction Support not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Construction Support will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask Construction Support to cease processing your data for these direct marketing purposes by sending an email to email@example.com.
6.7 Lodging Complaints
You have the right to lodge complaints about the data processing activities carried out by CITP before the competent data protection authorities. You have the right to file a complaint with the Information Commissioner's Office.
7. Operating Globally
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us following the instructions in the Contact Us section below.